Colorado Ends Twelve-Step Requirement for Parolees

Colorado parolees will no longer be required to attend Alcoholics Anonymous, Narcotics Anonymous or other religious twelve-step programs as a condition of release, under changes the state Department of Corrections began implementing this week, the advocacy organization American Atheists announced Thursday. The parole board will instead refer people under supervision to peer support networks that include secular programs such as SMART Recovery and LifeRing.

The group said the reforms put the core protections of recovery-options legislation it has championed into effect for parolees without requiring new legislation, and that they were negotiated with the department by its Colorado Secular Advocacy Team and a coalition of partners. The Department of Corrections has not issued its own announcement of the changes.

What the department agreed to change

According to American Atheists, the department ended the twelve-step mandate effective immediately. It also committed to improving access, transparency and disclosure for parolees required to participate in sober housing programs as a release condition. Under the changes, provider applications must disclose any faith-based requirements, and any parolee whose sober housing assignment conflicts with their religious or nonreligious beliefs will be informed of alternative placements and referred to them.

To close access gaps, the department will offer a telehealth option for parolees who want to attend a secular peer support program but live too far from a group. Coalition members will meet with the department regularly to raise issues facing nonreligious and religious-minority Coloradans under supervision, and American Atheists listed Colorado Alternative Defense Counsel, the Interfaith Alliance of Colorado, SMART Recovery, LifeRing and Front Range Defense and Legal Counsel among its partners in the effort.

"You don't lose your First Amendment rights when you become involved with the criminal legal system," said Victoria Anderson, a state policy specialist at American Atheists. "Today, thanks to the efforts of our Secular Advocacy Team and coalition partners throughout Colorado, the Department of Corrections is implementing meaningful change so that no one will be subjected to religious programming as a condition of their parole."

Sheryl Kallivrousis, co-chair of the Colorado Secular Advocacy Team, said the group worked with Rep. Lori Goldstein, a Democrat representing District 29, to bring the department to the table. "This didn't happen overnight," she said. "Our team spent several years building relationships with legislators and key stakeholders."

A requirement that courts have questioned

Federal courts, including multiple U.S. circuit courts of appeal, have held that forcing people into twelve-step programs as a condition of supervision violates the Establishment Clause of the First Amendment. The requirement nonetheless remains common in parole and probation systems across the country, and American Atheists says many people fear that requesting an alternative could cost them their freedom.

In 2023, the organization settled a case on behalf of Andrew Miller, a West Virginian who it said was repeatedly denied parole after refusing to take part in pervasively religious twelve-step programming while incarcerated. A preliminary injunction ordered the requirement removed, and Miller was released.

How far the change reaches beyond Colorado is unclear. American Atheists says the twelve-step requirement remains common in parole and probation systems nationwide, and the organization is treating the Colorado agreement as a template for organizers in other states. For people leaving custody with a substance use disorder, the change reframes a long-standing question about court-ordered treatment: medication-assisted treatment and outpatient care are established clinical alternatives to twelve-step programming, and parole conditions in Colorado can no longer steer people exclusively toward the religious version.

Where the change stops

Parole is covered; probation is not. Kallivrousis said the coalition intends to press for the same treatment of secular options in probation conditions, adding, "I hope Colorado is the model for organizers in every state."

American Atheists did not release the text of any written agreement with the Department of Corrections, and the department did not respond to the announcement with a public statement of its own. The group's account does not describe whether the changes are written into department policy or applied case by case, or how compliance will be verified.