FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND EMAIL: Tam my.Westcott@tulsad rugcourt.com Ms. Tammy Westcott COURTS Program Director Tulsa Veterans Treatment Court 16 E. 16th St. #202 Tulsa, OK 74119 Re: Unconstitutional Religious Work Program Dear Ms. Westcott: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Tulsa Veterans Treatment Court. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are ?thher informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Co-Pmidemr the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Tulsa Veterans Treatment Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Ntlron, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemno, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Tulsa Veterans Treatment Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel 7- 3 exploitative/2017110? 1/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (603) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (580) 795-2169 The Honorable Wallace Coppedge District Judge Marshall County District Court, Johnston County District Court (interim) PO Box 58 Madill, OK 73446 Re: Unconstitutional Religious Work Program Dear Judge Coppedge: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Marshall County District Court drug courts. FF RF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free ?'om addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian?themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion hour the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Marshall County District Court cease sending offenders to CAAIR. The CAAIR program is so flagrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 20l4) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. 1d. at 544-45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, I 15 F.3d 1068 (2nd Cir. I997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Marshall County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel 2 3 exploitative/20 7/ 10/ l/c9434 84-ae9f- e7-9b93 -b97043e57a22_story.html FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (918) 596-5402 The Honorable Rebecca B. Nightingale District Judge Tulsa County District Court 500 S. Denver, Rm. 708 Tulsa, OK 74103 Re: Unconstitutional Religious Work Program Dear Judge Nightingale: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Tulsa County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one?year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, C's-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Tulsa County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (finding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlaw?ll. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Tulsa County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4L4. Sam Grover Associate Counsel STG:cem 2 3 exp loitative/ZO 17/ 1 0f 1 l/c9434 84-ae9f-1 1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL The Honorable Ken Graham District Judge Stephens County District Court l0l S. Street Duncan, OK 73533 Re: Unconstitutional Religious Work Program Dear Judge Graham: 1 am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Stephens County District Court drug courts. FF RF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Stephens County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurrzmon, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probarr'on, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlaw?JI. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Stephens County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 2L4, Sam Grover Associate Counsel STG:cem 2 3 exploitative/20 1 7/1 0/1 l/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (405) 257-2631 The Honorable George W. Butner District Judge Seminole County District Court P.O. Box 656 Wewoka, OK 74884 Re: Unconstitutional Religious Work Program Dear Judge Butner: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Seminole County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Seminole County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inorrye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Seminole County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel STG:cem 2 3 exploitative/201 7/10/1 l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. Box 750 MADISON. WI 53701 . (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (918) 923-4567 The Honorable Sheila A. Condren District Judge Rogers County District Court 200 S. Riggs Blvd. Claremore, OK 74017 Re: Unconstitutional Religious Work Program Dear Judge Condren: 1 am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Rogers County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Clo-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Rogers County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?illy inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kartzman, 403 U.S. 602 (l97l). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 20l4) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under [983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kenma, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, I IS F.3d l063 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-cornpelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Rogers County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel 2 3 exploitative/2017/10/l l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON.W153701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (580) 332-5766 The Honorable Steven Kessinger District Judge Pontotoc County District Court l20 W. 13th Street Ada, OK 7482] Re: Unconstitutional Religious Work Program Dear Judge Kessinger: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Pontotoc County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the first four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Pontotoc County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. 1d. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaning?Jl sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Pontotoc County District Court should completely dissociate itself ?'om CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4, Sam Grover Associate Counsel STG:cem 2 3 exploitative/2017/10/l l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. Box 750 MADISON. WI 53701 . (608)256-8900 . October 16, 20 7 SENT VIA U.S. MAIL AND FAX: (918) 540-3278 The Honorable Robert G. Haney District Judge Ottawa County District Court l02 E. Central Ave. Ste. 200 Miami, OK 74354 Re: Unconstitutional Religious Work Program Dear Judge Haney: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Ottawa County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Ottawa County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kenma, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Ottawa County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 741.4? Sam Grover Associate Counsel STG:cem 2 3 exploitative/20 1 7/1 0/ 1 l/c9434 84-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL The Honorable John Kane District Judge Osage County District Court 600 Grandview, Rm. 