“All America Is a Prison”:The Nation of Islam and thePoliticization of African AmericanPrisoners, –ZOE COLLEY

This article examines the rise of the Nation of Islam (NOI) within America’s penal systemduring the late s and the s. In doing so, it explores the reasons for the NOI’s appealamong African American prisoners, its contribution to the politicization of those prisoners,the responses of penal, state and federal authorities to the proliferation of prison mosques, andthe way in which imprisoned Black Muslims’ campaign for freedom of religious expressionestablished the legal groundwork for the prisoners’ rights movement of the late s and thes. This research presents the prison as a locus of black protest and the African Americanprisoner as an important, but largely overlooked, actor within the black freedom struggle. It callsupon historians to recognize the importance of the prison as both a site and a symbol of blackresistance during the post-World War II period.

That’s why black prisoners become Muslims so fast when Elijah Muhammad’steachings filter into their cages by way of other Muslim convicts. “The white man isthe devil” is a perfect echo of that black convict’s lifelong experience.

The Autobiography of Malcolm X.

Malcolm X’s conversion to the Nation of Islam (NOI) while incarceratedin Leavenworth Prison, Kansas is part of the well-established narrative ofhis life. A number of biographies and studies of the man detail the awakeningof his political consciousness while incarcerated and the importance of thatexperience in drawing him into the NOI. What is less often recognized is that

Department of History, School of Humanities, University of Dundee. Email: z.a.colley@dundee.ac.uk.Malcolm X’s prison conversion was part of a much longer process of politicization. His father,Earl Little, had been a member of Marcus Garvey’s United Negro Improvement Association(UNIA). The NOI was heavily influenced by the UNIA’s brand of urban, anti-Christian blacknationalism and religious zeal. The UNIA provided the cultural bedrock for the NOI. It isclear that Malcolm X was heavily influenced by his father’s involvement with the UNIA, aswell as his father’s death in . While an inquest ruled that his death had been accidental,Earl Little’s family believed he had been murdered by a white vigilante group, the Black Legion.On the impact of Malcolm X’s childhood upon his later life see Manning Marable,Malcolm X:

Journal of American Studies, (), , – © Cambridge University Press doi:./S First published online August

Malcolm X’s conversion story could have been told by countless prisonersduring the s and s. Over the course of those two decades, the Nationof Islam appeared in correctional institutions across the nation, creating thefirst black protest movement within the American prison system. The prisonbranch of the NOI attracted only small numbers of convicts during the earlyto mid-s, while the threat of repression from authorities meant that thegroup often operated underground; however, as the overall membership of theNation of Islam increased during and , so its prison membershipcame into view. Ascertaining the size of the NOI’s prison membership duringthis period is difficult, to say the least. In , a Nation of Islamrepresentative reported that the group had recruited four hundred prisonersin the last twelve months; this represented about percent of the total numberof registered members. Three years later, prison wardens and governmentofficials in New York, New Jersey, California, Washington, DC, and Illinoisissued warnings that the group was undermining the “racial harmony” andorder of their correctional institutions. Sociologists’ reports and court recordssupport their view that the Nation of Islam had continued to spread throughthese states’ penal systems. A conservative estimate would place the Nation’s

A Life of Reinvention (London: Allen Lane, ). Other studies that address Malcolm X’searly life and prison conversion are David Gallen, Remembering Malcolm (New York: Carrolland Graf, ); Peter Goldman, The Life and Death of Malcolm X (Urbana: University ofIllinois Press, ); Hakim Jamal, From the Dead Level: Malcolm X and Me (New York:Random House, ); Jeffry Ogbar, Black Power: Radical Politics and African AmericanIdentity (Baltimore: John Hopkins University Press, ); Bruce Perry,Malcolm: The Life ofa ManWho Changed Black America (New York: Station Hill, ); Richard Turner, Islam inthe African American Experience (Bloomington: Indiana University Press, ). See alsoMalcolmX and Alex Haley, The Autobiography of Malcolm X (London: Penguin, ).

In , the NOI experienced a rapid increase in membership, much of it due to the publicityreceived from the documentary The Hate That Hate Produced, which was broadcast in July. For example, Essien-Udom reported that between March and December theNOI increased the number of temples from in states to in states. A year later, thegroup had doubled in size, reaching a membership that was estimated as somewhere between, and ,. The year also marked the beginning of reports from prison officialson the problems caused by imprisoned Muslims, as well as petitions to courts by imprisonedBlack Muslims challenging their treatment, thereby suggesting that the organization wassimultaneously becoming more popular among black prisoners and more visible to prisonauthorities. See William Strickland,Malcolm X: Make It Plain (New York: Viking, ), –; Essien Udosen Essien-Udom, Black Nationalism: A Search for an Identity in America(Chicago: The University of Chicago Press, ), –; Marable, –

Estimates for the NOI’s membership in varied between , and ,; the figure of percent is based on a membership of ,. Clearly, the Nation of Islam was recruitingprisoners before , as reflected by the conversion of Malcolm X. Essien-Udom, , .

“Muslim Negroes Suing the State,” New York Times, March ; “Muslims a Problem inPrison,” Trenton Evening Times, Nov. ; “Muslins Studied in Jersey Prison,” New YorkTimes, Nov. ; James B. Jacobs, Stateville: The Penitentiary in Mass Society (Chicago: TheUniversity of Chicago Press, ), , n.; Testimony of Dr. Henri Yaker to theSupreme Court of New Jersey in Cooke v. Tramburg, Dec. . Available at www.leagle.

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prison membership in the early s at around ,, or percent of anoverall membership believed to have been , at the very least, with themajority of its support concentrated in the states mentioned above.While theNOI had a female prison service, it is not clear how many female prisonersconverted to the NOI; the available evidence certainly speaks in terms of thisbeing an exclusively male phenomenon.Over the last five years, historians’ interest in the Nation of Islam has grown:the product of a new and vibrant debate on black radicalism and the blackpower movement that has been dubbed “new black power studies.” Forexample, in his study of the NOI, Jeffry Ogbar has argued that theorganization was the “chief inspiration” for the black power movement andthat we cannot understand the radicalism of the post- era without a fullunderstanding of the Nation’s work during the s and early s.

Despite this growing body of literature on the NOI, its work inside America’spenal system remains obscured from view. Historians dutifully acknowledgethe group’s strong appeal to prisoners, often doing so via a discussion ofMalcolm X’s conversion, but they rarely deviate from this standard narrative toconsider the wider significance of this phenomenon. This article seeks to fill

com/xmlResult.aspx?page=&xmldoc=NJ_.xml&docbase=CSLWAR----&SizeDisp=, accessed Feb. . Also see “Comment. Black Muslims in Prison:Of Muslim Rites and Constitutional Rights,” Columbia Law Review, (), –;Dulcey A. Brown, “Black Muslim Prisoners and Religious Discrimination: The DevelopingCriteria for Judicial Review,” George Washington Law Review, (–), –; JamesB. Jacobs, “The Prisoners’ Rights Movement and Its Impacts, –,” Crime and Justice, (), –.

The figure of , inmate members is a conservative one, equating to percent of the lowestfigure of ,. An alternative guide to the popularity of the Nation of Islam among prisonerscan be found in Keith Butler, “The Muslims Are No Longer an Unknown Quantity,”Corrections Magazine, (), –. This placed the NOI’s inmate population in at,, which equated to percent of the overall , membership. By that point, theorganization had undergone profound change. The NOI had been recognized as a religion inmost prisons and inmates were generally allowed to pray without hindrance; one must assumethat a greater number of inmates felt able to identity themselves openly with the Nation.

Peniel Joseph, “The Black Power Movement: A State of the Field,” Journal of AmericanHistory, (), –, .

