The original topic under discussion involves the US government by way of Boise police arresting people for not being in shelters - in some cases there were beds available that came with mandatory religious programs and the 9th circuit court held that that was insufficient to count as freely offered housing.

People were, essentially, arrested for not attending religious ceremonies - there is a lot more interesting nuance here, but suffice to say that the 1st Amendment is absolutely relevant if people are potentially being jailed by the state due to a failure to attend religious ceremonies.