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 a Supreme Being. The judge also stated that, while the prisoner deserved disciplinary action, the punishment given him had been excessive and was based principally on the fact that he had made complaints against District of Columbia officials.

Less than a month after NOI prisoners were granted permission to practice their religion, there were two riots in the Youth Center at the Lorton facility. Damage of several thousand dollars was caused by about 50 NOI followers and sympathizers. Prison authorities promptly banned further Muslim services in the Youth Center as dangerous to prison discipline and order. Services were still permitted in the adult section of the prison system, where NOI leaders were allowed to conduct services for the NOI inmates.

In 1964, a Federal district judge ordered District prison officials to permit NOI followers at the Youth Center to resume the practice of their religion. The order came in a ruling involving a suit filed by 15 NOI prisoners. The judge declared that to "justify the prohibition of the practices of an established religion at the Youth Center, the prison officials must prove by satisfactory evidence that the teachings and practice of the sect create a clear and present danger to the orderly functioning of the institution." There was no conclusive evidence offered, the judge held, to show that the 1962 riots had been instigated or led by members of the NOI.