¹ 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 black nationalism and religious zeal. The UNIA provided the cultural bedrock for the NOI. It is clear that Malcolm X was heavily influenced by his father's involvement with the UNIA, as well as his father's death in 1931. 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 Marable, Manning, Malcolm X: A Life of Reinvention (London: Allen Lane, 2011)Google Scholar. Other studies that address Malcolm X's early life and prison conversion are Gallen, David, Remembering Malcolm (New York: Carroll and Graf, 1992)Google Scholar; Goldman, Peter, The Life and Death of Malcolm X (Urbana: University of Illinois Press, 1979)Google Scholar; Jamal, Hakim, From the Dead Level: Malcolm X and Me (New York: Random House, 1972)Google Scholar; Ogbar, Jeffry, Black Power: Radical Politics and African American Identity (Baltimore: John Hopkins University Press, 2005)Google Scholar; Perry, Bruce, Malcolm: The Life of a Man Who Changed Black America (New York: Station Hill, 1991)Google Scholar; Turner, Richard, Islam in the African American Experience (Bloomington: Indiana University Press, 1997)Google Scholar. See also Malcolm, X and Haley, Alex, The Autobiography of Malcolm X (London: Penguin, 2001)Google Scholar.

² In 1959, the NOI experienced a rapid increase in membership, much of it due to the publicity received from the documentary The Hate That Hate Produced, which was broadcast in July 1959. For example, Essien-Udom reported that between March 1959 and December 1959 the NOI increased the number of temples from 30 in 15 states to 50 in 22 states. A year later, the group had doubled in size, reaching a membership that was estimated as somewhere between 30,000 and 100,000. The year 1959 also marked the beginning of reports from prison officials on the problems caused by imprisoned Muslims, as well as petitions to courts by imprisoned Black Muslims challenging their treatment, thereby suggesting that the organization was simultaneously becoming more popular among black prisoners and more visible to prison authorities. See Strickland, William, Malcolm X: Make It Plain (New York: Viking, 1994), 84–85Google Scholar; Essien-Udom, Essien Udosen, Black Nationalism: A Search for an Identity in America (Chicago: The University of Chicago Press, 1962), 70–72Google Scholar; Marable, 155–64

³ Estimates for the NOI's membership in 1958 varied between 3,000 and 12,000; the figure of 5 percent is based on a membership of 7,500. Clearly, the Nation of Islam was recruiting prisoners before 1958, as reflected by the conversion of Malcolm X. Essien-Udom, 171, 192.

⁴ “Muslim Negroes Suing the State,” New York Times, 19 March 1961; “Muslims a Problem in Prison,” Trenton Evening Times, 1 Nov. 1962; “Muslins Studied in Jersey Prison,” New York Times, 8 Nov. 1962; James Jacobs, B., Stateville: The Penitentiary in Mass Society (Chicago: The University of Chicago Press, 1977), 60Google Scholar, 256 n.19; Testimony of Dr. Henri Yaker to the Supreme Court of New Jersey in Cooke v. Tramburg, 14 Dec. 1964. Available at www.leagle.com/xmlResult.aspx?page=3&xmldoc=196455743NJ514_1439.xml&docbase=CSLWAR1–1950–1985&SizeDisp=7, accessed 4 Feb. 2012. Also see “Comment. Black Muslims in Prison: Of Muslim Rites and Constitutional Rights,” Columbia Law Review, 62 (1962), 1488–1504CrossRefGoogle Scholar; Brown, Dulcey A., “Black Muslim Prisoners and Religious Discrimination: The Developing Criteria for Judicial Review,” George Washington Law Review, 32 (1963–64), 1124–40Google Scholar; Jacobs, James B., “The Prisoners' Rights Movement and Its Impacts, 1960–1980,” Crime and Justice, 2 (1980), 429–70CrossRefGoogle Scholar.

