TWO DISTINCT APPROACHES HAVE TRADITIONALLY BEEN TAKEN BY THE COURTS - EITHER A COMPELLING INTEREST STANDARD OR, AS A FUNCTION OF SPECIAL PRISON CIRCUMSTANCES, A REASONABLENESS STANDARD. HOWEVER, IN KAHANE V. CARLSON (1975), THE SECOND CIRCUIT APPLIED YET ANOTHER TEST IN ITS CONSIDERATION OF THE NECESSITY OF ACCOMODATING THE RELIGIOUS DIETARY REQUIREMENTS OF PRISONS - THE IMPORTANT OR SUBSTANTIAL INTEREST STANDARD. WHILE THIS THIRD TEST FALLS SOMEHWERE BETWEEN THE TWO PREVIOUSLY USED STANDARDS, NO EXPLICIT DEFINITION WAS OFFERED AS TO ITS BOUNDARIES. IT IS SUGGESTED THAT BY EMPLOYING A STANDARD DIFFERENT IN SOME UNDEFINED DEGREE FROM BOTH THE REASONABLENESS AND COMPELLING INTEREST TESTS, THE SECOND CIRCUIT FURTHER COMPLICATED AN ALREADY CONFUSED AREA WITHOUT CONSTRUCTIVELY CONTRIBUTING THERETO. (AUTHOR ABSTRACT MODIFIED)