Prison administrators’ jobs have become more complex since RFRA was first enacted in 1993 along with the advent of international terror and increasingly violent gangs. Both phenomena have roots in religion, and, therefore, extreme religious liberty has hit the federal and state prison systems hard.

The fanatical Muslim terrorist networks within United States borders before September 11, 2001, were an undetected cancer spreading through the system. But they were hard at work: a bomb exploded in the World Trade Center basement in 1993. Our own prisons – and the military – have been potential breeding grounds for them. It took the annihilation of almost 3,000 victims from abroad and the U.S., and the World Trade Center – two of the tallest buildings in the world – for Americans to realize that there was a religious movement intent on their destruction.

In the aftermath of September 11, it quickly became apparent that Muslim chaplains in the prisons and the military were in a strategic position to recruit, train, and indoctrinate those individuals who were open or vulnerable to an approach.