While the NOI’s influence upon later black power organizations is clear, the group also had aconflicted relationship with the black power movement. Elijah Muhammad scorned blackpower groups for their secularity and members were banned from contact with black poweradvocates. Ogbar, –. Also see Peniel Joseph, Waiting ‘Til the Midnight Hour: A NarrativeHistory of Black Power in America (New York: Holt, ), –.

The one work which has looked at this part of the NOI’s history in any depth is historianEric Cummins’s The Rise and Fall of California’s Radical Prison Movement (Palo Alto:Stanford University Press, ). Cummins’s work credits Black Muslims inside California’sthree largest penitentiaries with providing the groundwork for the prison activism of the lates. His work helps us to understand the politicization of black prisoners, but his focusupon California means that he overlooks the fact that the NOI was active in prisonsthroughout the nation. California was home to the most active and militant prison rights

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that historiographical gap. It offers a new perspective on the Nation of Islam,one which looks beyond the direct influence of Malcolm X to reveal the fullextent of its appeal within the nation’s prisons. It considers the significance ofprisoners within the Nation of Islam’s ideology, how the prison templesrecruited members, what motivated prisoners to join the Nation of Islam,what impact they had upon the prison system, and how authorities both insideand outside the penal system responded to the proliferation of prison temples.In doing so, it also highlights two broader themes within the Nation of Islam’shistory. First, it contributes to an existing body of literature on the responsesof white authorities to the growing popularity of the Nation of Islam. Officialinvestigations into the prison temples reveal the wider fear that the organiz-ation was covertly planning a violent assault upon white America. Second, andmost importantly, the prison temples help us to understand the strength of theNOI’s appeal within the very poorest black neighborhoods. Racked by terriblepoverty, police brutality, and high levels of crime, these working-class com-munities experienced the highest levels of male incarceration. Arrest andimprisonment was an experience shared by a large part of the NOI’s member-ship; for example, Ogbar estimates that percent of the members of HarlemTemple Number Seven had criminal records. Thus the influence ofimprisoned Muslims stretched across the prison walls to help shape theNation of Islam’s critique of white privilege and its ideological appeal withinthe ghettoes. This article presents prisons as a locus of black protest and the

movement in the country and provided some of the most influential prison leaders, but it wascertainly not exceptional. Furthermore, The Rise and Fall closely focusses upon the BlackMuslims’ impact upon prison administration. We do not get a sense of the how the prisontemples fitted into the NOI as a whole, nor the impact they had upon the black freedomstruggle. Legal scholars have paid more attention to imprisoned Muslims, although thisresearch is overwhelmingly focussed upon the significance of the prisoners’ claims for freedomof religious expression. “Comment,” –; Brown, –; Christopher Smith, “BlackMuslims and the Development of Prisoners’ Rights,” Journal of Black Studies, , (),–, –.

For existing studies on the responses of white authorities to the NOI see Claude Clegg, AnUnoriginal Man: The Life and Times of Elijah Muhammad (New York: St. Martin’s Press,), –, –, –; Essien-Udom, –; Mattias Gardell, Countdown toArmageddon: Louis Farrakhan and the Nation of Islam (Durham, NC: Duke University Press,); Dawn-Marie Gibson, A History of the Nation of Islam: Race, Islam, and the Quest forFreedom (Santa Barbara: Praeger, ), –; Eric Lincoln, The Black Muslims in America(Grand Rapids, MI: William B. Eerdmands, ), –; Marable, –, –.

Gail O’Brien, The Color of the Law: Race, Violence, and Justice in the Post-World War II South(Chapel Hill: University of North Carolina Press, ); Brian Wagner, Disturbing the Peace:Black Culture and the Police Power after Slavery (Cambridge, MA: Harvard University Press,); Leonard Moore, Black Rage in New Orleans: Police Brutality and African AmericanActivism from World War II to Hurricane Katrina (Baton Rouge: Louisiana State UniversityPress, ). Ogbar, .

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African American prisoner as a “demonized, dismissed, and overlooked” actorwithin the black freedom struggle, and thereby offers a unique perspective onthe rising politicization of some black prisoners during the later s and thes. The inclusion of prisoners in the historiography of the black freedomstruggle not only recognizes their agency in challenging their treatment, it alsoexplains how this form of black radicalism fitted into the wider movement forpolitical and social power during the postwar period.

In , W. D. Fard arrived in Detroit’s black community. Travelling fromhouse to house, he peddled silks while spreading the message that he was aprophet sent by Allah to teach African Americans their true heritage. Thosewho listened were instructed that blacks were the original race and descendantsof “the lost–found tribe of Shabazz.” Six thousand years ago, an evil scientistnamed Mr. Yacub had created a race of “white, blue eyed devils.” God hadgiven the white race six thousand years to rule the earth, during which timethey had enslaved blacks and separated them from the language and culture oftheir African–Asiatic ancestors. However, their reign was due to end; Godwould soon return to destroy the evil white race and restore the noble blackrace to its rightful position as ruler of the world. Fard soon gained a followingwithin Detroit’s black community. It was claimed that by there wereeight thousand members in the city alone. The following year, police forcedFard to leave Detroit; the reason for his mysterious disappearance thefollowing year confounds historians. Shortly before his disappearance, Fard

Joseph, “The Black Power Movement,” .One of the greatest challenges in researching the Nation of Islam is the paucity of material onits work, especially during its early days; this challenge is made even greater when combinedwith the test of investigating the lives of black prisoners. Fortunately, there are some ways ofpenetrating this tightly closed group. Sociologists and psychologists were intrigued by thechanging nature of prison society during the s and s. Many of these scholars weredrawn to the increasingly volatile nature of prison race relations during this time; thus theirwork offers insights into the lives of black convicts, as well as some specific information on theNation of Islam. Along with newspaper reports and the work of sociologists, FBI reports canhelp us to gauge which parts of the country had the greatest concentration of convict supportand the nature of their activities. In addition, prison rights advocates working during the lates and the s were interested in uncovering the history of prison race relations; this hasprovided a resource of essays and interviews by individuals who lived within the prison systemduring the s and s. Most significantly, we have the writings of black activist EldridgeCleaver, who started his career as a high-ranking member of California’s most active NOIprison temple in Soledad.

Erdmann D. Beynon, “The Voodoo Cult among Negro Migrants in Detroit,” AmericanJournal of Sociology, (), –, . Most historians follow Beynon’s estimate,although the FBI claimed that there were more than ,members by . See Gardell, .

From its earliest days under W. D. Fard, the Nation of Islam was the target of law-enforcement agencies and FBI surveillance. The group first came to the attention of Detroitauthorities in late , after police arrested Robert Harris for the ritual murder of JamesSmith. Harris claimed that it had been predestined that a sacrifice would be made on that day

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had appointed Elijah Poole his Messenger and given him the name ElijahMuhammad. This was not enough, however, to prevent the group descendinginto internal turmoil in the wake of Fard’s disappearance. During the s,the group splintered into competing factions, each claiming to be Fard’srightful successor. It would not be until after World War II that Muhammadwas able to consolidate his hold on power and begin the process of rebuildingthe organization. Under Muhammad’s control, the NOI grew in size andinfluence. After a period of retrenchment during the late s and the s,the group enjoyed an era of rapid growth during the late s and earlys. During this period, white flight to the suburbs and deindustrializationbrought the hardening of residential segregation and with it the continueddecline of urban black communities. Meanwhile, the civil rights movement inthe South inspired some northern African Americans, while also highlightingtheir alienation from white society. The Nation of Islam, with Malcolm X asits chief orator, drew upon these developments to expand its presence withinthese communities; the organization attacked the hypocrisy of white liberalsand vehemently criticized the civil rights movement’s emphasis upon inte-gration. By , its membership was estimated at somewhere between, and , and it owned a business empire worth millions.

