Prison and Religion

Clifton Williams has been a practicing Muslim for 20 years but is currently incarcerated at State Correctional Institution Mahanoy. During one of his scheduled work times in the kitchen he had not yet been given any assignments, so he decided to complete one of his five daily prayers. He found an isolated corner away from the working area where he could pray, but prisoners were not permitted to occupy unauthorized areas on their own. After five minutes of prayer he was ordered to return to his duties in the kitchen but he refused; he was eventually removed from the kitchen and taken back to his cell. Williams was punished for refusing to obey an order, and for occupying an unauthorized area. Williams pleaded guilty to the misconduct charges because, in the Muslim faith, once a prayer has commenced one must continue until it is finished. Williams filed a civil rights action pursuant against SCI Mahanoy for violating the Free Exercise Clause of the First Amendment. In order for there to be a violation, he must show that the facility prevented him from “engaging in his religion without any justification reasonably related to legitimate penological interests.”

Balancing the rights of the incarcerated and maintaining a safe environment for the inmates as well as the guards is a complex topic. Based on the ruling, it was determined that there was no violation of the Constitution because the guards have an obligation to maintain safety and security within the prison. With nearly 400 inmates and just 26 guards, the inmates cannot be left alone in an unauthorized area. Prisoners also have plenty of time to pray in their cell, that is why they are not permitted to pray during work hours. The conflict here is whether or not the prison should make accommodations for Muslim inmates so that they can have access to a clean room for prayer. In the past, during Ramadan, the facility provided a separate room for Muslim inmates to pray. In the meantime, prisoners are supposed to use the break room and or their cells to practice Salah. Williams complained that the break room did not suffice because other inmates tracked dirt and urine on the floor. I feel that making a special room for prayer would be an accommodation that violates the Lemon Test, because it would favor Islam and it would not serve a secular purpose. Another solution would be to implement a new ‘leave and return’ policy which would allow inmates to leave work in order to go and pray. This would require the inmates, like Williams, to be removed from work with an escort. However, this could cause further conflict by weakening the security force overlooking the inmates in the kitchen, and other prisoners would take advantage of this accommodation to get out of work. I feel that in order to maintain a maximum security level, without making special religious accommodations, and enabling the Muslim inmates to practice their religion with relative freedom; their five prayers must take place in their designated cells or in the break room. This would not interfere with their labor hours, nor would it jeopardize the level of security within the prison.