⁵ The figure of 1,500 inmate members is a conservative one, equating to 5 percent of the lowest figure of 30,000. An alternative guide to the popularity of the Nation of Islam among prisoners can be found in 14 Butler, Keith, “The Muslims Are No Longer an Unknown Quantity,” Corrections Magazine, 4 (1978), 55–63Google Scholar. This placed the NOI's inmate population in 1978 at 12,000, which equated to 12 percent of the overall 100,000 membership. By that point, the organization had undergone profound change. The NOI had been recognized as a religion in most prisons and inmates were generally allowed to pray without hindrance; one must assume that a greater number of inmates felt able to identity themselves openly with the Nation.

⁶ Joseph, Peniel, “The Black Power Movement: A State of the Field,” Journal of American History, 96 (2009), 751–76, 752CrossRefGoogle Scholar.

⁷ While the NOI's influence upon later black power organizations is clear, the group also had a conflicted relationship with the black power movement. Elijah Muhammad scorned black power groups for their secularity and members were banned from contact with black power advocates. Ogbar, 2–3. Also see Joseph, Peniel, Waiting ‘Til the Midnight Hour: A Narrative History of Black Power in America (New York: Holt, 2006), 9–67Google Scholar.

⁸ The one work which has looked at this part of the NOI's history in any depth is historian Cummins's, EricThe Rise and Fall of California's Radical Prison Movement (Palo Alto: Stanford University Press, 1994)Google Scholar. Cummins's work credits Black Muslims inside California's three largest penitentiaries with providing the groundwork for the prison activism of the late 1960s. His work helps us to understand the politicization of black prisoners, but his focus upon California means that he overlooks the fact that the NOI was active in prisons throughout the nation. California was home to the most active and militant prison rights movement in the country and provided some of the most influential prison leaders, but it was certainly not exceptional. Furthermore, The Rise and Fall closely focusses upon the Black Muslims' impact upon prison administration. We do not get a sense of the how the prison temples fitted into the NOI as a whole, nor the impact they had upon the black freedom struggle. Legal scholars have paid more attention to imprisoned Muslims, although this research is overwhelmingly focussed upon the significance of the prisoners' claims for freedom of religious expression. “Comment,” 1488–1504; Brown, 1124–40; Smith, Christopher, “Black Muslims and the Development of Prisoners' Rights,” Journal of Black Studies, 24, 2 (1993), 751–76, 136–37CrossRefGoogle Scholar.

⁹ For existing studies on the responses of white authorities to the NOI see Clegg, Claude, An Unoriginal Man: The Life and Times of Elijah Muhammad (New York: St. Martin's Press, 1997), 84–91Google Scholar, 173–74, 257–60; Essien-Udom, 239–42; Gardell, Mattias, Countdown to Armageddon: Louis Farrakhan and the Nation of Islam (Durham, NC: Duke University Press, 1996)Google Scholar; Gibson, Dawn-Marie, A History of the Nation of Islam: Race, Islam, and the Quest for Freedom (Santa Barbara: Praeger, 2012), 30–32Google Scholar; Lincoln, Eric, The Black Muslims in America (Grand Rapids, MI: William B. Eerdmands, 1994), 169–76Google Scholar; Marable, 182–83, 355–57.

¹⁰ O'Brien, Gail, The Color of the Law: Race, Violence, and Justice in the Post-World War II South (Chapel Hill: University of North Carolina Press, 1999)CrossRefGoogle Scholar; Wagner, Brian, Disturbing the Peace: Black Culture and the Police Power after Slavery (Cambridge, MA: Harvard University Press, 2009)CrossRefGoogle Scholar; Moore, Leonard, Black Rage in New Orleans: Police Brutality and African American Activism from World War II to Hurricane Katrina (Baton Rouge: Louisiana State University Press, 2010)Google Scholar.

¹¹ Ogbar, 22.

¹² Joseph, “The Black Power Movement,” 752.

