After a lengthy appeals process, the 4th Circuit Court of Appeals has rejected an RLUIPA suit brought by an inmate claiming a denial of religious freedom rights.Johan Krieger practices Asatru, a polytheistic faith from Northern Europe. He argued the need for an outdoor worship circle to practice his faith, which prison officials denied. The Appeals Court said he had not established why the worship circle needed to be outside.

The appeals court said Krieger had to show that denial of the worship circle and other materials substantially burdened his ability to practice his religion. To establish such a substantial burden, an inmate must show that the government “substantially pressured him to modify his behavior and to violate his religious beliefs.”

Krieger argued that the outdoor worship circle was necessary to practice his faith because the Blot ceremony is best performed outdoors. However, the appeals court found that “Krieger failed to offer any explanation regarding the reason why indoor worship would compromise his religious beliefs.”

You can read the opinion here.