10

TAKING THE WORD TO JAILS AND PRISONS

        From Chaplain Ray to Charles Colson's Prison Fellowship, one of the most active evangelistic movements today is occurring in jails and prisons around the United States. Notwithstanding the usual puns about a captive audience, the men and women who are serving time have come as close to hitting bottom as anyone can, are dealing with the harsh realities of prison life on a day-to-day basis, and are often open to receiving the gospel of Jesus Christ.
        Not only does evangelism in the prison community present an opportunity for Christians, it's a ministry that was mandated by Jesus Himself (Matt. 25:31-46). And, like other forms of evangelistic ministry, it can be a challenging one in which to function.
        The law speaks extensively to the religious rights of prisoners. Over the past twenty years, there have been more court cases that deal with religious rights in prison than any other area in which religion and law intersect. The reason for this is simple: most of the lawsuits that have addressed religious issues in prison were filed by prisoners themselves, who are often more adept at legal maneuvers than many attorneys.
        How many of these lawsuits have involved the rights of Christians to witness in jails and prisons? The answer may surprise you: virtually none. To understand why, in this chapter we'll look at the prison system, discuss how you can pursue evangelistic activities in that system, and explore some of the religion cases that have been decided by the courts.
        Unlike most of the other chapters in this book, this one will not focus on law, but on strategy. Because the legal precedents covering your right to engage in prison ministry are minimal, the best way to function effectively in the prison environment is to understand, from a Christian perspective, how the system works.

A Look at the Prison System

        In the United States, the correctional system consists of prisons, penitentiaries, and correctional facilities at the federal and state levels, as well as prisons and jails at the local level. Correctional institutions are generally segregated in three ways: by sex (with male and female prisoners being housed in different institutions or different wings of the same institution), by age (with prisoners under the age of 18 being housed in youth facilities or detention centers), and security level (ranging from minimum to maximum security, with prisoners on death row segregated from the general inmate population).
        As of 1992, there were more than one million prison inmates in the United States, which imprisons 455 people per 100,000 in the population - more than any other nation in the world. In contrast, the rate in South Africa, the second highest in the world, is 311 people per 100,000. The incarceration rate in Great Britain is only 97 people per 100,000, and the world's lowest rate is in India, with 34 people imprisoned per 100,000.[1]
        Cultural and racial factors appear to play a significant role in the American correctional system, with 3,370 black males per 100,000 in the population imprisoned. A 1990 report by the United States Department of Justice indicated that nearly one in four black males aged 20 to 29 was either in prison, jail, on probation, or on parole.[2] This becomes relevant when one considers that one of the strongest religious movement in American prisons today is the Nation of Islam, or Black Muslim movement. As in the case of other cults when it comes to street ministry, there's both good news and bad news in that fact. The good news is that there have been many Black Muslim cases that have affirmed the religious rights of prisoners in general; the bad news is that there are a lot of inmates who are turning to the Nation of Islam instead of the cross of Christ.
        Daniel Van Ness of the Justice Fellowship, the legal wing of Charles Colson's Prison Fellowship, has observed, "More people live in our prisons than live in the cities of Atlanta or Pittsburgh, in the states of Wyoming or Alaska, or in thirty-nine nations of the world."[3] In 1990, many prisons were so overcrowded that they had a higher population than the towns that surrounded them. These included the California State Prison at Folsom (6,564 inmates), the Louisiana State Penitentiary at Angola (5,176), Mississippi State Penitentiary at Parchman (4,641), Pennsylvania State Correctional Institution at Graterford (4,153), and the State Prison of Southern Michigan at Jackson (4,110).[4] As a result, many states have begun to implement correctional alternatives that include the privatization of prisons, house arrest (in which a person serves his or her sentence at home, wearing a tamper-proof bracelet that emits a radio frequency to a central monitoring center), intensive probation supervision programs, and victim-offender reconciliation programs.[5]
        To say that prison life is not pleasant is an understatement. The first thing that occurs when an offender is put into prison is that the offender loses his or her autonomy. According to Van Ness:

The inmate's life is regulated to the point that his ability and need to make decisions is all but eliminated. Standard clothing is provided. Food is served at specified hours and inmates eat what is given them. Work, if it is available, is assigned, as are educational opportunities. Hours are determined by regulation. Visiting is done at specified intervals.[6]

        Van Ness notes five common traits of the prison experience: the deprivation of liberty, the deprivation of goods and services, the deprivation of heterosexual relationships, the deprivation of autonomy, and the deprivation of security.[7] Donald Smarto of the Institute for Prison Ministries at the Billy Graham Center at Wheaton College identifies factors that include the dehumanizing effects of loss of choice, the threat of violence, abuse from guards, and solitary confinement.[8]
        For prisoners in solitary confinement or on death row, life is even more empty. Jack Henry Abbott, himself a convict, dramatically reflects:

        You sit in solitary confinement stewing in nothingness, not merely your own nothingness but the nothingness of society, others, the world. The lethargy of months that add up to years in a cell, alone, entwines itself about every "physical" activity of the living body and strangles it slowly to death, the horrible decay of truly living death. You no longer do pushups or other physical exercises in your small cell; you no longer pace the four steps back and forth across your cell . . .
        Time descends in your cell like the lid of a coffin in which you lie and watch as it slowly crosses over you. When you neither move nor think in your cell, you are awash in pure nothingness.
        Solitary confinement in prison can alter the ontological makeup of a stone.[9]

        Another trait common among prisoners is a declaration of innocence regarding the commission of the crimes for which they've been imprisoned. Bernard Adeney observed:

Rationalizations are common among prisoners for the crimes that sent them to prison. Chaplain Harry Howard, of San Quentin, once commented to me ironically that it was hard to find a guilty man in San Quentin. One study classified typical rationalizations of prisoners into five groups: 1) denial of responsibility; 2) denial of injury; 3) denial of victim; 4) condemnation of the condemners, and 5) appeal to higher loyalties.[10]

        Yet, for better or worse, the law allows inmates to proclaim their innocence and to petition for the redress of grievances by appealing to various court systems. That right has been ensured, among other methods, by guaranteeing the inmates access to an adequately equipped law library within the prison walls. In Bounds v. Smith (1977), the United States Supreme Court affirmed lower court decisions that require prisons to maintain law libraries for the use of inmates:

The fundamental right of access to the courts require prison authorities to assist inmates in the preparation and filing of meaningful legal papers with adequate law libraries or adequate assistance from persons trained in the law.[11]

        Thus, all prisons, whether state or federal, must maintain a law library for inmates that includes, at minimum, legal reference works such as the decisions of the Supreme Court, the complete federal case reporter system, the complete regional reporter system for the region in which the prison is located, the statutes of the state in which the prison is located, the state digest, Modern Federal Practice Digest, and at least one set of a general reference work on criminal law.[12]
        One thing a prisoner has on his or her hands is time. Combined with the precedents requiring access to legal reference materials, this has resulted in the creation of "jailhouse lawyers," inmates who have done so much research that they often end up knowing more about criminal law, constitutional law, the rules of legal procedure, and the rules of evidence than many attorneys.
        Thanks to both jailhouse lawyers and legal organizations in the prison reform movement, a number of cases have been heard by the courts that have impacted religious rights in prisons.

