O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987).

Prison Fellowship. (2023). Annual report 2022. Prison Fellowship Ministries.

Ramirez v. Collier, 595 U.S. 411 (2022).

Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C. §§ 2000cc et seq.

Rideau, W. (2010). In the place of justice: A story from inside the world’s largest penitentiary. Alfred A. Knopf.

Notes

1 Carson, E. A. (2021). Prisoners in 2020—Statistical tables. U.S. Department of Justice, Bureau of Justice Statistics. The United States incarcerates approximately 629 per 100,000 residents (when Carson wrote)—a rate that exceeds every other nation for which reliable data are available. The most recent figure (Bureau of Justice Statistics, 2024) is closer to 541 per 100,000 for sentenced state and federal prisoners.

2 Colson, C. W. (1976). Born again. Chosen Books. Colson’s memoir remains the most widely read account of conversion and prison ministry in the evangelical tradition.

3 Prison Fellowship. (2023). Annual report 2022. Prison Fellowship Ministries. The Angel Tree program alone has served more than 12 million children since its inception.

4 Earley served as President of Prison Fellowship from 2002 to 2012, during which period the organization expanded both its direct ministry programs and its policy advocacy work.

5 Duwe, G., & King, M. (2013). Can faith-based correctional programs work? An outcome evaluation of the InnerChange Freedom Initiative in Minnesota. International Journal of Offender Therapy and Comparative Criminology, 57(7), 813-841.

6 Duwe & King (2013), pp. 833-836. The cost-benefit analysis used conservative assumptions regarding the monetization of recidivism reduction.

7 For a discussion of the methodological challenges in evaluating faith-based correctional programs, see Johnson, B. R. (2011). More God, less crime: Why faith matters and how it could matter more. Templeton Press, pp. 153-178.

8 Rideau, W. (2010). In the place of justice: A story from inside the world’s largest penitentiary. Alfred A. Knopf. Rideau, who spent 44 years at Angola as both an inmate and the editor of the prison magazine The Angolite, provided an insider’s account of the prison’s transformation.

9 Hallett, M., Hays, J., Johnson, B. R., Jang, S. J., & Duwe, G. (2017). The Angola prison seminary: Effects of faith-based ministry on identity transformation, desistance, and rehabilitation. Routledge, pp. 28-45. It should be noted that Cain resigned Jan 1, 2016, amid Advocate reporting on real-estate dealings with inmate-family-connected developers and prisoner death-bed videotape allegations. He was cleared by the Louisiana State Police, OIG, and Department of Public Safety and Corrections. The state legislative auditor flagged corrections employees working on Cain’s private residence on state time. He currently runs the Mississippi Department of Corrections.

10 Hallett et al. (2017), pp. 89-112. The deployment of inmate ministers as hospice workers was particularly significant, given that Angola houses a large population of aging lifers who will die within the institution.

11 Hallett et al. (2017), pp. 113-145. The authors drew on Maruna’s (2001) desistance theory and Giordano et al.’s (2002) theory of cognitive transformation to explain the identity shifts observed among seminary participants.

12 Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C. §§ 2000cc et seq.

13 Cruz v. Beto, 405 U.S. 319 (1972).

14 O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987).

15 Cutter v. Wilkinson, 544 U.S. 709 (2005).

16 Holt v. Hobbs, 574 U.S. 352 (2015).

17 Ramirez v. Collier, 595 U.S. 411 (2022). Chief Justice Roberts, writing for the majority, emphasized that “the government may not substantially burden” a prisoner’s religious exercise even in the execution chamber.

18 Alper, M., Durose, M. R., & Markman, J. (2018). 2018 update on prisoner recidivism: A 9-year follow-up period (2005–2014). U.S. Department of Justice, Bureau of Justice Statistics.

