Privilege through Prayer: Examining Bible-Based Prison Rehabilitation Programs under the Establishment Clause


In early June of 2006, an Iowa federal judge found a publicly-funded prison ministry to be in violation of the Establishment Clause and ordered it stopped. The program in question, the InnerChange Freedom Initiative, conceived and maintained by Prison Fellowship Ministries, utilized an overtly Christian model to rehabilitate inmates through spiritual and moral regeneration. In the eyes of the court, the failure of the state of Iowa to provide a reasonable secular alternative had the primary effect of advancing religion and fostered excessive governmental entanglement under a traditional Lemon analysis. Equally important in the court’s decision was the lack of conclusive evidence demonstrating a positive effect upon recidivism rates of InnerChange inmates compared with the rates of inmates within the general Iowa prison population. This comment addresses the seemingly endless problem of inmate recidivism in light of both studies evaluating the effectiveness of the InnerChange program, as well as more general solutions proposed under the Faith-Based Initiative. The fallout from Americans United for a Separation of Church and State v. Prison Fellowship Ministries, 432 F.Supp.2d 862, could not only impact future decisions of prison administrators but potentially limit the application of the Bush Administration’s controversial Faith-Based Initiative.


Constitutional Law | Religion Law

Date of this Version

December 2006