To understand the rapid expansion of the Nation of Islam, one mustlook to the communities in which it thrived. Detroit, like other northern andmid-western cities, had experienced a rapid influx of African Americans fromthe rural South; they were drawn northward in search of new economicopportunities and an escape from lynching and segregation. Starting in thes, the process reached a height during the boom years of World War II.These migrants quickly learnt that the “sweet land of liberty” was anythingbut; while they had escaped the extremes of southern racism, they nevertheless

and that his “volunteer” would become a “Saviour.” Ten days later, police raided the NOIheadquarters and arrested Fard and two other members. They were subsequently released, butthe Detroit press dubbed the NOI a “voodoo cult” and it would continue to draw theattention of law-enforcement officers. Beynon, –. The FBI surveillance on Fard isavailable at http://vault.fbi.gov/Wallace%Fard%Muhammed, accessed July . OnW. D. Fard and the early years of the Nation of Islam see Clegg; Karl Evanzz, The Rise andFall of Elijah Muhammad (New York: Random House, ); Gibson.

See Gardell, –; Lincoln, –. For example, the NOI’s publication Muhammad Speaks regularly highlighted the abuse ofcivil rights activists by legal officials. “Spurn Bail to Protest Arrest,” Muhammad Speaks(hereafterMS), March , ; “Lynching! The Crime without Punishment,”MS, Sept., ; “Why Capital Punishment Is the Most Premeditated of All Murders,” MS, Oct., ; “Crime, Race and Freedom,” MS, Nov. , ; “Stay out of Jail Drive!”, MS, Dec. , ; “Negro Youths Braved Jail Terms, Left Prison Ready to Fight on forFreedom,”MS, June , ; “Muslims Rip Cop ‘Storm Trooper’ Act in Negro Area,”MS, Aug. , ; “Rep. Powell Demands All Facts in ‘Chain Gang’ Trial of Muslims,” MS, Nov. , . See Essien-Udom, –.

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lived in a society where black inferiority was deeply ingrained within themainstream culture. Living in the slums of northern cities, these migrantsendured overcrowded and dilapidated housing and faced a constant struggleto provide for their families. Such problems were particularly acute duringthe Great Depression, when hope gave way to bitterness at the virulentdiscrimination in employment and welfare provision. As living conditionswithin the nation’s black communities declined ever further, so the Nation’scriticism of white America appeared to correspond with African Americans’plight. The attraction of the NOI to prisoners was partly a natural extensionof the group’s strong appeal within these poor black neighborhoods, wherethe discriminatory nature of law enforcement was felt most keenly, and – asalready noted – high numbers of residents had a history of criminal activity.Police brutality and arbitrary arrest, which was a common experience in thesecommunities, meant that the police were often the focus of African Americanhostility and suspicion. When combined with residential segregation, em-ployment discrimination, and underfunded schools, the racist criminal-justicesystem sustained a northern version of racial apartheid that kept blackresidents trapped in a cycle of poverty and crime.

Lincoln, .Gail O’Brien’s study of policing in Tennessee reveals how the police “operated as the frontlineguardians of an arbitrary criminal justice system and a social order that controlled black[communities].” O’Brien, The Color of the Law. Leonard Moore’s work on the policing ofblacks in New Orleans shows how these victims of police brutality were overwhelminglyworking-class: the same areas where the Nation of Islam found its greatest amount of support.Moore, –.

On the ‘urban decline’ of cities see Arnold Hirsch, Making the Second Ghetto: Race andHousing in Chicago, – (Chicago: The University of Chicago Press, ); KevinM. Kruse and Thomas J. Sugrue, eds., The New Suburban History (Chicago: The Universityof Chicago Press, ); Wendell Pritchett, Brownesville, Brooklyn: Blacks, Jews, and theChanging Face of the Ghetto (Chicago: The University of Chicago Press, ); RobertO. Self, American Babylon: Race and the Struggle for Postwar Oakland (Princeton: Universityof Princeton Press, ); Amanda Seligman, Block by Block: Neighborhoods and Public Policyin Chicago’s West Side (Chicago: The University of Chicago Press, ); Thomas J. Sugrue,The Origins of the Urban Crisis: Race and Inequality in Postwar Detroit (Princeton: PrincetonUniversity Press, ); Sugrue, Sweet Land of Liberty: The Forgotten Struggle for Civil Rightsin the North (New York: Random House, ). On the use of the term “apartheid” inrelation to American race relations see Douglas Massey and Nancy A. Denton, AmericanApartheid: Segregation and the Making of the Underclass (Cambridge, MA: HarvardUniversity Press, ). Massey and Denton argue that the hypersegregation of blackcommunities constitutes a form of racial apartheid and is the primary cause of AfricanAmerican poverty. Historians who have drawn this comparison include George M.Frederickson, White Supremacy: A Comparative Study in American and South AfricanHistory (New York: Oxford University Press, ); Nikhil Pat Singh, Black Is a Country:Race and the Unfinished Struggle for Democracy (Cambridge, MA: Harvard University Press,); Komozi Woodard, A Nation within a Nation: Amiri Baraka (LeRoi Jones) and BlackPower Politics (Chapel Hill: University of North Carolina Press, ).

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The group’s theological discourse has been the subject of a number ofstudies; they have emphasized the way in which the NOI’s doctrine blendedIslamic, Christian, and Judaic traditions. A prominent theme within thisscholarship is the way in which supporters assumed a new identity upon theirconversion: one which signified racial pride and self-respect, and rejected thedominant racial ideology of black inferiority. The first step in this process ofrebirth was the shedding of one’s surname, which was viewed as a product oftheir slave ancestry, and the granting of a new Islamic name. Given theimportance of Christianity to African American identity and culture, Fard’steachings inevitably engaged with this aspect of black life. He made extensiveuse of the Bible, as the religious text with which African Americans were mostfamiliar, to portray Christianity as the white man’s religion and a tool of racialcontrol. In doing so, he sought to break the bond between African Americanidentity and Christian values. However, at the same time as castigatingChristianity as the product of white malevolence, Fard also appropriatedelements of biblical discourse to produce a doctrine that, as Zafar Ansari hasshown, bore “a greater degree of resemblance with Judaism and . . . especiallyChristianity than Islam.” Thus the NOI’s doctrine combined religious influ-ences with African American history and heritage to produce a philosophythat spoke directly to African Americans’ experiences with white privilege.

While Muslims awaited God’s arrival and their redemption, the NOIdeveloped an interim program of racial separatism, education, and self-transformation that would prepare its supporters for life after the fall of whiteAmerica. Upon conversion, members were instructed to follow a strict moralcode that included abstention from alcohol, smoking, and drug use. They wererequired to pray five times a day, attend two temple meetings per week, andpartake in the recruitment of (or “fishing” for) new members. They were alsotaught to respect constituted authority, dress smartly, work hard, live frugally,

Zafari Ansari “Aspects of Black Muslim Theology,” Studia Islamica, (), –;Essien-Udom, –; Lincoln, –.

This discussion draws upon Richard Turner’s focus upon the importance of significationwithin the African American Islamic tradition. See Turner, Islam in the African AmericanExperience.

For example, Ansari observes that Muhammad’s concept of God-as-man was far closer toChristian beliefs than to Islamic. He points to the NOI’s idea that God’s concerns werefocussed exclusively upon blacks as resembling the Jewish concept of Yahweh. OrthodoxMuslims rejected the NOI’s doctrine; however, as Lincoln argues, the NOI was part of a pan-Islamic movement that was based on antiwhite sentiment. See Ansari, , –; Lincoln,–.

