NH Federal Court Holds Prison Anti-Violence Program Is Secular

In Bader v. Wren, 2008 U.S. Dist. LEXIS 6952 (D NH, Jan. 30, 2008), a New Hampshire federal magistrate judge rejected an Establishment Clause challenge to the "Alternatives to Violence Program" offered to inmates at the New Hampshire State Prison. He concluded that the program is not religious, even though it is rooted in Quaker philosophy. Unlike religion-based 12-step programs, AVP's identification of "Transforming Power" is much closer to "the non-religious idea of willpower within the individual." He explained: "AVP teaches that Transforming Power has a unique meaning to each participant.... It could mean the same thing, or diametrically opposite things, to a Jewish, Christian, Muslim, Buddhist or atheist participant. While the program teaches an ideology of the power within each individual to transform his or her perspective. It seeks to accomplish this without reliance on, reference to, or invocation of, any theology. Transforming Power, as utilized in the AVP, is not part of any religion and cannot be understood as religious."