Resource: Cruz v. Beto

Petitioner prisoner, an alleged Buddhist, complained that he was not allowed to use the prison chapel, that he was prohibited from writing to his religious advisor, and that he was placed in solitary confinement for sharing his religious material with other prisoners. The Federal District Court denied relief without a hearing or findings, holding the complaint to be in an area that should be left "to the sound discretion of prison administration." The Court of Appeals affirmed.