ABSTRACT
The First Amendment to the United States Constitution states in part that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof. . . .”1 An obvious contradiction exists within the two clauses of this Amendment. This contradiction is particularly apparent when the amendment is applied to the prisoners of correctional systems. In Gittlemacker v. Prasse,2 the inherent diffi culty in applying First Amendment religious freedom to prisoners is pointed out:
But to go further and suggest that the free exercise clause demands that the state not only furnish the opportunity to practice, but also supply the clergy, is a concept that dangerously approaches the jealously guarded frontiers of the establishment clause.