Religious Life in Prison

        The court system in the United States has traditionally maintained a hands-off attitude regarding the daily operation of prisons and jails, as well as the restrictions placed upon inmates. From 1960 to 1980, however, the prison reform movement filed numerous court cases designed to increase prisoner rights, reduce overcrowding in the prison population, and expand community-based corrections. The peak period for the movement was in the early 1970's after an inmate riot at the Attica prison in New York.
        Many of the cases addressed by the courts included the right of prisoners to have their religious beliefs recognized as legitimate by the correctional system, especially those that represented minority religions such as the Nation of Islam and Buddhism.[13] Other cases have ad dressed the establishment of indigenous religious groups founded by prisoners themselves - some borne out of serious religious commitment, some as a joke, and some as a political tool to manipulate the correctional system.[14]
        Religious issues that have been addressed by the courts over the past twenty years, with mixed results, include the right of prisoners to have the special dietary requirements of their religious faith accommodated by prison administrators,[15] the right of inmates to religious services in their own faith (especially minority religions such as the Nation of Islam and the Native American Church),[16] the right of inmates to receive religious literature by mail,[17] and the right of male prisoners whose religion forbade contact with members of the opposite sex outside of marriage not to be frisked by female corrections officers.[18]
        Traditionally, prisons have tended to favor the Judeo-Christian faiths, to the extent that most prison chaplains represent familiar denominations. In 1979, for example, at the height of the prison reform movement, the Federal Bureau of Prisons employed sixty-three chaplains, of whom forty-one were Protestant, twenty-one were Catholic, and one was Jewish.[19] Dale Pace of the Good News Mission, an interdenominational prison ministry, enumerates the professional qualifications for prison chaplains:

In general the government employer follows the minimum requirements recommended by the [American Correctional Association's] Manual of Correctional Standards. These are that a chaplain possess: (1) college and theological degrees, (2) ordination and ecclesiastical endorsement, (3) parish experience, (4) a minimum of one year of CPE [Clinical Pastoral Education], and (5) the right personality. In addition, a chaplain serving a correctional institution must have the approval of the institution's administration (sheriff, warden, superintendent, commissioner). Some penal system chaplains must also be nominated by a representative personnel committee, either local or state or National Council of Churches.[20]

        While the qualifications for institutional chaplains are presumably not intended to result in religious discrimination, one result is that the overwhelming majority of chaplains tend to come from liberal and mainline denominations. While there are exceptions, most chaplains are not born-again Christians.
        Generally, the mandate of institutional chaplains is to help meet the spiritual needs of persons who are unable to pursue their own religious activities outside an institutional environment. Therefore, chaplains are commonly found in jails and prisons, the military, hospitals, and other restricted settings. While the employment of chaplains by the government would appear to violate the Lemon test (discussed in Chapter 5), the courts generally weigh any potential violation of the Establishment Clause against the Free Exercise Clause and hold that chaplains provide a reasonable accommodation of the spiritual needs institutionalized persons.
        The problem inherent in government-paid chaplaincies is that the chaplains are mandated to meet the spiritual needs of all of their constituents, regardless of whether those constituents (inmates, soldiers, hospital patients, etc.) are Christian. Hypothetically, if a prison inmate asks a chaplain to give him a copy of the Koran, two factors come into play: first, the chaplain cannot refuse the inmate's request if the prison normally provides inmates with copies of the Bible or other religious literature. Second, when the chaplain hands the Koran to the inmate, he or she (the government employs both male and female chaplains) can't say, "You know, brother, this book won't show you the way to salvation. You can only be saved through faith in Christ."
        The same principle exists in other chaplaincy services such as the military. Lieutenant Commander G.M. Clifford of the Navy Surface Weapons Group at Pearl Harbor has observed:

The motto of the Navy Chaplain Corps, "Cooperation Without Compromise," implies that ministry as a chaplain is not intended to alter the chaplain's theology. Yet a likely consequence of ministering in the pluralistic setting of the sea services would seem to be a broadening of the chaplain's theology by influencing that theology to become more inclusive. For example, Chaplains from Christian faith groups are responsible for facilitating pastoral care to Buddhist personnel without trying to convert the person to Christianity and without compromising the chaplain's integrity. Repeatedly engaging in this type of pluralistic ministry seems likely to impact the chaplain's own theology.[21]

