Holding that because NA's twelve steps are grounded in "a religious concept of a Higher Power," "the program runs afoul of the prohibition against the state's favoring religion in general over non-religion," despite its references to a God not being tied to any particular faith
Holding that the plaintiff established the second element of his prima facie case for failure to accommodate his “religious practice of attending the ceremony in which his wife and children were converted to Judaism,” where the plaintiff's supervisor “knew” that he was Jewish, “knew” that his “wife was studying for conversion,” and “when [the plaintiff] requested the time off, he informed the [supervisor] why he needed to miss work”
Holding that it is a violation of the Establishment Clause of the United States Constitution to condition an inmate's participation in extended family visitation on his attending a rehabilitation program that included religious tenets