The earlier history of the Moorish Science Temple of America, which was founded in thes and similarly combined Islamic theology with an outright rejection of black inferiority,is an example of a larger Islamic tradition within African American culture. On the MoorishScience Temple and its influence upon the NOI see Essien-Udom, –; Gardell, –;Gibson, A History of the Nation of Islam, –; Lincoln, –.

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and avoid eating the meat of “poison animals,” which included hogs, duck,geese, and catfish. Alongside this demand for moral and psychological trans-formation, the NOI also called for political, economic, and social separationfrom white America. The NOI’s demand that they be “allowed to establish aseparate state or territory” was often made; however, it appears that otheraspects of its program of racial separatism were both more popular andachievable. Starting in Detroit in the early s, the NOI formed its owneducational institutions, which offered children from poor black neighbor-hoods an alternative to the poorly funded public schools in the ghetto. Theimportance of economic self-sufficiency had been an aspect of Fard’s teaching,but under Elijah Muhammad this goal gained increased prominence. In ,the NOI purchased a -acre farm in Michigan. Muhammad subsequentlycreated an economic empire worth millions and included a restaurant, bakery,and grocery stores.

Starting in the s, the Federal Bureau of Investigation conductedsurveillance on NOI leaders and sought to discredit the organization and itsleadership, while police raids of temples and harassment of supporters werecommon complaints. It was the Black Muslims’ refusal to register for the draftduring World War II that first inspired a large-scale FBI investigation of thegroup; fear that the group’s disavowal of allegiance to the United States poseda threat to the nation’s domestic order and international security was inten-sified by informants’ reports of pro-Japanese sentiment at NOI meetings.

In , Elijah Muhammad was convicted on eight counts of sedition andthree counts of draft evasion, and given a sentence of from between one andfive years. In total, around one hundred Black Muslims were incarcerated fordraft resistance. During his four-year-long imprisonment, Muhammad andhis fellow Muslim inmates continued their proselytizing and succeeded inconverting a number of other prisoners. Muhammad was released in tofind his organization in tatters. The continued and determined campaign oflegal harassment against NOI members had driven away large numbers ofsupporters; in , Detroit’s Temple No. had just thirty-five active mem-bers. Claude Clegg’s study of Muhammad highlights his incarceration as aturning point in the history of the organization. Having faced numerouschallenges to his leadership, his persecution by federal and prison authoritieshelped to project an image of Muhammad as a martyr in the battle against

On the NOI’s moral code see Essien-Udom, –, –; Lincoln, –.On the importance of the NOI’s economic power see Clegg, An Unoriginal Man, –;Essien-Udom, –; Gibson, –; Lincoln, –.

See Beynon, “The Voodoo Cult,” –; Gibson, –. Mattias Gardell, –, –,provides one of the best accounts of the FBI’s campaign against the NOI.

Clegg, . Ibid., .

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white tyranny; his suffering at the hands of his oppressors not only earned him“a permanent place in Muslim hagiography,” it also enabled him to consolidatehis hold on power and unite the group behind his leadership. Just asimportantly, Muhammad’s time in prison personalized the plight of AfricanAmerican inmates and convinced him of the need to spread his messagewithin the penal system. He would continue to play a personal role in theconversion of prisoners by responding to their letters with a personal reply andenclosing five dollars. His experience convinced him that the conversion of the“living dead” inside America’s penal system was of paramount importance tothe overall aim of liberating African Americans from their white oppressors.

The desire to recruit prisoners was part of a larger campaign to challenge thehigh rate of black criminality within the ghettoes. Muhammad offered a con-servative view of black criminality, preferring to explain such behavior inpathological terms. Black criminals were rebuked for emulating the sinfulbehavior of whites and especially for praying upon members of their own race.Such people had apparently lost their way, having been drawn towards theways of the “white devil.” He called upon them to abandon their wickedbehavior and undergo a spiritual and moral rebirth by following the word ofAllah. Once they discovered their identity as members of the supreme race,they would naturally desist from criminal activity.

For African American prisoners, the crucial element of this philosophy wasthe promise of redemption. While the NOI’s moral code reflected a decidedlyconservative interpretation of black criminality, it also recognized the innategoodness within every prisoner and offered them hope for the future. As wellas promising salvation, the NOI provided practical solutions to the challengeof escaping the cycle of poverty and prison by providing newly releasedconverts with employment and housing. The NOI claimed a high level ofsuccess in preventing recidivism among African American ex-convicts. Thusthe African American prisoner took on a symbolic value within the NOI’sphilosophy of racial uplift and moral transformation: its ability to turn ahardened criminal into an upstanding member of the black community wasthe ultimate demonstration of Islam’s power to destroy the cancer of whiteimmorality.Malcolm X held particular significance for African American prisoners.

Eldridge Cleaver, an ex-convict and leader of the temple in California’s

Ibid., .One of the most detailed accounts of Muhammad’s incarceration and its impact upon bothhis leadership style and the NOI as a whole can be found in ibid., –.

Elijah Muhammad, Message to the Black Man in America (Phoenix: Secretarius, ), .Muhammad appealed to the courts to “turn over such criminals to be executed under the realIslamic law,” and explained, “It is our desire to put a stop once and for all to such crimes beingcommitted among our people.” Lincoln, .

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San Quentin prison, explained: “A former prisoner himself, he had risenfrom the lowest depths to great heights. For this reason he was a symbol ofhope, a model for thousands of black convicts who found themselves trappedin the vicious PPP cycle: prison–parole–prison.” Malcolm X oftenreiterated Elijah Muhammad’s contemptuous attitude towards blackcriminals; for example, reflecting upon his life as a hustler in Detroit, hedescribed himself as the “personification of evil.” However, there are alsoexamples, and particularly towards the end of his involvement with the NOI,of how he set himself apart from Muhammad by presenting black criminalityas the product of a racist social structure and African American prisoners asvictims of that racism. “Usually the convict comes from among thosebottom-of-the-pile Negroes,” he explained in his autobiography, “the“Negroes who through their entire lives have been kicked about, treatedlike children –Negroes who never have met one white man who didn’t eithertake something from them or do something to them.” This more political,and less judgmental, view of black criminality was apparently shared byother converts. In an interview with historian Eric Lincoln, one memberaddressed the plight of African American prisoners by highlighting thehypocrisy of the white-controlled criminal-justice system. “Did you kill? Ifyou killed a white man, they murder us at will. They decorate their trees withthe bodies of our people. Or they kill us by ‘law,’ but they cannot enforce thesame ‘law’ to protect us or let us vote.” Echoing this belief that no AfricanAmerican could ever secure justice at the hands of whites, Malcolm X arguedin a interview not only that white racism created the conditionsunder which black criminality flourished, but that the white power structureactively cultivated black criminality as a way of deflecting challenges to itsauthority:

I firmly believe that it was . . . the Judaic–Christian society . . . that created all of thefactors that send so many so-called Negroes to prison . . . [A]fter a so-called Negro inprison trys [sic] to reform and become a better man, the prison authorities are moreagainst that man than they were against him when he was completely criminallyinclined, so this is again hypocrisy.

The importance of Elijah Muhammad’s interpretation of black criminality isundeniable; however, it is also evident that other interpretations of suchbehavior circulated among the membership. Malcolm X’s criminal past and his

E. Cleaver, “Initial Reactions on the Assassination of Malcolm X,” in Cleaver, Soul on Ice(New York: MacGraw Hill/Ramparts, ), –, .

