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 confinement, while others professed different religious affiliation on entering prison and later claimed conversion to the NOI.

The problems created by NOI practitioners in prisons, reformatories, and detention centers have included outright violence, as well as preparation of petitions or legal suits alleging authorities were denying them their constitutional right of religious freedom. One of the most significant court battles between prisoners and prison authorities has involved NOI members or sympathizers in District of Columbia penal institutions. Members of the NOI were first permitted to conduct weekly religious meetings in District penal institutions in 1955. In 1959, a group of Muslims nearly rioted in a recreation yard at the Lorton Reformatory in Lorton, Virginia, where District inmates are incarcerated. Some time later, prison officials isolated a prisoner for preaching the NOI program to his fellow prisoners. The NOI follower brought a suit in Federal district court in Washington, D.C., charging discrimination for not being allowed to practice his religion. In July, 1962, a district court judge ordered him to be returned to the area of general prisoners and to be permitted to practice his religion. In his decision, the judge indicated that NOI adherents embraced a legally recognized religion, since they believed in