        Remember the cases in Chapter 7 ("Taking the Word to Work") that documented how employees in government-affiliated agencies are not permitted to share the gospel on the job? Things aren't quite that bad for chaplains, whose positions are, by nature, religious. But what happens when a chaplain engages in evangelistic activity? Virtually the same thing. In one case, Franklin Baz, a Veteran's Administration chaplain who was an ordained minister in the Assemblies of God, was discharged, in part, because he was too evangelistic. The reasons cited by the Veteran's Administration for his discharge included:

[H]e failed to demonstrate ability to understand a multi-disciplinary approach to patient health care; he failed to understand the need to work within established procedures to accomplish objectives; and he had difficulty in relating to other chaplains which complicated the effective coordination of their spiritual ministry."[22]

        In upholding his dismissal, a federal district court acknowledged a basic difference in the concept of the chaplaincy held by Baz and the Veteran's Administration. In Baz v. Walters (1984), Judge Harold A. Baker wrote:

The [chaplain] saw himself as an active, evangelistic, charismatic preacher while the chaplain service saw his purpose as a quiescent, passive listener and cautious counselor. This divergence in approach is illustrated by [Chaplain Baz's] listing "twenty-nine decisions for Christ" in his quarterly report of activities to the Veteran's Administration. It was one of the matters pointed out [to Chaplain Baz by his supervisor] as unacceptable conduct on the part of a Veterans Administration chaplain.[23]

        While the court acknowledged that Chaplain Baz had established a firm case of religious discrimination, it also held that the views of the chaplaincy service reflected legitimate aims and needs of the Veteran's Administration in conducting its affairs.
        In short, there is little room for government-paid chaplains to engage in active biblical evangelism. While the government is willing to accommodate a person's spiritual needs, chaplains are expected to subscribe to what has often been called "civil religion" - a faith similar to the plain label, no-name brands of foods you might find in the generic products aisle of a supermarket.[24]
        The other difficulty is that members of the clergy are required to have at least one year of Clinical Pastoral Education (CPE) in order to qualify for the chaplaincy. CPE is geared toward training persons in pastoral care, oriented toward a liberal perspective, and often fosters a hostility toward biblical Christianity. According to Dale Pace:

        All who go through CPE seem to be affected by the characteristic of liberalism that places the locus of authority not in theological or biblical doctrine, but vests it in the example of a religious life . . . Thus, the CPE training process seems to cause even evangelical and fundamental chaplains to shift their emphasis and trust (at least to some degree) from God's Word and His Spirit to the influence of their presence as persons.
        From its inception, CPE has failed to emphasize theological content . . . In fact, much hostility has been observed toward sound doctrine (i.e., evangelical theology) from numerous ministers with CPE training.[25]

        Pace conducted extensive surveys of jail and prison chaplains and found, among other things, that CPE-trained chaplains worked less hours per week than those without CPE, have a smaller response by inmates to their religious and counseling programs, and spend less time with inmates in Bible and religious education classes. While non-CPE trained chaplains were less effective as program administrators, they appeared to meet the spiritual needs of prisoners more effectively.[26]

An Opportunity for Ministry

        If prisoners are not receiving a biblical background from chaplains, who is in a position to share the gospel with them?
You are. Many jails and prisons allow outside persons to engage in ministry to inmates and, as an outsider, you have more freedom than state-paid chaplains to engage in biblical discussions that present the Christian gospel without the need to compromise the message. A chaplain can't tell an inmate that he or she is going to hell in a proverbial handbasket because the inmate is a Muslim, Buddhist, or atheist, but you can. (I don't recommend presenting the gospel that way, but use the example to illustrate that you, as a volunteer and an outsider, have more freedom to openly discuss the uncompromised message of Christ than a state-paid chaplain does.)
        The ability to get your foot in the door requires some diplomacy. The fact is that no jail or prison has to allow you into their institution at all. Generally, the courts defer to prison administrators in the interest of maintaining a secure environment, and that includes the freedom of administrators to refuse admission to anyone they feel will convey a message that is not in harmony with the goals of the correctional facility.
        It also includes the right of prison administrators, including chaplains, to determine who will be allowed to convey a religious message behind the institution's walls. The courts have held that as long as a prison makes a reasonable effort to accommodate inmates' religious needs, they need not even allow outside clergy into the prisons to meet specific denominational needs. Thus, if the chaplain of a prison is from any type of Protestant Church, the administration can declare that all Protestant prisoners are covered. If, for example, a prison employs a Presbyterian chaplain, then a prisoner cannot demand that the prison sponsor services conducted by a Baptist. This has been an issue in several cases in which members of the Nation of Islam have sued prison authorities because of their objection to other Islamic groups.
        So, let's get to the bottom line. What rights to you have under the law to go into the prisons and witness to inmates, share the gospel, engage in Bible studies, or hold worship services? For all intent and purpose, none.
        Nonetheless, outside individuals and prison ministries are granted permission to conduct such activities every day, and there are some strategic techniques in which you can engage to pursue a prison ministry.