Malcolm X and Haley, Autobiography, . Ibid., . Lincoln, . “Malcolm X talks with Kenneth B. Clark,” in The Negro Protest: James Baldwin, Malcolm Xand Martin Luther King Talk with Kenneth B. Clark (Boston: Beacon Press, ), ,original emphasis.

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prison conversion clearly made him a powerful influence upon incarceratedsupporters; if we take Cleaver’s point as evidence of such influence, itappears likely that, at the very least, his pronouncements on the plight ofthe African American prisoner and black criminality competed with those ofElijah Muhammad.In a number of speeches, Malcolm X continued to create a metaphorical

association between the treatment of African Americans and incarceration,a point best summed up in his claim that “all America is a prison.” Looking be-yond the NOI’s immediate membership to encompass all African Americans,he appealed to them to realize, “You’re still in prison. That’s what Americameans: prison. I think that what you should realize, is that in America thereare twenty million black people, all of whom are in prison.” His descriptionof America as one colossal penitentiary made incarceration a shared experiencethat spanned across the prison walls.

While the Nation’s interpretation of black criminality circulated amongprisoners, official censorship, which banned the distribution of MuhammadSpeaks and other NOI literature, left them somewhat isolated from thisdialogue. Efforts to prevent the spread of “inflammatory” literature werepart of a much larger campaign to prevent Muslims from practicing theirreligion; this centered upon preventing NOI supporters from meeting asa group, isolating leadership figures in solitary confinement, and breakingup temples by transferring members to different institutions. As early as ,Muslims in Washington, DC’s Lorton Reformatory complained that prisonauthorities were preventing them from practicing their religion. EldridgeCleaver recalled returning to San Quentin prison in after a paroleviolation. In his absence, a small coterie of Black Muslims had emerged in

Ibid., .This argument was also being made by incarcerated civil rights activists in the South. MalcolmX’s insistence that black Americans were trapped within a “political, economic and mentalprison” was echoed in the civil rights movement’s belief that confronting the fear ofimprisonment by accepting jail was the route to psychological liberation. Both acknowledgedthe centrality of the criminal-justice system in oppressing black Americans, as well as thepoliticizing effect of imprisonment. On this comparison see Zoe A. Colley, Ain’t Scared ofYour Jail: Arrest, Imprisonment, and the Civil Rights Movement (Gainesville: University Pressof Florida, ).

Conflict over NOI literature centered on access to Muhammad Speaks, which commencedproduction in . However, prisoners also sought access to other material, includingMuhammad’s writing. Despite official censorship, some literature, especially Malcolm X’sAutobiography, made its way into the prisons and was circulated within undergroundnetworks. In Autobiography rented at the considerable cost of one pack of cigarettes. See“Prisons Feel a Mood of Protest,” New York Times, Sept. , .

Butler, “The Muslims Are No Longer an Unknown Quantity,” . Also see “Ordeal atLorton Prison: Why Black Jobs in Jail Join Muhammad,” MS, Oct. , ; “HistoricCourt Fight Ends for Muslim Inmates,” MS, Oct. , .

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the prison, headed by Cleaver’s friend Butterfly. It was Butterfly whoconverted Cleaver to the Nation of Islam. Writing in Soul on Ice,he explained:

In those days if you walked into any prison set aside for solitary confinement, therewas absolutely no doubt that you’d find ten or fifteen Black Muslims who were being“disciplined” for staunchly confronting prison officials with implacable demands thatMuslims be allowed to practice their religion with the same freedom and privileges asthe Catholics, Jews, and Protestants.

Sociologist James Jacobs reported that Black Muslims in Illinois’s StatevillePenitentiary “surfaced as a problem for prison officials” during , althoughthe NOI’s presence in the prison dated back to . Jacobs estimated thatduring the early s, between and percent of all prisoners in solitaryconfinement were Muslims. In Texas, authorities took an alternativeapproach. Having decided in that the number of Muslim inmates wasthreatening to destabilize race relations within Texan prisons, the Departmentof Corrections ordered that supporters be distributed throughout the penalsystem in an attempt to limit their influence upon other African Americanprisoners.

The rising conflict between Muslim prisoners and prison authorities poseda dilemma for Elijah Muhammad. While Muhammad expected inmates topractice their religion and recruit new converts, he was also reluctant to see hisorganization become embroiled in a fight against prison racism and was eagerfor his convict supporters to join the struggle on the streets. Furthermore,the expectation that members always respect authority and conform to existinglaws evidently placed the prison temples in an awkward position. They facedthe stark choice of challenging their treatment, and thereby disobeying theNOI’s moral code, or being forced to take their organization underground.It is entirely possible – if not probable – that some prisoners decided to keeptheir support hidden from prison authorities. However, as we can see from theproliferation of legal cases brought by imprisoned supporters and occasionalinstances of direct confrontation with prison staff, many others chose the

Cleaver, . Eldridge Cleaver, “Prisons: The Muslims’Decline,” in Frank Browning et al., eds., Prison Life:A Study of the Explosive Conditions in America’s Prisons (New York: Harper and Row, ),. Also see John Irwin, Prisons in Turmoil (Boston: Little, Brown and Company, ), .

Jacobs, Stateville, , n. ; Robert T. Chase, “Civil Rights on the Cell Block: Race,Reform, and Violence in Texas Prisons and the Nation, –,” Ph.D. dissertation,University of Maryland, .

The NOI’s “Muslim Program” – a statement of its philosophy – included the demand that all“Believers of Islam” be freed from the nation’s prisons. On the NOI’s belief that prisonconverts should do everything they could to secure release see “Muhammad’s People Belongin Paradise, Not Prisons,” MS, April , .

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former option. While they shared the same structure and ideology, theprison environment created different priorities and forced prison supporters toengage in a far more open campaign against white authority.The media, government reports, and sociologists’ research suggest that there

was rarely more than a handful of Black Muslims inside individual prisons in. The same evidence reflects the growing popularity of the organizationamong prisoners from , while the – period marked a rapidincrease in membership. Sociologists observed at the time that this phenom-enon was the product of two factors: the growing numerical dominance ofAfrican Americans within the general prison population and the impact of thecivil rights movement. As African Americans accounted for a growingpercentage of the prison population, and were influenced by black protestoutside the penal system, so some inmates resolved to challenge their owntreatment; the Nation of Islam was the main beneficiary of these changes.Sociologist Leo Carroll described the early s as a period of increasingracial solidarity between African American inmates and of a “dramatic change”to their political outlook. “The primary axis of life for most black inmates isracial identification,” he observed. “Brotherhood is based upon the recognitionof a shared fate at the hands of a common oppressor, and the essence of therelationship is mutual aid in the face of oppression.” By adopting this outlookblack prisoners were “able to integrate their role as a prisoner with their role asa black man in a way which places them in the vanguard of a . . .movementagainst . . . oppression.” Such developments created the conditions for, andacted as a backdrop to, the increasing militancy and visibility of the prisontemples.

Jacobs, Stateville, –; Cleaver, Soul On Ice, –; “The Nation of Islam,” FBI CriminalResearch Section report, Oct. , –, available at http://vault.fbi.gov/Nation%of%Islam/Nation%of%Islam%Part%%of%/view, accessed Feb. ;“Muslins Studied in Jersey Prison”; “Muslims a Problem in Prison”; “Muslim NegroesSuing the State.”

Leo Carroll, Hacks, Blacks, and Cons: Race Relations in a Maximum Security Prison(Lexington: D. C. Heath, ), , ; Cummins, The Rise and Fall, –; DonC. Gibbons, Society, Crime, and Criminal Behavior (New York: Prentice Hall, ), ;Jacobs, Stateville, –; Jacobs, “The Prisoners’ Rights Movement,” –; Irwin, –.

