On December 29, 2006, the US Court of Appeals for the Fourth Circuit upheld the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). Virginia was sued by an inmate claiming he was refused a kosher diet as required by his religion. RLUIPA prohibits governments from imposing regulation upon inmates that engenders religious discrimination. Virginia argued that federal funding for prisons was improperly tied to state compliance with RLUIPA. The court disagreed, finding that "RLUIPA is a valid exercise of Congress' spending power and that, because Virginia voluntarily accepted federal correctional funds, it cannot avoid [its] substantive requirements."



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