¹³ One of the greatest challenges in researching the Nation of Islam is the paucity of material on its work, especially during its early days; this challenge is made even greater when combined with the test of investigating the lives of black prisoners. Fortunately, there are some ways of penetrating this tightly closed group. Sociologists and psychologists were intrigued by the changing nature of prison society during the 1950s and 1960s. Many of these scholars were drawn to the increasingly volatile nature of prison race relations during this time; thus their work offers insights into the lives of black convicts, as well as some specific information on the Nation of Islam. Along with newspaper reports and the work of sociologists, FBI reports can help us to gauge which parts of the country had the greatest concentration of convict support and the nature of their activities. In addition, prison rights advocates working during the late 1960s and the 1970s were interested in uncovering the history of prison race relations; this has provided a resource of essays and interviews by individuals who lived within the prison system during the 1950s and 1960s. Most significantly, we have the writings of black activist Eldridge Cleaver, who started his career as a high-ranking member of California's most active NOI prison temple in Soledad.

¹⁴ Beynon, Erdmann D., “The Voodoo Cult among Negro Migrants in Detroit,” American Journal of Sociology, 43 (1938), 894–907, 897CrossRefGoogle Scholar. Most historians follow Beynon's estimate, although the FBI claimed that there were more than 35,000 members by 1934. See Gardell, 54.

¹⁵ 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 Detroit authorities in late 1932, after police arrested Robert Harris for the ritual murder of James Smith. Harris claimed that it had been predestined that a sacrifice would be made on that day and that his “volunteer” would become a “Saviour.” Ten days later, police raided the NOI headquarters and arrested Fard and two other members. They were subsequently released, but the Detroit press dubbed the NOI a “voodoo cult” and it would continue to draw the attention of law-enforcement officers. Beynon, 894–907. The FBI surveillance on Fard is available at http://vault.fbi.gov/Wallace%20Fard%20Muhammed, accessed 20 July 2012. On W. D. Fard and the early years of the Nation of Islam see Clegg; Evanzz, Karl, The Rise and Fall of Elijah Muhammad (New York: Random House, 1999)Google Scholar; Gibson.

¹⁶ See Gardell, 57–58; Lincoln, 15–16.

¹⁷ For example, the NOI's publication Muhammad Speaks regularly highlighted the abuse of civil rights activists by legal officials. “Spurn Bail to Protest Arrest,” Muhammad Speaks (hereafter MS), 4 March 1963, 2; “Lynching! The Crime without Punishment,” MS, 25 Sept. 1964, 7; “Why Capital Punishment Is the Most Premeditated of All Murders,” MS, 6 Oct. 1964, 1; “Crime, Race and Freedom,” MS, 22 Nov. 1963, 5; “Stay out of Jail Drive!”, MS, 6 Dec. 1963, 2; “Negro Youths Braved Jail Terms, Left Prison Ready to Fight on for Freedom,” MS, 7 June 1963, 13; “Muslims Rip Cop ‘Storm Trooper’ Act in Negro Area,” MS, 15 Aug. 1962, 3; “Rep. Powell Demands All Facts in ‘Chain Gang' Trial of 5 Muslims,” MS, 20 Nov. 1962, 2.

¹⁸ See Essien-Udom, 67–74.

¹⁹ Lincoln, 13.

²⁰ Gail O'Brien's study of policing in Tennessee reveals how the police “operated as the frontline guardians 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 of blacks in New Orleans shows how these victims of police brutality were overwhelmingly working-class: the same areas where the Nation of Islam found its greatest amount of support. Moore, 3–4.

²¹ On the ‘urban decline’ of cities see Hirsch, Arnold, Making the Second Ghetto: Race and Housing in Chicago, 1940–60 (Chicago: The University of Chicago Press, 1998)CrossRefGoogle Scholar; Kruse, Kevin M. and Sugrue, Thomas J., eds., The New Suburban History (Chicago: The University of Chicago Press, 2006)Google Scholar; Pritchett, Wendell, Brownesville, Brooklyn: Blacks, Jews, and the Changing Face of the Ghetto (Chicago: The University of Chicago Press, 2002)Google Scholar; Self, Robert O., American Babylon: Race and the Struggle for Postwar Oakland (Princeton: University of Princeton Press, 2004)Google Scholar; Seligman, Amanda, Block by Block: Neighborhoods and Public Policy in Chicago's West Side (Chicago: The University of Chicago Press, 2005)Google Scholar; Sugrue, Thomas J., The Origins of the Urban Crisis: Race and Inequality in Postwar Detroit (Princeton: Princeton University Press, 1996)Google Scholar; Sugrue, , Sweet Land of Liberty: The Forgotten Struggle for Civil Rights in the North (New York: Random House, 2009)Google Scholar. On the use of the term “apartheid” in relation to American race relations see Massey, Douglas and Denton, Nancy A., American Apartheid: Segregation and the Making of the Underclass (Cambridge, MA: Harvard University Press, 1993)Google Scholar. Massey and Denton argue that the hypersegregation of black communities constitutes a form of racial apartheid and is the primary cause of African American poverty. Historians who have drawn this comparison include Frederickson, George M., White Supremacy: A Comparative Study in American and South African History (New York: Oxford University Press, 1981)Google Scholar; Singh, Nikhil Pat, Black Is a Country: Race and the Unfinished Struggle for Democracy (Cambridge, MA: Harvard University Press, 2004)Google Scholar; Woodard, Komozi, A Nation within a Nation: Amiri Baraka (LeRoi Jones) and Black Power Politics (Chapel Hill: University of North Carolina Press, 1999)CrossRefGoogle Scholar.