For example, James Jacobs concluded that the combined effect of “black numericalsuperiority . . . and the example of black civil rights activity on the streets . . . facilitate[ed] therise of . . . the Black Muslims” inside Stateville. Jacobs, Stateville, –; Carroll, , .

This process of politicization was bolstered by prison desegregation, which started in somestates during the early s, although the penal system in many southern states remainedsegregated until after the Civil Rights Act. The removal of racial barriers intensifiedracial conflict as white prisoners battled to retain territorial control. The process ofdesegregation remains a relatively understudied area of penal history. On desegregation inCalifornia see Cummins, –. For studies by nonhistorians see Chad R. Trulson and JamesW. Marquart, “The Caged Melting Pot: Toward an Understanding of the Consequences of

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As the only African American protest organization to have a presence insidethe penal system before the late s, the Nation of Islam acted as amouthpiece for a small body of black prisoners who were being politicized bycivil rights activism outside the prison; it allowed them to situate their ownstruggles against white privilege within a wider analysis of American racerelations. In a wider sense, it enabled prisoners to express their frustration andanger at the white power structure, and especially their treatment by whitepolice officers and prison guards, while also offering a positive message ofeconomic self-help and psychological transformation. Despite the NOI’spejorative attitude toward black criminality, it offered prisoners acceptance,redemption, and an alternative identity that stretched beyond that of acriminal – a factor that was reflected in their choice to physically separate fromthe rest of the convicts.The Nation of Islam reached the height of its influence inside prisons

between and . Research produced by prison psychologists andsociologists during this time provides intriguing insights into the daily lifeof those prisoners. As Ellen Herman has shown, this was a period when psy-chologists, in particular, assumed a “central place in debates about the . . .state . . . of American society.” This “romance of American psychology”certainly infiltrated the penal system, where psychologists sought to assess themental status of prisoners and advise on the likelihood that they could berehabilitated. Black Muslim prisoners inevitably became the focus of suchassessment; thus the work of psychologist Henri Yaker in New Jersey StatePenitentiary is particularly interesting. Yaker spent two years researching NOIsupporters within the prison and published his report on the group in .His research indicated that the typical convert was around twenty-five years ofage and had a long history of criminal activity. They distinguished themselvesfrom other African American prisoners by shaving their heads and markingthe “seal of Islam on their foreheads with either cigarettes or caustic soap.” Inaddition to following daily prayer rituals, members were expected to spendtheir time studying the Qur’an and spreading the word of ElijahMuhammad. Eldridge Cleaver offered further information on the activitiesof prison temples, explaining that they adopted the same organizationalstructure as those outside the prison walls: each had a minister, a captain, andits own military force, the Fruit of Islam (FOI). Relatively little is known

Desegregation in Prisons,” Law and Society Review, (), –; Trulson andMarquart, “Racial Desegregation and Violence in the Texas Prison System,” Criminal JusticeSystem, (), –. Lincoln, The Black Muslims, .

Ellen Herman, The Romance of American Psychology: Political Culture in the Age of Experts(Berkeley: University of California Press, ), .

“Muslims A Problem in Prison”; Testimony of Dr. Henri Yaker; “Muslims Studied in JerseyPrison.”

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about the highly secretive FOI, either inside or outside the prisons. EricLincoln’s study described the Fruit of Islam as a “protective unit,”comprising “carefully chosen, rigorously trained” men, whose job it was toprovide protection to members from white attack. He also suggested that theelite group may have acted as an internal “police force,” which disciplinedmembers who failed to fulfill their duties. Just how the FOI operated insidethe prison temples can only ever be the subject of conjecture, but given theintensity of racial hostility within the prisons and the constant threat ofrepression, it is conceivable that this defensive force was of particularimportance to the prison temples.

In his report, Yaker reasoned that the organization appealed to thosewith a need “to act aggressively to compensate for the feelings of psychosexualinadequacy and feelings of loss of masculine identity.” The psychologistreflected the mainstream view that Black Muslim prisoners were a patho-logically violent group; he went so far as to liken them to the “strong-armedmen” who were drawn to support Hitler in his earliest days. Whiledeliberately provocative, his description hinted at an important factor in thegroup’s appeal: in a world where African American men felt emasculated bypoverty and white racism, conversion to the Nation of Islam offered prisonersa renewed sense of masculinity. Although Elijah Muhammad emphasized

Cleaver, “Prisons: The Muslims’ Decline.” Lincoln, –. Also see Essien-Udom, Black Nationalism, –.This argument was reflected in liberal sociologists’ and psychologists’ assessment of racism,and specifically the emasculating effect of racism upon black men. See William H. Grier andPrice M. Cobbs, Black Rage (New York: Basic Books, ); Kenneth B. Clark, Dark Ghetto:Dilemmas of Social Power (Middletown, CT: Wesleyan University Press, );Abram Kardiner and Lionel Ovesey, Mark of Oppression: A Psychological Study of theAmerican Negro (New York: W.W. Norton, ); Daniel P. Moynihan, The Negro Family:A Case for Action (March ).

Yaker quoted in “Muslims a Problem In Prison.” Also see Testimony of Dr. Henri Yaker;“Muslims Studied in Jersey Prison.”

Ogbar, Black Power, . As Steve Estes has observed, the expectation that black men respectand protect women from white attack “directly challenged the defeminization anddenigration of black womanhood in mainstream white culture.” Revelations in thatMuhammad had long engaged in extramarital affairs threw the sincerity of these teachingsinto account. The FBI had long been aware of Muhammad’s indiscretions and had, largelyunsuccessfully, used them in their attempt to discredit him. Steve Estes, I Am A Man! Race,Manhood, and the Civil Rights Movement (Chapel Hill: University of North Carolina Press,), . On the role of women in the Nation of Islam see Farah Griffin, “‘Ironies of theSaint’: Malcolm X, BlackWomen and the Price of Protection,” in Bettye Thomas-Collier andVincent P. Franklin, eds., Sisters in the Struggle: African American Women in the Civil Rights–Black Power Movement (Palo Alto: Ebrary, ). Conventional analyses of NOI genderrelations have tended to focus upon how Muhammad’s emphasis upon protecting blackwomen from white men was more about protecting black men’s “proprietary rights” overblack women than about honoring women. Feminist historians have argued that thisoverlooks the way in which black women often viewed their membership of the NOI and

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the need to protect and respect black women at all times, he also conformed tothe patriarchal outlook of mainstream society and censored women for being“the greatest tool of the devil.” Women were expected to follow traditionalgender roles by looking after the home and children, although they were per-mitted to work if the family’s economic circumstances required it, while menwere to be the main wage earners. Such gendered roles presented poor AfricanAmerican men with an opportunity to reclaim their manhood and sense ofpride. This was clearly attractive to those from the ghettoes, where intensepoverty robbed them of their ability to provide for their families. In the super-masculine environment of the prison, this aspect of the Nation of Islam carriedparticular importance. Taken away from their families, African American menlived in an environment where physical prowess was the key to securingrespect and physical protection. Eldridge Cleaver explained his conversion tothe Nation of Islam in terms of a psychological escape route that helped himto assert his manhood. Cleaver explained: “If I had followed the path laid downfor me by officials, I’d have undoubtedly long since been out of prison – but,” hecontinued, “I’d be less of a man.” For Cleaver, submission to white authorityrepresented the loss of manhood; open and direct confrontation with prisonofficials and white inmates was the only way to protect his masculinity.The expansion of the Nation’s presence inside the penal system, combined

with prisoners’ more overt challenges to the racial order, evidently concernedthose in charge. From , prison and government officials offered increas-ingly shrill warnings about the growing strength of the NOI inside theircorrectional institutions. This corresponded with an increase in alarm over thegrowing popularity of the group outside the prison walls. The copious recordsdetailing the FBI’s investigations into the NOI and Elijah Muhammad revealthe extent of the government’s fears that Black Muslims would amass sufficientsupport to launch a violent attack upon white authority. In , the FBIproduced its first investigative report on the Nation of Islam, a section ofwhich was dedicated to the prison branch. It reported that the NOI had takenhold within the penal system in several states, and that Muslim prisoners inWashington, DC, California, New Jersey, Illinois, and New York were en-gaged in legal suits against prison authorities. Interestingly, it made a distinc-tion between imprisoned black supporters and those working in the general

how it provided them with opportunities to challenge the prevailing gender stereotypes.Jamillah Karim provides the example of the NOI’s Muslim Girls Training and CivilizationClass. She argues that, while teaching in the class was intended to educate girls on how tofulfill their roles of wife and mother, NOI women actually transformed it to a “space forbroadening the scope of motherhood to community activism.” See Jamillah Karim, “ThroughSunni Women’s Eyes: Black Feminism and the Nation of Islam,” Souls: A Critical Journal ofBlack Politics, Culture and Society, (), –, , . Ogbar, .

