Judge rules Missouri’s refusal to admit family members into execution chamber does not substantially burden inmate’s religious rights under RLUIPA or the First Amendment
In the final days before his scheduled execution, Lance Shockley asked a federal court to allow his two daughters, both ordained ministers, to accompany him into the execution chamber and administer religious rites. The state declined. The court upheld that decision.
On October 11, 2025, Chief Judge Stephen R. Clark of the U.S. District Court for the Eastern District of Missouri denied Shockley’s request for a preliminary injunction. The case is captioned Shockley v. Adams, et al., No. 4:25-cv-01513-SRC (E.D. Mo. 2025). The full opinion is available here: Justia Docket Entry and Ruling.
Shockley, who was convicted of murdering Missouri State Highway Patrol Sergeant Carl “DeWayne” Graham Jr. in 2001, has not challenged his guilt or his death sentence. Instead, he sought an emergency stay based on his request to have his daughters present during his execution to provide religious sacraments and lay hands on him in prayer. His lawsuit invoked the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment.
Judge Clark concluded that Missouri’s refusal to admit family members into the execution chamber did not amount to a “substantial burden” on religious exercise under federal law. The court emphasized that the Department of Corrections had offered multiple alternatives. These included permitting a non-family minister of Shockley’s choice to perform the same rites and allowing his daughters to observe the execution and participate from outside the chamber.
The court found that these accommodations preserved Shockley’s ability to engage in the religious practices he requested. He could receive communion, be anointed with oil, and have someone pray over him during the execution. What he could not do was choose his daughters to perform those rites within the chamber itself. According to the court, that limitation did not rise to the level of a constitutional violation.
Corrections officials submitted declarations describing the high-security nature of Missouri’s execution facilities. No family member has ever been permitted inside the chamber. The Department cited the proximity of the holding cell to the execution chamber, concerns about emotional interference, the risk of disruption, and past violations of confidentiality by spiritual advisors. Officials stressed that physical contact and close relationships can increase risk, even without intent to cause harm.
The court acknowledged that ministers are not interchangeable, but found no evidence that Shockley’s religious practice required his daughters specifically. Nor did the record show that only they could perform the rites in a manner consistent with his faith. Shockley did not explain why the proposed alternatives were inadequate. He did not show that Missouri’s policy singled out religious practice or reflected hostility toward his beliefs.
Under RLUIPA, a state may impose burdens on religious exercise if it demonstrates a compelling interest and uses the least restrictive means. Judge Clark concluded that Missouri met this standard. Preventing disruptions and maintaining order during an execution are compelling interests. Allowing non-family spiritual advisors while excluding family members, the court reasoned, reflected a tailored and reasonable policy.
The court also emphasized the timing of the filing. Shockley brought the claim only five days before his execution, despite having months to raise the issue. Judge Clark noted that late-stage litigation in capital cases must be reviewed with caution. The court found that Shockley’s delay, coupled with an undeveloped record, weighed against the extraordinary relief he sought.
The ruling dismissed the case with prejudice. Shockley’s motion to proceed in forma pauperis was also denied, as his counsel had already paid the filing fee and failed to submit the required documentation. The court granted motions to keep certain Department of Corrections records sealed, finding that Missouri law protected those materials from public disclosure.
Barring further intervention, Shockley’s execution remains scheduled. No additional hearings are currently set in federal court.
Glossary Entry: “With Prejudice”
Definition:
A legal term indicating that a case has been dismissed permanently and cannot be brought again in the same court or on the same claims.
Context:
When a court dismisses a case “with prejudice,” it signals that the court has made a final determination on the merits or found procedural grounds that bar the plaintiff from refiling. This contrasts with a dismissal “without prejudice,” which leaves the door open for the case to be refiled.
Example from Usage:
In Shockley v. Adams, the U.S. District Court for the Eastern District of Missouri dismissed the case with prejudice after finding that the plaintiff failed to demonstrate a violation of his religious rights. This means Shockley cannot bring the same claims again in federal court.
Key Implication:
A dismissal with prejudice has the same effect as a final judgment. It is typically used when the court believes that allowing the case to be refiled would be legally inappropriate or futile.
Tags: Lance Shockley, Missouri execution, RLUIPA decision, First Amendment religion, execution chamber access
Prepared with AI assistance.