302 Pawhuska, OK 74056 Re: Unconstitutional Religious Work Program Dear Judge Kane: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Osage County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-Presidents the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Osage County District Court cease sending offenders to CAAIR. The CAAIR program is so flagrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (I971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Osage County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4; Sam Grover Associate Counsel 2 3 exploitative/2017/10/l l/c9434184uae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53?01 (608) 256-8900 October 16, 20l7 SENT VIA U.S. MAIL AND FAX: (918) 758-1237 The Honorable Ken Adair District Judge Okmulgee County District Court 314 W. 7th Street, Ste. 305 Okmulgee, OK 74447 Re: Unconstitutional Religious Work Program Dear Judge Adair: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Okmulgee County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the first four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Cir-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the 0kmu gee County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. Sec, 6.3., Lemon v. Kurrzman, 403 U.S. 602 (I971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 20l4) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. I997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable diSpute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Okmulgee County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 1.4. Sam Grover Associate Counsel STG:cem 2 3 exploitative/20 1 7/1 0/ l/c9434l 84-ae9f-l le7-9b93-b97043e5 7a22_story.html FREEDOM FROM RELIGION foundation P.O. Box 750 MADISON. WI 53701 (608J 256-8900 - October 16, 2017 SENT VIA U.S. MAIL AND FAX: (580) 622-2979 The Honorable Aaron Duck Associate District Judge Murray County District Court PO Box 578 Sulphur, OK 73086 Re: Unconstitutional Religious Work Program Dear Judge Duck: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Murray County District Court drug courts. FFRF is a nationwide nonprofit organization with more than 29,000 members across the country, including members in Oklahoma. FF purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-Presidents the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Murray County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?illy inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 .3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Murray County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 7.1.4? Sam Grover Associate Counsel 2 3 exploitative/2017/10/l l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON.W153701 (608) 256?8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (405) 527-1856 The Honorable Leah Edwards District Judge McClain County District Court 12! N. 2nd Street Purcell, OK 73080 Re: Unconstitutional Religious Work Program Dear Judge Edwards: 1 am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the McClain County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Co-Prerz'demr the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the McClain County District Court cease sending offenders to CAAIR. The program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurrzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 430 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to in the future. The McClain County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel STG:cem 2 3 exploitative/20 17/ 0! 1 l/c9434 1 84-ae9f-l le7-9b93-b97043 e5 7a22__story.html FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October I6, 2017 SENT VIA U.S. MAIL AND FAX: (918) 825-4415 The Honorable Terry H. McBride District Judge Mayes County District Court 1 Court Place, Suite 240 Pryor, OK 7436] Re: Unconstitutional Religious Work Program Dear Judge McBride: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Mayes County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Mayes County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment ?'ee exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544-45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 7l4 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d l068 (2nd Cir. l997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlaw?Jl. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Mayes County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 2L4, Sam Grover Associate Counsel 2 3 exploitative/20 1 7/1 0/1 l/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. Box 750 - MADISON. WI 53701 (608) 256-8900 . October 20l7 SENT VIA U.S. MAIL The Honorable Todd Hicks Associate District Judge Love County District Court 405 W. Main Street Marietta, OK 73448 Re: Unconstitutional Religious Work Program Dear Judge Hicks: 1 am writing on behalf of the Freedom From Religion Foundation (FF RF to bring your attention to a serious constitutional violation occurring in the Love County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion ?'om the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Cir-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Love County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. 1d. at 544-45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inonye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, ?5 F.3d 1068 (2nd Cir. 1997) (finding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). [t is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Love County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4; Sam Grover Associate Counsel 2 3 exploitative/2017/10/i l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (405) 282-7661 The Honorable Louis A. Duel Associate District Judge Logan County District Court 301 E. Harrison, Rm. 203 Guthrie, OK 73044 Re: Unconstitutional Religious Work Program Dear Judge Duel: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Logan County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of ?'ee labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries ?'om heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Logan County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. 403 U.S. 602 (l97l). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inonye v. Kemna, 504 F.3d 705, 7l4 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cty. Dept. of Probation, 115 F.3d 1068 (2nd Cir. I997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Logan County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel 2 3 exploitative/20 711 0/ l/c9434l 84-ae9f- le7-9b93-b97043 e5 7322_story.html FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (580) 228-2185 The Honorable Dennis Gay Associate District Judge Jefferson County District Court 220 N. Main St Waurika, OK 73573 Re: Unconstitutional Religious Work Program Dear Judge Gay: 1 am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Jefferson County District Court drug courts. FRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free ?'om addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Clo-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Jefferson County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (I971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlaw?Jl. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Jefferson County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel 2 3 exploitative/2017/10/l l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256?8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (405) 379-3204 The Honorable Gordon Allen Associate District Judge Hughes County District Court PO Box 875 Holdenville, OK 74848 Re: Unconstitutional Religious Work Program Dear Judge Allen: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Hughes County District Court drug courts. FF RF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, C's-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Hughes County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?illy inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, 3.3., Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Hughes County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4L Sam Grover Associate Counsel 2 3 exploitative/2017/10/l 1/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256?8900 October 2017 SENT VIA U.S. MAIL AND FAX: (405) 224-0514 The Honorable Kory Kirkland District Judge Grady County District Court P.O. Box 605 Chickasha, 0L 73023 Re: Unconstitutional Religious Work Program Dear Judge Kirkland: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Grady County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Cry-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Grady County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inonye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d 1068 (2nd Cir. 1997) (finding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable diSpute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlaw?il. The religious components in are pervasive, as are the human rights abuses. is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Grady County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4; Sam Grover Associate Counsel 2 3 exploitative/2017/10/1 1/c9434134-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 2017 SENT VIA U.S. MAIL AND FAX: (405) 238-1138 The Honorable Steven Kendall Associate District Judge Garvin County District Court 20] W. Grant Street Pauls Valley, OK 73075 Re: Unconstitutional Religious Work Program Dear Judge Kendall: I am writing on behalf of the Freedom From Religion Foundation (FF RF to bring your attention to a serious constitutional violation occurring in the Garvin County District Court drug courts. FFRF is a nationwide nonprofit organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Garvin County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?illy inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kartzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 7 4 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d l068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. I996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlaw?il. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Garvin County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4; Sam Grover Associate Counsel 2 3 exp loitative/ZO 17/1011 l/c9434 84-ae9f- e7-9b93 -b97043e5 7a22_story.html FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 20l7 SENT VIA U.S. MAIL AND FAX: (918) 253-5739 The Honorable Barry V. Denney District Judge Delaware County District Court P.0. Box 489 Jay, OK 74346 Re: Unconstitutional Religious Work Program Dear Judge Denney: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Delaware County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Cir-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Delaware County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kenma, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlaw?ll. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced?labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Delaware County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 71.4; Sam Grover Associate Counsel 2 3 exploitative/20 7/ 0/ 1/c9434 84-ae9f-l e7-9b93 -b97043e5 7a22_story.html FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October l6, 20l7 SENT VIA U.S. MAIL The Honorable Jeff Virgin District Judge Cleveland County District Court 200 S. Peters Ave. Norman, OK 73069 Re: Unconstitutional Religious Work Program Dear Judge Virgin: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Cleveland County District Court drug courts. FF RF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, C's-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Cleveland County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (I971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544-45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Cleveland County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, .4947. Sam Grover Associate Counsel STG:cem 2 3 exploitative/2017/10/l 1/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL The Honorable Dennis Morris District Judge Carter County District Court 20 B. Street S.W., Rm. 304 Ardmore, OK 73401 Re: Unconstitutional Religious Work Program Dear Judge Morris: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Carter County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one?year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report - or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of ?at: labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Ctr-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Carter County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 U.S. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. 1d. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inoaye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that govemmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for govemmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Carter County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, Sam Grover Associate Counsel STG:cem 2 3 exploitative/2017/10/1 l/c9434184-ae9f-1 FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON.W1537OI (608) 256-8900 October 16, 20 7 SENT VIA U.S. MAIL AND FAX: (405) 262-1522 The Honorable Paul Hesse District Judge Canadian County District Court P.O. Box 730 El Reno, OK 73036 Re: Unconstitutional Religious Work Program Dear Judge Hesse: I am writing on behalf of the Freedom From Religion Foundation (FFRF) to bring your attention to a serious constitutional violation occurring in the Canadian County District Court drug courts. FF RF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. FF purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All CAAIR clients are required to attend church services every Sunday for the first four months of their term, as well as weekly bible study each Wednesday. A former CAAIR client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. CAAIR primarily functions as a source of free labor for several major chicken companies - most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, Cir-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Canadian County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woe?Jlly inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurrzman, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. erron, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under I983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544?45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inouye v. Kenma, 504 F.3d 705, 7l4 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cry. Dept. of Probation, 15 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable dispute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlawful. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Canadian County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 71.4; Sam Grover Associate Counsel 2 3 exploitative/2017110? l/c9434184-ae9f-l FREEDOM FROM RELIGION foundation P.O. BOX 750 MADISON. WI 53701 (608) 256-8900 October 16, 2017 SENT VIA U.S. MAIL AND FAX: (580) 931-0577 The Honorable Mark Campbell District Judge Bryan County District Court 402 W. Evergreen St. Durant, OK 7470] Re: Unconstitutional Religious Work Program Dear Judge Campbell: I am writing on behalf of the Freedom From Religion Foundation (FF RF) to bring your attention to a serious constitutional violation occurring in the Bryan County District Court drug courts. FFRF is a nationwide nonpro?t organization with more than 29,000 members across the country, including members in Oklahoma. purposes are to protect the constitutional principle of separation between state and church, and to educate the public on matters relating to nontheism. It has come to our attention that for the last several years, the court has regularly sentenced non-violent offenders to Christian Alcoholics Addicts in Recovery for terms of one-year in place of traditional drug rehabilitation programs or prison time. The CAAIR program markets itself as an intensive substance abuse recovery program whose goal is ?provide every man an equal opportunity to achieve a life free from addiction.?1 In reality, however, CAAIR clients get very little to nothing in the way of actual drug rehabilitation treatment. Instead, they receive only a heavy dose of religious indoctrination that is utterly repugnant to that most basic human right enshrined in our First Amendment - the freedom of conscience. From what we have learned, the depth of religious coercion in the CAAIR program is staggering. All clients are required to attend church services every Sunday for the ?rst four months of their term, as well as weekly bible study each Wednesday. A former client reported to us that ?counselling? sessions, which were ostensibly meant to be drug and alcohol counselling, consisted almost entirely of watching Christian-themed ?lms and church sermons. We are further informed that every few months, a Christian acting troupe called ?For His Glory Drama Ministries? visits CAAIR and performs sketches that promote Christian ideology, including an actor playing Jesus. only perfunctory attempt at substance abuse treatment (albeit still religious in nature) are twelve-step group meetings led by fellow CAAIR clients. Attendance at religious events is absolutely mandatory. Failure to report or merely being tardy - will result in a loss of privileges or possibly expulsion from the program, which for most of these men will mean prison time. A more religiously coercive environment is scarcely imaginable. And all this to say nothing of the appalling conditions under which these men are forced to work, day in and day out, without a single cent to show for it. primarily ?mctions as a source of free labor for several major chicken companies most notably Simmons Foods, Inc. Former CAAIR clients report of grievous injuries from heavy machinery that are left untreated, abusive supervisors who accuse the ill and injured of ?laziness,? and 1 Dan Barker and Annie Laurie Gaylor, C's-President: the ever-present, nauseating stench of chicken blood and feces.2 We understand that CAAIR was recently named in a federal class action lawsuit over its exploitative practices.3 We write to ensure that the Bryan County District Court cease sending offenders to CAAIR. The CAAIR program is so ?agrantly religious and so woefully inadequate at rehabilitating offenders that it does not serve any secular purpose, as required by law. See, Lemon v. Kurtzman, 403 US. 602 (1971). Compelling program participants to attend a religious event as a term of their probation is patently illegal. See Jackson v. Nixon, 747 F.3d 537 (8th Cir. 2014) parole stipulation requiring [an offender] to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment?). The Jackson court held that a Department of Corrections director and the director of the substance abuse treatment program could each be held personally liable under 1983 for violating an atheist prisoner?s First Amendment free exercise rights by requiring his participation in religious activities as a condition of the program. Id. at 544-45. Other federal courts uniformly agree that mandatory participation in religious programs, such as Alcoholics Anonymous, violates the Establishment Clause. See, Inonye v. Kemna, 504 F.3d 705, 714 n.9 (9th Cir. 2007) (holding that ?the program involved here has such substantial religious components that governmentally compelled participation in it violated the Establishment Clause?); Warner v. Orange Cty. Dept. of Probation, 115 F.3d 1068 (2nd Cir. 1997) (?nding an Establishment Clause violation when the state required a probationer to attend AA meetings); Kerr v. Ferrey, 95 F.3d 472, 480 (7th Cir. 1996) (holding mandatory AA participation unconstitutional). It is simply beyond any reasonable diSpute that the CAAIR program is far more religiously coercive than simply AA or NA. As the cases cited above demonstrate, the Constitution only requires showing a ?substantial religious component? for governmentally-compelled attendance in a program to be unlaw?il. The religious components in CAAIR are pervasive, as are the human rights abuses. CAAIR is not a drug rehabilitation program in any meaningful sense of the term; it is a forced-labor camp, shot-through with religious proselytization. For your drug courts to continue to send Oklahomans to CAAIR is a patent violation of the First Amendment. We ask that you communicate immediately with all drug courts under your supervision and ensure that no offenders are sentenced to CAAIR in the future. The Bryan County District Court should completely dissociate itself from CAAIR. All offenders currently enrolled must be offered a secular alternative. Given the documented abuses within the program, all offenders should be recalled from the program entirely. Please inform us in writing of the steps you are taking address this grave breach of the First Amendment and basic human rights. Thank you for your time and attention to this serious matter. Sincerely, 4.4? Sam Grover Associate Counsel STG:cem 2 3 exploitativef20 17/ 1 0/1 1/c9434 1 84-ae9f-1 e7-9b93 -b97043 e5 7a22_story.html