Cleaver, Soul on Ice, .

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population: incarcerated members were apparently even more troublesomethan those outside the prison walls. Supporters were characterized as oppor-tunistic troublemakers, who had little interest in the religious aspects of theNOI but were “primarily interested” in using membership as a cover for theirchallenges to prison authorities and in fomenting racial discontent amongblack inmates. To support this view, it included details of a failed plot bytwenty Muslim inmates to spearhead a racial uprising in a Pennsylvania statepenitentiary. At the same time as viewing the prison temples as a danger to thestability of the penal system, the report also noted that news of their activitieswas being used outside the prisons “as a propaganda weapon to stir up itsmembers.” Apart from news of the failed Pennsylvania plot, the reportoffered no evidence to support its view that prisoners posed a greater threat tothe racial order than mainstream supporters, but it perhaps derived from abelief that black criminals were both more inclined to engage in violentbehavior and had a very clear reason to seek vengeance against whiteauthorities. This also fed into a fear that prison converts might contribute to aradicalization of the NOI upon their release.The FBI was not alone in its concerns about the prison temples; its belief that

the NOI posed a grave danger to the stability of the penal system was recountedin the mass media and in official reports during the early s. InMarch ,the New York Times reported alleged instances of Muslim-organized violencein California, Alabama, New York, and Maryland’s prisons. New York andDistrict of Columbia authorities reported incidences of Muslims forciblypreventing staff from breaking up their meetings. In Lorton Reformatory, theprison temple was suspected of provoking African Americans to protest againstpoor living conditions. The Times related the fears of New York state officialsthat they were facing a potentially “explosive state” inside their prisons. Twomonths later, James V. Bennett, director of the Federal Bureau of Prisons,testified before the House Appropriations Committee that over the last twelvemonths federal prisons had experienced “a great deal of difficulty . . . [with]aggressive and race-conscious groups, including a considerable number of so-called Black Muslims.” The greatest problems had come in Atlanta’s FederalPenitentiary, where “several gangs” of Black Muslims had caused “a lot oftrouble.” He continued: “I have been in the business a long time and I havenever met a more aggressive hostile group. They refuse to . . . accept any kindof leadership from our officers.”

See “The Nation of Islam,” Oct. , –. “Muslim Negroes Suing the State”; “Muslims a Problem in Prison.” The most radical prisonbranches of the NOI were found in California’s Soledad, San Quentin, and Folsom prisons.Eric Cummins, The Rise and Fall, –, refers to instances of Muslim-organized protests.

“Muslim Negroes Suing the State.”

Zoe Colley

Henri Yaker’s report on New Jersey State Prison reflected these concerns,but he went much further in explaining why the prison temples were a clearand present danger to the nation’s penal system. Not only did he believe thatthe NOI was responsible for provoking black discontent inside the prisons, healso believed that this was part of a larger plot within the NOI to use AfricanAmerican prisoners as foot soldiers in a “holy war” against white America. Theprison minister, who he reported was a “sophisticated . . . and persuasive” man,had been planted inside correctional institutions in order for them to “sow[their] spiritual seed in a fertile field.” He concluded with a chimerical visionof black inmates bursting out of the prison walls, intent on revenge againstwhite America. “If this happens,” he warned, “then the demonic forces shallbreak loose.” White officials’ fear that the Nation of Islam was steeringAfrican American prisoners towards a violent assault against their captors wasmostly a product of their own neuroses. While some prison temples extendedtheir protests to include direct protest against prison racism, the majority ofimprisoned NOI members focussed upon the right to practice their religionand continued to believe that the courts offered the best chance of redressagainst official repression.

The first case of legal action was launched by Muslims in LortonReformatory in after the prison’s superintendent placed fifty-eight ofthem in solitary confinement. Muhammad Speaks reported that the inmateswere refused medical attention, and forced to survive on slices of dry bread andto drink water from the urinals. Over the course of the next five years,Muslims across the country followed the Lorton prisoners’ example and filedhundreds of legal challenges to their treatment. The scale of this legal assault istruly impressive. For example, the FBI reported in June that legalpetitions and forty-two appeals by Black Muslim prisoners were pending inthe federal courts of Washington, DC and Virginia alone. While prisonerssometimes received moral support from outside the prison walls, the NOIleadership generally refused to provide legal or financial assistance. For themost part, prisoners prepared these legal cases without support and relied uponprison libraries to educate themselves in case law and prepare briefs. There are

Yaker quoted in “Muslims a Problem in Prison.” “Muslim Negroes Suing the State”; “Muslims a Problem in Prison.” “The Nation of Islam,” Oct. , ; “Ordeal at Lorton Prison”; “Historic Court FightEnds”; “Muslims a Problem in Prison”; Testimony of Dr. Henri Yaker; Butler, “The MuslimsAre No Longer an Unknown Quantity,” . Four convicts in a New York State prison alsolaunched a legal battle against prison authorities in . See “Muslim Negroes Suing theState.”

“Nation of Islam. Cult of the Black Muslims,” FBI Criminal Research Section report, May, . Available at http://vault.fbi.gov/Nation%of%Islam/Nation%of%Islam%Part%%of%/view, accessed Feb. .

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a number of reasons why support for the prisoners was not forthcoming. Mostobviously, these challenges to prison authorities, and especially instances ofdirect confrontation with guards and white inmates, contravened ElijahMuhammad’s expectation that followers respect authority and follow rules.Their appeals to state and federal courts implicitly acknowledged the authorityof the US government and thereby placed the prison temples in furtherconflict with Muhammad’s teachings. However, there were other forces atwork. Claude Clegg has described how Elijah Muhammad’s incarcera-tion meant that he “dreaded exposing himself to further persecution anddetention.” Over the years, this desire to avoid legal repression increasinglypushed him away from “activist tendencies,” meaning that “protest rallies atpolice stations, and extremely vocal draft resistance were largely things of thepast.” Instead, Muhammad focussed upon building up the group’s economicbase as a less confrontational activity. Despite these efforts, the FBI intensifiedits campaign against Elijah Muhammad in the early s, while policeharassment and brutality grew in its severity; the effect upon Muhammad wasto push him towards an ever more conservative stance, which necessarilydemanded that he withhold support from his prison followers. At the sametime that Muhammad was adopting a more conservative leadership style, theprison temples were becoming more militant in their protests. The increas-ingly political outlook of prisoners was particularly noticeable after andwithin California’s correctional institutions.Muhammad’s refusal to providesupport only compounded this trend as prison supporters became increasinglydisillusioned with and isolated from the NOI leadership.

