The demise of RFRA came about in 1997 when the Archbishop of San Antonio, Tex., ("Bishop") brought an action against the City of Boerne, Tex., after the Catholic Church was refused a building permit by the City of Boerne to expand the size of its 73-year- old church located in a designated historic district of the town. During the pre-RFRA era, the courts used a shifting burden approach to determine adverse constitutional impact on an inmate's First Amendment religious rights. First, the government must provide evidence that the particular restriction placed on the inmate's freedom was based on security or similar issues. Having done so, the burden then shifted to the inmate to demonstrate by substantial evidence that the government's position was without basis or was overstated. After RFRA, however, the burden of proof shifted from the inmate to the government, which then had to demonstrate that the adverse impact on religious freedom was necessary because of compelling governmental interests. In "Bishop," the majority of the Court viewed RFRA as sweeping coverage that ensured its intrusion at every level of government, displacing laws and prohibiting official actions of almost every description and regardless of the subject matter. RFRA's restrictions had applied to every agency and official of Federal, State, and local government. RFRA also applied to all Federal and State law, statutory or otherwise, whether adopted before or after its enactment. RFRA made any law subject to challenge at any time by any individual who alleged a substantial burden on his/her free exercise of religion. Correctional administrators, attorneys general, and those who lobby Congress on behalf of corrections should use due diligence to continue to monitor this issue and be prepared to mount a concerted effort to exempt governmental institutions from any future legislative effort by Congress similar to RFRA. 5 notes