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.
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."
but by the punishments that the good have inflicted."
— Oscar Wilde

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