U.S. | Restrictions on Spiritual Advisers in Execution Chambers Persist Despite Supreme Court Ruling

When Lance Shockley was exe­cut­ed in Missouri in October 2025, he request­ed the pres­ence of his daugh­ter, an ordained min­is­ter, in the exe­cu­tion cham­ber as his spir­i­tu­al advis­er. The Missouri Department of Corrections (MDOC) denied his request, and Mr. Shockley was exe­cut­ed. His case rep­re­sents one exam­ple of how states have applied the U.S. Supreme Court’s 2022 rul­ing in Ramirez v. Collier, a deci­sion that acknowl­edged the reli­gious rights of death-sen­tenced pris­on­ers at the time of their exe­cu­tion. In its 8 – 1 rul­ing, the Supreme Court held that John Ramirez, a death-sen­tenced pris­on­er in Texas, had the right to have a spir­i­tu­al advis­er touch him and pray aloud dur­ing his exe­cu­tion. The Court based this deci­sion on both the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA) and urged states to adopt clear poli­cies for allow­ing spir­i­tu­al advis­ers into execution chambers.

Since the Ramirez deci­sion, exe­cut­ing states have han­dled the pres­ence of spir­i­tu­al advis­ers in the exe­cu­tion cham­ber in var­i­ous ways. Alabama and Louisiana, which have adopt­ed nitro­gen gas exe­cu­tions, allow spir­i­tu­al advis­ers into the cham­ber, but they must sign forms acknowl­edg­ing the poten­tial risks of being present in the exe­cu­tion cham­ber. Oklahoma allows for spir­i­tu­al advis­ers to touch the pris­on­er in an exe­cu­tion cham­ber, while South Carolina does not allow spir­i­tu­al advis­ers in the exe­cu­tion cham­ber regard­less of method of execution.

Missouri has not updat­ed its exe­cu­tion pro­to­col since 2013, fail­ing to heed the Court’s advice. The state has also allowed some spir­i­tu­al advis­ers to be present dur­ing exe­cu­tions while deny­ing oth­ers. In 2023, Leonard ​“Raheem” Taylor, who was Muslim, request­ed an imam be present dur­ing his exe­cu­tion. An imam had been cleared to vis­it Mr. Taylor the morn­ing of his exe­cu­tion, but MDOC offi­cials did not allow him to enter the cham­ber dur­ing Mr. Taylor’s exe­cu­tion. According to a let­ter from the war­den, this was ​“due to insti­tu­tion­al secu­ri­ty con­cerns relat­ed to chang­ing the pro­to­col at this late hour.” Court doc­u­ments show offi­cials pro­vid­ed con­flict­ing dead­lines for request­ing a spir­i­tu­al advis­er. Mr. Taylor’s lawyers stat­ed he pre­vi­ous­ly signed a form declin­ing wit­ness­es because he believed it applied only to fam­i­ly mem­bers and did not want his fam­i­ly wit­ness­ing his death.

Prison offi­cials denied the pres­ence of Mr. Shockley’s daugh­ter as his spir­i­tu­al advis­er despite MDOC’s pol­i­cy allow­ing for fam­i­ly to be present as spir­i­tu­al advis­ers. Officials said they denied his request because fam­i­ly mem­bers ​“pose a dan­ger” to the exe­cu­tion and spec­u­lat­ed that they could, for exam­ple, try to remove the IV line. The Marshall Project reports that a spokesper­son for MDOC cit­ed state code as the rea­son for the denial of Mr. Shockley’s request, though an expert said the courts have not inter­pret­ed the cit­ed statute in the way MDOC applied it.

In con­trast, Missouri has allowed more than a hand­ful of oth­er reli­gious lead­ers to be present in the exe­cu­tion cham­ber. In 2022, the Rev. Darryl Gray was per­mit­ted to place his hand on Kevin Johnson’s shoul­der and pray dur­ing his exe­cu­tion and in 2024, Marcellus Williams’ spir­i­tu­al advis­er, Imam Jalahii Kacem was also present in the execution chamber.

Questions and con­sti­tu­tion­al con­cerns regard­ing the pres­ence of spir­i­tu­al advis­ers in the exe­cu­tion cham­ber pre­date Ramirez v. Collier. In February 2019, Alabama car­ried out the exe­cu­tion of Domineque Ray, a Muslim man who had request­ed the pres­ence of his imam dur­ing his exe­cu­tion. The state’s exe­cu­tion pro­to­col at that time man­dat­ed a Christian chap­lain be present in the exe­cu­tion cham­ber. No oth­er advis­ers from oth­er faiths were allowed. Mr. Ray learned of this restric­tion just ten days before his sched­uled exe­cu­tion, when the prison denied his request for a copy of the exe­cu­tion pro­to­col. He filed a peti­tion five days after learn­ing this infor­ma­tion. The 11th Circuit Court of Appeals ini­tial­ly stayed his exe­cu­tion, but in a 5 – 4 deci­sion, the U.S. Supreme Court lift­ed this stay and allowed Mr. Ray’s exe­cu­tion to pro­ceed with­out address­ing the con­sti­tu­tion­al con­cerns at the heart of the case, cit­ing the untime­li­ness of his claim.

Justice Elena Kagan, writ­ing for the dis­sent, stat­ed that Alabama’s pol­i­cy meant ​“a Christian pris­on­er may have a min­is­ter of his own faith accom­pa­ny him into the exe­cu­tion cham­ber to say his last rites. But if an inmate prac­tices a dif­fer­ent reli­gion — whether Islam, Judaism, or any oth­er — he may not die with a min­is­ter of his own faith by his side.” Justice Kagan wrote that this ​“goes against the Establishment Clause’s core prin­ci­ple of denom­i­na­tion­al neu­tral­i­ty.” Her dis­sent con­clud­ed that the Court’s major­i­ty opin­ion, which allowed his exe­cu­tion to pro­ceed, was ​“pro­found­ly wrong.” Mr. Ray was able to spend the morn­ing of his exe­cu­tion with his imam, but for the three hours lead­ing up to his exe­cu­tion, he did not have access to his advis­er. Mr. Ray was exe­cut­ed February on 7, 2019.

Just a month after Mr. Ray’s exe­cu­tion, the U.S. Supreme Court stayed the exe­cu­tion of Patrick Murphy, a Buddhist pris­on­er on Texas’ death row whose spir­i­tu­al advis­er had been denied access to the execution chamber.

Source: Death Penalty Information Center, Hayley Bedard, February 3, 2026

"One is absolutely sickened, not by the crimes that the wicked have committed,
but by the punishments that the good have inflicted."

— Oscar Wilde