• Be diplomatic. You and I may know that there are a lot of chaplains who are not saved, but if you expect to get your foot in the door of a prison, I wouldn't accuse a chaplain who professes to be Christian of not knowing the Lord. You may not bring him or her to the cross, but a sense of tact will allow you to reach a greater number of prisoners without having the prison door slammed in your face by a chaplain you've offended.
• Despite the jaded picture I've painted of government-paid and institutional chaplains in this chapter, don't take my portrait as too wide a stereotype. There are chaplains out there who know and love the Lord, but their hands are often tied by the bureaucracy in which they work. They may see you as a vehicle for getting the gospel to inmates in a manner in which they can't engage. Remember, not all chaplains are the enemy.
• Check out smaller, local jails located near you that don't have a chaplain. Approach the warden or superintendent and ask if you can begin a Bible study at the jail for inmates. Stress that your goal is to assist in the rehabilitation of the prisoners, and that Christian prisoners have a good track record when it comes to prison behavior. If possible, avoid born-again "jargon" that a non-Christian administrator wouldn't understand. If the warden perceives some benefit from an administrative perspective, he or she is more likely to grant you admission to the prison. You may also be able to serve as the volunteer chaplain for that jail and, if they do not have services already, may be able to conduct worship for the prisoners. Remember that despite the qualifications for government-paid chaplains, you do not have to be an ordained member of the clergy to engage in this type of ministry, especially on a volunteer basis; the Lord may open a door you did not expect to be opened for you.
• Even if a jail already has a chaplain, there are many opportunities to share the gospel with prisoners in the course of volunteer work. Call the chaplain and ask how you can be used to minister to prisoners. Also remember that God is sovereign. Even if the chaplain isn't a born- again Christian, the Holy Spirit can still see that you are placed in a position to engage in ministry. One helpful suggestion: instead of approaching the chaplain and telling him or her, "Here's what I want to do," ask where there's an opportunity for you to be used. Remember that when you enter the prison, you're in someone else's domain, not your own. Believe that God will use you to His glory, and you'll find the right opportunity to engage in ministry.
• Even if you can't engage in worship services or a Bible study in prison, don't rule out visiting inmates on a one-to-one basis. Even Jesus didn't speak about evangelistic crusades in jails; he merely addressed visiting prisoners (Matt. 25:31-46). Your one-on-one visitation can be more of a blessing to a prisoner, not to mention a Christian witness, than group evangelistic activities. Some prisons require that you be placed on an individual inmate's approved visitor list in order to enter the facility; check with your local prison to determine their policy.
• Another way of engaging in ministry with inmates is through correspondence. Residents of your local area may benefit from this type of ministry when they are arrested on criminal charges. Two suggestions regarding correspondence with inmates: First, you should consider renting a post office box so your address does not become known to prisoners. Generally, correspondence ministry is safe, but you don't want the wrong person showing up at your doorstep at three o'clock in the morning. Using a post office box provides an added measure of security for yourself. Second, you should be aware that some prisoners write sexually graphic letters (especially male inmates writing to women). You should discern whether you wish to engage in correspondence with a prisoner engaging in this type of writing (after all, he may still come to know the Lord) or whether you should terminate the correspondence relationship.
