Barry A. Hazle Jr. served his time for drug possession. When he was released on parole, he was told that he had to attend a 90-day drug treatment program, which involved the well-known 12-step program (commonly used by Alcoholics Anonymous.) The 12-step program includes references to God and submitting to a “higher power.”
He asked to be reassigned to a secular treatment project but it didn’t happen so he attended and objected to the 12-Step classes. His parole officer arrested him for violating parole and Hazle was sent back to prison for four months. A three-judge panel of the U.S. 9th Circuit Court of Appeals said “a jury should award Barry A. Hazle Jr., a drug offender, compensatory damages for his loss of freedom and could consider possible punitive and emotional distress damages as well.” He was compensated nearly $2 million for the First Amendment violation.