Outside Clergy Requirement for Ramadan Services Upheld
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Officials at a county prison provided for communal worship during Ramadan only if an outside leader could be found. This restriction did not violate the Turner standard because the Ramadan participants came from different housing units, raising order and security concerns; the plaintiff had other means of religious expression available, since he could fast during the day (defendants made meals available at alternative times) and could go to weekly services; and nothing impeded his individual prayer. The prison didn't have enough staff to oversee all group activities. See: Muhammad v. Klotz, 36 F.Supp.2d 240 (E.D.Pa. 1999).