²² Ansari, Zafari “Aspects of Black Muslim Theology,” Studia Islamica, 53 (1981), 137–76CrossRefGoogle Scholar; Essien-Udom, 115–32; Lincoln, 63–93.

²³ This discussion draws upon Richard Turner's focus upon the importance of signification within the African American Islamic tradition. See Turner, Islam in the African American Experience.

²⁴ For example, Ansari observes that Muhammad's concept of God-as-man was far closer to Christian beliefs than to Islamic. He points to the NOI's idea that God's concerns were focussed exclusively upon blacks as resembling the Jewish concept of Yahweh. Orthodox Muslims 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, 146, 167–68; Lincoln, 26–27.

²⁵ The earlier history of the Moorish Science Temple of America, which was founded in the 1920s 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 Moorish Science Temple and its influence upon the NOI see Essien-Udom, 45–47; Gardell, 37–45; Gibson, A History of the Nation of Islam, 6–10; Lincoln, 48–52.

²⁶ On the NOI's moral code see Essien-Udom, 83–114, 195–205; Lincoln, 63–93.

²⁷ On the importance of the NOI's economic power see Clegg, An Unoriginal Man, 99–100; Essien-Udom, 154–58; Gibson, 39–42; Lincoln, 85–90.

²⁸ See Beynon, “The Voodoo Cult,” 894–907; Gibson, 19–22. Mattias Gardell, 71–76, 85–92, provides one of the best accounts of the FBI's campaign against the NOI.

²⁹ Clegg, 97.

³⁰ Ibid., 97.

³¹ Ibid., 93.

³² One of the most detailed accounts of Muhammad's incarceration and its impact upon both his leadership style and the NOI as a whole can be found in ibid., 82–108.

³³ Muhammad, Elijah, Message to the Black Man in America (Phoenix: Secretarius, 1965), 322Google Scholar. Muhammad appealed to the courts to “turn over such criminals to be executed under the real Islamic law,” and explained, “It is our desire to put a stop once and for all to such crimes being committed among our people.”

³⁴ Lincoln, 109.

³⁵ Cleaver, E., “Initial Reactions on the Assassination of Malcolm X,” in Cleaver, , Soul on Ice (New York: MacGraw Hill/Ramparts, 1967), 57–68, 64Google Scholar.

³⁶ Malcolm X and Haley, Autobiography, 185.

³⁷ Ibid., 199.

³⁸ Lincoln, 199.

³⁹ “Malcolm X talks with Clark, Kenneth B.,” in The Negro Protest: James Baldwin, Malcolm X and Martin Luther King Talk with Kenneth B. Clark (Boston: Beacon Press, 1963), 22, original emphasisGoogle Scholar.

⁴⁰ Ibid., 24.

⁴¹ This argument was also being made by incarcerated civil rights activists in the South. Malcolm X's insistence that black Americans were trapped within a “political, economic and mental prison” was echoed in the civil rights movement's belief that confronting the fear of imprisonment by accepting jail was the route to psychological liberation. Both acknowledged the centrality of the criminal-justice system in oppressing black Americans, as well as the politicizing effect of imprisonment. On this comparison see Colley, Zoe A., Ain't Scared of Your Jail: Arrest, Imprisonment, and the Civil Rights Movement (Gainesville: University Press of Florida, 2012)CrossRefGoogle Scholar.