Prison officials certainly viewed these legal challenges as part of a larger pro-test movement among African American prisoners against the penal system.They responded with an equally vigorous defense in which they argued thatrecognizing the NOI as a genuine religion would also legitimize its antiwhiteideology. The FBI went so far as to deny the sincerity of the legal cases, arguingthat they were part of a “cult of harassment” that was designed to create extrawork for prison officials. In dismissing a series of claims brought by Black

On the impact of Muhammad’s incarceration see Clegg, An Unoriginal Man, –.On the divergence between NOI strategy inside and outside prisons, and especially theincreasingly political outlook of California’s prisoners, see Cummins, .

The police raid of the Los Angeles temple, during which Ronald T. Stokes was killedand six other members were injured, exemplified the impact of legal harassment upon theorganization. Four Muslims were subsequently charged with assault upon a law-enforcementofficer and sentenced to long prison sentences. Elijah Muhammad’s refusal to provide thesemen with legal assistance angered both prisoners and mainstream members. See Cleaver, Soulon Ice; Clegg, –; Frederick Knight, “Justifiable Homicide, Police Brutality, orGovernmental Repression? The Los Angeles Police Shooting of Seven Members ofthe Nation of Islam,” Journal of Negro History, (), –.

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Muslims in New York’s Clinton Prison, the presiding judge argued, “Thesimilarity of the complaints, prepared while the plaintiffs were not supposed tobe in communication with each other . . . indicates that these applications arepart of a movement, which . . . lack the spontaneity of a genuinely wrongedperson.” At stake was nothing less than the “very survival of the author-itarian [prison] regime.” The prison temples faced a difficult situation: eversince , the Ruffin v. Commonwealth definition of inmates as “slaves of thestate” had been used to justify the denial of prisoners’ constitutional rights.

Black Muslims battled against an almost century-long tradition of courtacquiescence to prison authorities on matters relating to institutional manage-ment. The ensuing legal battle consumed state and federal courts for over adecade and drained resources as authorities resisted even the smallest ofMuslims’ demands.While the majority of legal challenges failed, the early s brought some

victories that slowly chipped away at prison wardens’ defense. Black Muslimssecured freedom from punishment on account of one’s religion, theopportunity to hold religious service, and the right to wear religious medals.

In , they finally made a breakthrough when, in Cooper v. Pate, it was ruledthat the Civil Rights Act applied to prisoners and could be used byBlack Muslims to demand recognition of their religion inside prisons. ThomasCooper had originally filed his pro se suit in , alleging that in refusingprisoners access to NOI literature, Stateville prison’s warden was deprivinghim of his right to religious worship. In , the US Supreme Court reversedearlier decisions denying Cooper’s claim and ordered the case be returned tothe Federal District Court. The following year, the Court ruled in Cooper’sfavor. Although it was narrowly focussed upon freedom of religious expression,the ruling held significance for all inmates. It can be likened to the impactof Brown v. Board of Education, which ruled against segregated schools, uponthe civil rights movement as a whole. Just as Brown provided the legalgroundwork for further challenges to racial segregation, so Cooper provideda constitutional basis upon which later campaigns for prisoners’ rights

Cummins, ; “Muslim Negroes Suing the State.” Smith, “Black Muslims,” –. Ibid., –. Also see Jacobs, “The Prisoners’ Rights Movement,” –; “Comment,”–; Brown, “Black Muslim Prisoners,” –.

On judges’ reluctance to intervene in the penal system see Brown, –; “Comment,”–.

The case of Sewell v. Pegelow, upheld the right of prisoners to not be punished onaccount of their religious faith; in , Fulwood v. Clemmer upheld a limited right toproselytize; in , Banks v. Havener guaranteed the right to hold religious services. The case of Coleman v. District of Columbia Commissioners upheld the right to wear religiousmedals. See Smith, –.

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was founded. According to James Jacobs, Cooper was subsequently citedin at least Supreme Court cases challenging the treatment of prisoners.The ruling ended the policy of nonintervention in penal institutions andconfirmed that prisoners had constitutional rights that the Supreme Court wasobliged to protect. Over the following decade, federal oversight of the nation’spenitentiaries helped to bring some of the most brutal and discriminatorypolicies to an end.

Cooper marked the high-point of the NOI’s work inside prisons.From , the organization experienced a decline in popularity amongAfrican American inmates. Elijah Muhammad’s split with Malcolm X was animportant factor in this shift in black prisoners’ support; this was particularlynoticeable in California. While the Nation of Islam continued to be aninfluential force among African American prisoners, after many weredrawn toward the Black Panther Party. The group followed the NOI’sexample by forming branches of the party inside correctional institutions andby celebrating the black prisoner as a crucial figure in the fight against whitesupremacy. After , African American prisoners formed the nucleus of aradical interracial prison rights movement. Building upon the Nation ofIslam’s concept of collective oppression, it drew upon anticapitalist, anti-colonial, and internationalist ideologies of the new left to articulate a class-based analysis of the criminal-justice system and its role in oppressing the poorand racial minorities.

Brown, –; Jacobs, “The Prisoners’ Rights Movement”; Jacobs, Stateville, –;Smith, –. The Cooper case was an exception to Elijah Muhammad’s refusal to providesupport to prisoners’ legal challenges; he hired an attorney on behalf of Cooper. In a Illinois case, Muslims were granted the right to have ministers visit them inside prison. InPennsylvania a year later prison authorities were ordered to lift their ban on MuhammadSpeaks. In a federal judge ruled that Black Muslims in California belonged to a legallyrecognized religion, and were therefore due the same rights as members of other religiousgroups. See Butler, “The Muslims Are No Longer an Unknown Quantity,” ; Cummins,–; Gordon Hawkins, The Prison: Policy and Practice (Chicago: The University ofChicago Press, ), –; John Pallas and Robert Barber, “From Riot to Revolution,” inErik Olin Wright, The Politics of Punishment: A Critical Analysis of Prisons in America(New York: Harper and Row, ), . Jacobs, Stateville, –.

Cleaver, “Prisons: The Muslims’ Decline,” ; Cummins, –. Malcolm X’s departurefrom the NOI, and his subsequent death, also had a destructive impact upon the NOI as awhole. As Dawn-Marie Gibson observes, – was a watershed period in the Nation ofIslam’s history. Alongside the split with Malcolm X, revelations about Elijah Muhammad’ssexual indiscretions and abuses of power further undermined his authority. See Gibson, AHistory of the Nation of Islam, .

Many politicized prisoners during the late s were keen to distance themselves from theearlier work of the Nation of Islam. They argued that the group’s emphasis upon blackseparatism had promoted division between prisoners, when they actually needed to uniteacross racial barriers to challenge prison authorities. See, for example, “George Jackson Speaksfrom Prison,” Black Panther Party Newspaper, Oct. , .

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Despite their relatively small numbers, incarcerated Black Muslims had animpact upon both the American penal system and the course of the blackfreedom struggle. The prison temples merged the separatist ideology of theNation of Islam with their own distinctive attack upon white privilege anddiscrimination. In doing so, they offered a message of racial pride and unity toAfrican American inmates at a time when they were subjected to racial segre-gation, hostility, and violence from both correctional officers and whiteinmates on a daily basis. They established the philosophical basis upon whichthe more overtly political action of African American prisoners during thepost- era was founded and carried the “torch of black protest” intothe black power era. Most importantly, in challenging the definitionof inmates as “slaves of the state,” the NOI forced the nation’s courts toscrutinize the treatment of its prisoners. Their victory before the SupremeCourt brought increased constitutional protection for all prisoners, and actedas a springboard for prison reform during the late s and the s.

Jacobs, “The Prisoners’ Rights Movement,” .

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