Williams v. Lara (2000)
Court Decisions on Religious Liberty
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Background Information
In 1992, the Chaplain's Education Unit (CEU), a separate unit within the Tarrant County Corrections Center (TCCC) in Tarrant County, Texas, was created by the Director of Chaplaincy, Hugh Atwell and Sheriff David Williams, both of whom had absolute control over the curriculum.
The purpose of the CEU was to promote rehabilitation and reduce violence through the teaching of orthodox, fundamentalist Christianity. The Sheriff ensured that what was taught was in accordance with his own personal religious views and that no other religious views could be discussed by volunteer chaplains or followed by any inmates, all of whom were in that section voluntarily.
Court Decision
After a variety of lower court decisions, the Texas Supreme Court took up the case in order to determine the constitutionality of the prison program.
The defendants argued that their goal was secular - to promote rehabilitation and reduce violence. This is a valid, secular goal but it is rendered suspect first, by the fact that Atwell admitted that the same goal could be achieved by other means and, second, by the fact that only one religious viewpoint was permitted. These factors indicate very strongly and another, unstated goal was religious indoctrination.
Furthermore, both Atwell and Williams admitted that they screened the inclusion of religious beliefs not for penological reasons (the only reasons allowed for restricting prisoners' rights) but instead based upon their personal religious biases. The voluntariness of the program was rejected as a valid defense:
...the fact that inmates were willing to submit to the instruction offered does not mean that Williams and Atwell did not promote their own personal religious beliefs over other religious teachings, and their official endorsement of the substance of the religious instruction offered in the CEU goes beyond what the Establishment Clause can tolerate.
Significance
This decision did not eliminate any religious programs in prisons or the position of prison chaplain. What it did, however, is emphasize the fact that prisons cannot become an arena where one religion or one religious perspective can become dominant or be favored by the prison administration.
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