⁴² Conflict over NOI literature centered on access to Muhammad Speaks, which commenced production in 1960. However, prisoners also sought access to other material, including Muhammad's writing. Despite official censorship, some literature, especially Malcolm X's Autobiography, made its way into the prisons and was circulated within underground networks. In 1971 Autobiography rented at the considerable cost of one pack of cigarettes. See “Prisons Feel a Mood of Protest,” New York Times, 19 Sept. 1971, 1.

⁴³ Butler, “The Muslims Are No Longer an Unknown Quantity,” 57. Also see “Ordeal at Lorton Prison: Why Black Jobs in Jail Join Muhammad,” MS, 9 Oct. 1964, 25; “Historic Court Fight Ends for Muslim Inmates,” MS, 23 Oct. 1964, 9.

⁴⁴ Cleaver, 22.

⁴⁵ Cleaver, Eldridge, “Prisons: The Muslims' Decline,” in Browning, Frank et al. , eds., Prison Life: A Study of the Explosive Conditions in America's Prisons (New York: Harper and Row, 1972), 100Google Scholar. Also see Irwin, John, Prisons in Turmoil (Boston: Little, Brown and Company, 1980), 69Google Scholar.

⁴⁶ Jacobs, Stateville, 60, 256 n. 19; Robert T. Chase, “Civil Rights on the Cell Block: Race, Reform, and Violence in Texas Prisons and the Nation, 1945–1990,” Ph.D. dissertation, University of Maryland, 2009.

⁴⁷ 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 prison converts should do everything they could to secure release see “Muhammad's People Belong in Paradise, Not Prisons,” MS, 25 April 1965, 9.

⁴⁸ Jacobs, Stateville, 58–70; Cleaver, Soul On Ice, 22–23; “The Nation of Islam,” FBI Criminal Research Section report, Oct. 1960, 51–52, available at http://vault.fbi.gov/Nation%20of%20Islam/Nation%20of%20Islam%20Part%201%20of%203/view, accessed 2 Feb. 2012; “Muslins Studied in Jersey Prison”; “Muslims a Problem in Prison”; “Muslim Negroes Suing the State.”

⁴⁹ Carroll, Leo, Hacks, Blacks, and Cons: Race Relations in a Maximum Security Prison (Lexington: D. C. Heath, 1974), 102Google Scholar, 112; Cummins, The Rise and Fall, 71–79; Gibbons, Don C., Society, Crime, and Criminal Behavior (New York: Prentice Hall, 1992), 527Google Scholar; Jacobs, Stateville, 58–9; Jacobs, “The Prisoners' Rights Movement,” 429–35; Irwin, 62–64.

⁵⁰ For example, James Jacobs concluded that the combined effect of “black numerical superiority … and the example of black civil rights activity on the streets … facilitate[ed] the rise of … the Black Muslims” inside Stateville. Jacobs, Stateville, 58–59; Carroll, 102, 112.

⁵¹ This process of politicization was bolstered by prison desegregation, which started in some states during the early 1960s, although the penal system in many southern states remained segregated until after the 1964 Civil Rights Act. The removal of racial barriers intensified racial conflict as white prisoners battled to retain territorial control. The process of desegregation remains a relatively understudied area of penal history. On desegregation in California see Cummins, 71–84. For studies by nonhistorians see Trulson, Chad R. and Marquart, James W., “The Caged Melting Pot: Toward an Understanding of the Consequences of Desegregation in Prisons,” Law and Society Review, 36 (2002), 743–82CrossRefGoogle Scholar; Trulson, and Marquart, , “Racial Desegregation and Violence in the Texas Prison System,” Criminal Justice System, 27 (2002), 233–55CrossRefGoogle Scholar.

⁵² Lincoln, The Black Muslims, 46.

⁵³ Herman, Ellen, The Romance of American Psychology: Political Culture in the Age of Experts (Berkeley: University of California Press, 1996), 1Google Scholar.