19 Johnson, B. R., & Larson, D. B. (2003). The InnerChange Freedom Initiative: A preliminary evaluation of a faith-based prison program. Center for Research on Religion and Urban Civil Society, University of Pennsylvania. The distinction between completer-only and intent-to-treat analyses is critical and has been the source of significant debate in the literature. There were 177 study participants, but only 75 completed all phases, and the 8% rearrest figure applies to those 75 graduates.

20 Johnson, B. R., Larson, D. B., & Pitts, T. C. (1997). Religious programs, institutional adjustment, and recidivism among former inmates in prison fellowship programs. Justice Quarterly, 14(1), 145-166.

21 Clear, T. R., & Sumter, M. T. (2002). Prisoners, prison, and religion: Religion and adjustment to prison. Journal of Offender Rehabilitation, 35(3-4), 127-159.

22 Correctional Service of Canada. (2019). Commissioner’s Directive 750: Spiritual services and interfaith committees. Government of Canada.

23 Beckford, J. A., & Cairns, I. C. M. (2015). Muslim prison chaplains in Canada and Britain. The Sociological Review, 63(1), 36-57.

24 R v. Zundel, [1992] 2 S.C.R. 731 (striking down Criminal Code §181, the "false news" provision). Zündel was subsequently deported to Germany in 2005 under a national-security certificate and convicted under §130 of the German Criminal Code (Volksverhetzung) in February 2007, receiving the maximum five-year sentence; he was released in 2010 and died in Germany in 2017.

25Criminal Code of Canada, §319(2.1), added by the Budget Implementation Act, 2022, No. 1, S.C. 2022, c. 10. Maximum sentence under this provision is two years’ imprisonment. R v. Paulin (Ontario Court of Justice, North Bay, September 18, 2025) was the first carceral sentence imposed under the new provision. Section 319(2.1) criminalizes “willfully promoting antisemitism by condoning, denying, or downplaying the Holocaust.” The law exists; just how many people have actually been imprisoned under it is unclear (most cases settle as fines or dropped charges). Prison is the law’s theoretical maximum, not necessarily its applied reality.

26 Bill C-16, An Act to amend the Canadian Human Rights Act and the Criminal Code, S.C. 2017, c. 13. Jordan Peterson, then a professor at the University of Toronto, rose to international prominence through his public refusal to comply with what he characterized as compelled speech under the legislation.

27 Law Society of British Columbia v. Trinity Western University, 2018 SCC 32; Trinity Western University v. Law Society of Upper Canada, 2018 SCC 33. The 7-2 decisions held that provincial law societies could refuse to accredit TWU's law school on the ground that its community covenant—requiring students to abstain from sexual activity outside heterosexual marriage—was discriminatory toward LGBTQ persons.

28 Pawlowski’s arrests and incarcerations between 2020 and 2023, including the May 2021 arrest on a Calgary highway for the offense of holding a Passover service, attracted significant international attention. He was sentenced in October 2023 to sixty days in jail and a $23,000 fine for inciting mischief during the Coutts border blockade—a charge stemming from a sermon he delivered to protesters. See R v. Pawlowski, 2023 ABKB 591.

29 Emergencies Act, R.S.C. 1985, c. 22 (4th Supp.), invoked February 14, 2022, in response to the Freedom Convoy protests. The Federal Court subsequently ruled in Canadian Frontline Nurses v. Canada (Attorney General), 2024 FC 42, that the invocation was unreasonable and violated §§ 2(b) and 8 of the Charter.

30 Americans United for Separation of Church and State v. Prison Fellowship Ministries, 509 F.3d 406 (8th Cir. 2007).

31 Americans United, 509 F.3d at 424-425. The Eighth Circuit upheld the district court’s finding that the IFI program in Iowa’s Newton Correctional Facility violated the Establishment Clause because it was pervasively sectarian and received direct state funding.

32 Mai & Subramanian (2017). The Price of Prisons: Examining State Spending Trends, 2010–2015. Vera Institute of Justice. Per-inmate costs vary dramatically by state, from $14,780 in Alabama to $69,355 in New York.