• If you have foreign language skills, especially Spanish, prisons present a special opportunity for ministry. Some prisons have significant Hispanic inmate populations, and they are often incarcerated in areas where there is not a large Hispanic population on the outside. Your skills in this area provide may be a real blessing to them. Other special needs prison populations include women and Asian inmates, who are often neglected in rural prison environments.
• Learn and follow jail or prison rules about the admission of visitors and other outsiders. Make sure you take identification with you, and be prepared to empty your pockets or be searched for weapons prior to entering an inmate area. Especially, be sure that you cooperate with correctional officers and guards and that you don't exhibit a poor attitude. Security measures are part of the cost of being able to enter a jail or prison to visit or engage in ministry; if you resist or act offended, the guards simply won't let you in.
• When entering a prison or jail, you may be asked to sign a waiver releasing the prison authorities from any liability if you are injured or taken hostage. The chance of anything bad happening to you is very slight; nonetheless, you should be aware of the waiver process before you go into the jails.
• When sharing the gospel, don't feel that you have to water down the message. However, use tact. If you preach to a group of Muslims and put too much stress on their being "damned to an eternal lake of fire and brimstone" (or emphasize other negative sermon lines), don't expect to be invited back into the prison.
• When sharing with non-Christian inmates in a small group situation, be subtle. If the prison you're visiting has a large Muslim population, remember that a prisoner who accepts Jesus may be harassed by fellow inmates. A prisoner's religious affiliation is often dictated by the extent to which he or she may be hassled by other prisoners. That shouldn't prevent you from witnessing, but keep the social factors inherent in prison life in mind and be prepared to discuss the ramifications of Christianity with inmates from their perspective.
• As in other situations that may place you in a potentially dangerous situation, use a team approach when working with prisoners. If you have never engaged in prison ministry, contact a local or national prison ministry or read some books on witnessing to inmates. As always, be especially protective of any female members of your team; women should never be left alone with male prisoners, either one-on-one or in a group situation. Remember that in a jail or prison, there is an added possibility of rape or a hostage crisis. You don't have to be paranoid, but use discernment and street smarts.
• Prison inmates are often adept at psychological manipulation. Therefore, learn to discern the difference between a prisoner who's making a sincere inquiry or commitment to Christ and one who, for lack of a better term, is engaging in "jive." Be wary of inmates who seek personal favors from you, especially when they write to you, and make sure you do not give anything to an inmate that is considered contraband by the prison administration. (A list of contraband items is generally available at the prison.)
• The need for ministry to prisoners doesn't end when they are released from prison. Another opportunity to consider is volunteering to work with released inmates in a halfway house as they make the transition back into society. There are both Christian and non-Christian halfway houses, and both types present an opportunity to spend quality time with men and women who have been released from prison to share the gospel message with them on both an individual and group basis. There is a high recidivism rate among released prisoners (the rate at which persons who have been convicted of a crime are likely to commit another crime). In addition to sharing Christ with released inmates, your ministry in an aftercare environment can help lower the rate or recidivism.
• Above all, go in prayer and come out in prayer. I've never seen a riot start as a result of prison evangelism, but it helps to remember that the early evangelists did start a few riots in the name of Jesus (Acts 17:6-8). When it comes to people responding to the gospel message, God has been known to perform a few miracles in jails and prisons. Strategy and technique are important, but prayer will always be your best weapon.