⁵⁴ “Muslims A Problem in Prison”; Testimony of Dr. Henri Yaker; “Muslims Studied in Jersey Prison.”

⁵⁵ Cleaver, “Prisons: The Muslims' Decline.”

⁵⁶ Lincoln, 101–2. Also see Essien-Udom, Black Nationalism, 149–57.

⁵⁷ This argument was reflected in liberal sociologists' and psychologists' assessment of racism, and specifically the emasculating effect of racism upon black men. See Grier, William H. and Cobbs, Price M., Black Rage (New York: Basic Books, 1968)Google Scholar; Clark, Kenneth B., Dark Ghetto: Dilemmas of Social Power (Middletown, CT: Wesleyan University Press, 1989)Google Scholar; Kardiner, Abram and Ovesey, Lionel, Mark of Oppression: A Psychological Study of the American Negro (New York: W. W. Norton, 1951)Google Scholar; Moynihan, Daniel P., The Negro Family: A Case for Action (March 1965)Google Scholar.

⁵⁸ Yaker quoted in “Muslims a Problem In Prison.” Also see Testimony of Dr. Henri Yaker; “Muslims Studied in Jersey Prison.”

⁵⁹ Ogbar, Black Power, 29. As Steve Estes has observed, the expectation that black men respect and protect women from white attack “directly challenged the defeminization and denigration of black womanhood in mainstream white culture.” Revelations in 1963 that Muhammad had long engaged in extramarital affairs threw the sincerity of these teachings into account. The FBI had long been aware of Muhammad's indiscretions and had, largely unsuccessfully, used them in their attempt to discredit him. Estes, Steve, I Am A Man! Race, Manhood, and the Civil Rights Movement (Chapel Hill: University of North Carolina Press, 2005), 91Google Scholar. On the role of women in the Nation of Islam see Griffin, Farah, “‘Ironies of the Saint’: Malcolm X, Black Women and the Price of Protection,” in Thomas-Collier, Bettye and Franklin, Vincent P., eds., Sisters in the Struggle: African American Women in the Civil Rights–Black Power Movement (Palo Alto: Ebrary, 2005)Google Scholar. Conventional analyses of NOI gender relations have tended to focus upon how Muhammad's emphasis upon protecting black women from white men was more about protecting black men's “proprietary rights” over black women than about honoring women. Feminist historians have argued that this overlooks the way in which black women often viewed their membership of the NOI and 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 Civilization Class. She argues that, while teaching in the class was intended to educate girls on how to fulfill their roles of wife and mother, NOI women actually transformed it to a “space for broadening the scope of motherhood to community activism.” See Karim, Jamillah, “Through Sunni Women's Eyes: Black Feminism and the Nation of Islam,” Souls: A Critical Journal of Black Politics, Culture and Society, 8 (2006), 19–30CrossRefGoogle Scholar, 20, 26.

⁶⁰ Ogbar, 29.

⁶¹ Cleaver, Soul on Ice, 29.

⁶² See “The Nation of Islam,” Oct. 1960, 51–54.

⁶³ “Muslim Negroes Suing the State”; “Muslims a Problem in Prison.” The most radical prison branches of the NOI were found in California's Soledad, San Quentin, and Folsom prisons. Eric Cummins, The Rise and Fall, 69–74, refers to instances of Muslim-organized protests.

⁶⁴ “Muslim Negroes Suing the State.”

⁶⁵ Yaker quoted in “Muslims a Problem in Prison.”

⁶⁶ “Muslim Negroes Suing the State”; “Muslims a Problem in Prison.”

⁶⁷ “The Nation of Islam,” Oct. 1960, 51; “Ordeal at Lorton Prison”; “Historic Court Fight Ends”; “Muslims a Problem in Prison”; Testimony of Dr. Henri Yaker; Butler, “The Muslims Are No Longer an Unknown Quantity,” 57. Four convicts in a New York State prison also launched a legal battle against prison authorities in 1959. See “Muslim Negroes Suing the State.”

