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37 Colum. Hum. Rts. L. Rev. 523 (2005-2006)
The Silence of Prayer: An Examination of the Federal Bureau of Prisons' Moratorium on the Hiring of Muslim Chaplains

handle is hein.journals/colhr37 and id is 531 raw text is: THE SILENCE OF PRAYER: AN
Stephen Seymour*
Incarceration by its nature denies a prisoner participation in the
larger human     community. To deny      the opportunity to affirm
membership in a spiritual community, however, may extinguish an
inmate's last source of hope for dignity and redemption.
- Justice William J. Brennan1
In the wake of the 9/11 terrorist attacks, the United States
government authorized the Office of the Inspector General (OIG) to
conduct a thorough review of the Federal Bureau of Prisons (BOP)
out of concern that Islamic terrorists may be recruiting from the
Muslim population in federal and state prisons. This suspicion soon
crystallized as authorities learned that high-profile terrorist suspects
Jose Padilla and Richard Reid each had converted to Islam while
imprisoned in Florida and England, respectively.2 In the course of its
*    The author is a J.D. candidate at Columbia Law School, 2006. He
graduated with distinction from Yale University in 1998 with a B.A. in political
science. He is a chapter editor for the Jailhouse Lawyers' Manual for
2005-2006. Special thanks to Kendall Thomas for his guidance in writing this
note. Thanks also Ryan Marks and Carolina Holderness for endless dedication
and editing; Kate Weisburd for being a fantastic advisor; and to Jennifer
Pastore for her insightful inputs and support.
1.   O'Lone v. Estate of Shabazz, 482 U.S. 342, 368 (1987) (Brennan, J.,
dissenting). Justice Brennan dissented from the Supreme Court's holding that
prison administrators did not violate the constitution by restricting inmates who
were on work details from attending weekly Muslim services because the
regulations were reasonably related to legitimate penological objectives.
2.   Off. of the Inspector Gen., A Review of the Federal Bureau of Prisons'

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