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 11^th 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.