⁶⁸ “Nation of Islam. Cult of the Black Muslims,” FBI Criminal Research Section report, May 1965, 88. Available at http://vault.fbi.gov/Nation%20of%20Islam/Nation%20of%20Islam%20Part%202%20of%203/view, accessed 2 Feb. 2012.

⁶⁹ On the impact of Muhammad's incarceration see Clegg, An Unoriginal Man, 97–99.

⁷⁰ On the divergence between NOI strategy inside and outside prisons, and especially the increasingly political outlook of California's prisoners, see Cummins, 65.

⁷¹ The 1962 police raid of the Los Angeles temple, during which Ronald T. Stokes was killed and six other members were injured, exemplified the impact of legal harassment upon the organization. Four Muslims were subsequently charged with assault upon a law-enforcement officer and sentenced to long prison sentences. Elijah Muhammad's refusal to provide these men with legal assistance angered both prisoners and mainstream members. See Cleaver, Soul on Ice; Clegg, 170–73; Knight, Frederick, “Justifiable Homicide, Police Brutality, or Governmental Repression? The 1962 Los Angeles Police Shooting of Seven Members of the Nation of Islam,” Journal of Negro History, 79 (1994), 182–96CrossRefGoogle Scholar.

⁷² Cummins, 88; “Muslim Negroes Suing the State.”

⁷³ Smith, “Black Muslims,” 136–37.

⁷⁴ Ibid., 138–39. Also see Jacobs, “The Prisoners' Rights Movement,” 429–70; “Comment,” 1488–1504; Brown, “Black Muslim Prisoners,” 1124–40.

⁷⁵ On judges' reluctance to intervene in the penal system see Brown, 1124–25; “Comment,” 1488–89.

⁷⁶ The 1961 case of Sewell v. Pegelow, upheld the right of prisoners to not be punished on account of their religious faith; in 1962, Fulwood v. Clemmer upheld a limited right to proselytize; in 1964, Banks v. Havener guaranteed the right to hold religious services. The 1964 case of Coleman v. District of Columbia Commissioners upheld the right to wear religious medals. See Smith, 131–46.

⁷⁷ Brown, 1124–40; Jacobs, “The Prisoners' Rights Movement”; Jacobs, Stateville, 64–65; Smith, 131–46. The Cooper case was an exception to Elijah Muhammad's refusal to provide support to prisoners' legal challenges; he hired an attorney on behalf of Cooper. In a 1967 Illinois case, Muslims were granted the right to have ministers visit them inside prison. In Pennsylvania a year later prison authorities were ordered to lift their ban on Muhammad Speaks. In 1970 a federal judge ruled that Black Muslims in California belonged to a legally recognized religion, and were therefore due the same rights as members of other religious groups. See Butler, “The Muslims Are No Longer an Unknown Quantity,” 57; Cummins, 72–73; Hawkins, Gordon, The Prison: Policy and Practice (Chicago: The University of Chicago Press, 1974), 138–39Google Scholar; Pallas, John and Barber, Robert, “From Riot to Revolution,” in Wright, Erik Olin, The Politics of Punishment: A Critical Analysis of Prisons in America (New York: Harper and Row, 1973), 8Google Scholar.

⁷⁸ Jacobs, Stateville, 139–44.

⁷⁹ Cleaver, “Prisons: The Muslims' Decline,” 103; Cummins, 95–96. Malcolm X's departure from the NOI, and his subsequent death, also had a destructive impact upon the NOI as a whole. As Dawn-Marie Gibson observes, 1964–65 was a watershed period in the Nation of Islam's history. Alongside the split with Malcolm X, revelations about Elijah Muhammad's sexual indiscretions and abuses of power further undermined his authority. See Gibson, A History of the Nation of Islam, 65.

⁸⁰ Many politicized prisoners during the late 1960s were keen to distance themselves from the earlier work of the Nation of Islam. They argued that the group's emphasis upon black separatism had promoted division between prisoners, when they actually needed to unite across racial barriers to challenge prison authorities. See, for example, “George Jackson Speaks from Prison,” Black Panther Party Newspaper, 17 Oct. 1970, 6.

⁸¹ Jacobs, “The Prisoners' Rights Movement,” 465.