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Barry Hazle is an atheist who was incarcerated for a year due to a drug charge before he was released on parole. As a condition of his parole, however, Hazle was required to attend a 90-day residential drug treatment program. Although Hazle did not object to attending such a program, he did object to the fact that he was assigned to a 12-step program with explicitly religious content referring to “God” and a “higher power.” As Hazle wrote in an official challenge to this placement, “I have committed myself to a full and lasting secular recovery and complete abstinence from illegal drugs,” but he objects to “forced participation in any spiritual/religious activities.”
Despite his objections, Hazle remained in the religious 12-step program, all while unsuccessfully trying to get transferred to a secular program. A little over a month after he entered the program, however, the program complained that Hazle was “sort of passive aggressive.” Hazle was charged with a parole violation, arrested, and incarcerated for another 100 days.