Holding: A state's refusal to allow a death row inmate's family members to serve as spiritual advisors in the execution chamber does not substantially burden religious exercise under RLUIPA when reasonable alternative accommodations are available.
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Shockley v. Adams (4:25-cv-01513-SRC) is a Free Exercise case decided by the U.S. District Court in 2025. The court held that a state's refusal to allow a death row inmate's family members to serve as spiritual advisors in the execution chamber does not substantially burden religious exercise under RLUIPA when reasonable alternative accommodations are available.