        Jails and prisons are not a pleasant place, but despite their flaws, inmates have a keen sense of reality. Many of them have been down so long that the only way they can go is up, and they are often one of the most receptive audiences for hearing and responding to the Word of God. Those who do make a commitment to Christ have had their lives changed and, from an evangelistic perspective, there are great blessings to be gained from engaging in a prison ministry.

NOTES

        1. Howard Goodman, "U.S. Jail Rate Still Tops World," The Philadelphia Inquirer, 11 February 1992, p. A3.
        2. Ibid.
        3. Daniel Van Ness, Crime and Its Victims (Downers Grove, IL: InterVarsity Press, 1986), 44.
4. Howard Goodman, "Prison Bursting at the Bars," The Philadelphia Inquirer, 12 March 1990, p. 2-A.
        5. For more information on prison alternatives, see Charles Colson and Daniel Van Ness, Convicted: New Hope for Ending America's Crime Crisis (Westchester, IL: Crossway Books, 1989).
        6. Van Ness, Crime and Its Victims, 53-54.
        7. Ibid., 44.
8. Donald Smarto, Justice and Mercy (Wheaton, IL: Tyndale House, 1987), 22.
9. Jack Henry Abbott, In the Belly of the Beat (New York: Vintage Books, 1981), 53.
        10. Bernard T. Adeney, "Living On the Edge: Ethics Inside San Quentin," Journal of Law and Religion 6 (1988): 442.
        11. Bounds v. Smith, 430 U.S. 817, 828 (1977).
        12. Craig v. Hocker, 405 F.Supp. 656 (D.Nev. 1975).
        13. See, e.g., Cooper v. Pate, 378 U.S. 546 (1964); Cruz v. Beto, 405 U.S. 319 (1972).
        14. Steve Levicoff, The New Song of Shiloh: An Historical, Legal, and Theological Exploration of an Indigenous Prison Church (Ph.D. Dissertation, The Union Institute, 1991).
        15. For a summary of cases dealing with the religious accommodation of dietary needs, see Religion In the Constitution: A Delicate Balance (Washington, DC: United States Commission on Civil Rights, Clearinghouse Publication No. 80, September 1983), 67-72, and James J. Gobert and Neil P. Cohen, Rights of Prisoners (Colorado Springs, CO: Shepherd's/McGraw-Hill, 1981), 152-154.
        16. See, e.g., Knuckles v. Prasse, 307 F.Supp. 1036 (E.D.Pa. 1969), aff'd., 435F.2d 1255 (3d Cir. 1970), cert. denied, 403 U.S. 936 (1977). See also the statement of Larry Taylor, warden at the Federal Correctional Institution at Lompoc, California, in Religious Discrimination: A Neglected Issue, a consultation sponsored by the United States Commission on Civil Rights in Washington, DC, in April 1979 (Washington, DC: United States Commission on Civil Rights, 1969), 129.
        17. Lawson v. Dugger, 840 F.2d 781 (11th Cir. 1987); Walker v. Blackwell, 411 F.2d 23 (5th Cir. 1969).
        18. Madyun v. Franzen, 704 F.2d 954 (7th Cir. 1983); Rivera v. Smith, 472 N.E.2d 1015 (N.Y. 1984).
        19. Richard A. Houlihan, priest and administrator, Federal Prison Systems Chaplaincy Services, consultation statement in Religious Discrimination: A Neglected Issue, 131.
        20. Dale K. Pace, A Christian's Guide to Effective Jail & Prison Ministries (Old Tappan, NJ: Fleming H. Revell, 1976), 117.
21. G.M. Clifford, III, "Ministry in a Pluralistic Environment," Military Chaplains' Review (Summer 1992): 67.
        22. Baz v. Walters, 599 F. Supp. 614, 618 (C.D.Ill. 1984).
        23. Ibid. at 617.
        24. See, e.g., Gail Gehrig, American Civil Religion: An Assessment, SSSR Monograph Series No. 3, (Washington, DC: Society for the Scientific Study of Religion, 1979). See also Richard V. Pierard and Robert D. Linder, Civil Religion and the Presidency (Grand Rapids: Academie Books, 1988).
        25. Pace, Jail & Prison Ministries, 100-101, 144. See also Jenny Yates Hammett, "A Second Drink at the Well: Theological and Philosophical Content of CPE Origins," Journal of Pastoral Care 29 (June 1975): 86-89.
        26. Ibid., 98-100.