In Cruz v. Beto, the U.S. Supreme Court in 1971 ruled on a case involving religious freedom within prisons. Fred Cruz, an inmate at Texas Department of Corrections, claimed that his First Amendment rights were violated as he was denied the ability to practice Buddhism while incarcerated and faced retaliation for filing lawsuits against prison officials regarding this matter. The court held that prisoners have a right to reasonable opportunities to exercise their religious freedoms under the First Amendment unless there are justifiable reasons related to prison discipline or security preventing it from being so. However, they also found no evidence of deliberate retaliatory punishment by prison officials towards Cruz due to his legal activities which would constitute violation of constitutional rights protected under Section 1983 (Civil Rights Act). Therefore, while affirming prisoner's right to practice religion freely barring legitimate penological concerns, the court did not find sufficient proof supporting Cruz's allegations about punitive reprisals.

In the dissenting opinion for Cruz v. Beto, it was argued that the majority's decision to remand the case back to lower courts failed to properly address and resolve key issues at hand. The dissenting justices believed that there was sufficient evidence presented by petitioner Fred Cruz indicating a violation of his First Amendment rights due to religious discrimination in prison. They contended that this issue should have been directly addressed by the Supreme Court rather than being sent back down for further proceedings. Furthermore, they expressed concern over potential bias in lower courts given their previous dismissals of Cruz's complaints without holding evidentiary hearings or making findings of fact on record.