see pp. 39f. of the pdf: http://www.supremecourt.gov/orders/courtorders/022916zor_7lho.pdf
The Court undoubtedly denied *cert.* because the pro se filing was very weak, verging on unintelligibility: http://www.scotusblog.com/wp-content/uploads/2015/12/Petitioners-Brief.pdf Alito appears to be correct that it's a Lukumi violation--indeed, almost certainly also a violation of the Freedom of Assembly Clause, as it involves straightforward sect discrimination in setting rules for collective prisoner bible studies. However, it appears that the prisoner failed to press a discrimination claim, or to cite Lukumi, in the district court, the court of appeals, or in his petition--so that it was litigated on straight Turney v. Safley terms. (A reply brief was finally filed by counsel a couple of weeks ago, after the Court had reconferenced the case multiple times. I'll send it around if I can find it.) Interestingly, Alito appears to concede that a showing of "substantial burden" is necessary in a Lukumi discrimination case. As far as I know, however, the Court has never addressed that question.
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