Their basic constitutional right to worship has been reinforced by decades of court decisions and more recently by the Religious Land Use and Institutionalized Persons Act.

Chaplains, volunteers and other representatives of these groups may organize religious services as often as daily in large prisons, while also providing pastoral care to inmates and staff.

[11] One recent study has suggested that such programs help to reduce a host of undesirable and unhealthy behaviors, like drug use, violence and risk taking.

[13] For instance, court actions recognizing Zen Buddhism as an "acceptable religion" have secured meditation programs in New York prisons.

[19] In 2006, Scott Jensen chose to remain on the ministry board after he was forced to leave the Wisconsin State Assembly following a felony conviction that was later overturned.

In 2005 Cutter v. Wilkinson came down on the side of at least three Neopagan prison inmates protesting the denial of access to ceremonial items and opportunities for group worship.

Yet in their decision the court reinforced the notion that "should inmate requests for religious accommodations become excessive, impose unjustified burdens on other institutionalized persons, or jeopardize an institution's effective functioning, the facility would be free to resist the imposition.