DENVER, CO — Thanks to advocacy by American Atheists, the organization’s Colorado Secular Advocacy Team, and a broad coalition of partners, Colorado parolees will no longer be required to attend Alcoholics Anonymous, Narcotics Anonymous, or any other religious twelve-step program as a condition of parole.
The change is one of several the Colorado Department of Corrections is implementing from recovery options legislation championed by American Atheists. The reforms agreed to by the Department put the core protections of the recovery options bill into effect for parolees without requiring new legislation.
Effective immediately, the Department of Corrections will end the twelve-step mandate, with the parole board instead referring parolees to “peer support networks,” which include secular programs such as SMART Recovery and LifeRing, instead of requiring AA, NA, or any other twelve-step program.
In addition, the Department will improve access, transparency, and disclosure for parolees who are required to participate in sober housing programs as a condition of release. Under the changes, all applications for providers must disclose any faith-based requirements and any parolee whose sober housing program conflicts with religious or nonreligious beliefs will be informed of alternative placement options and referred to them. And to address access gaps, parolees who want to attend a secular peer support program but do not have a group nearby will have a telehealth option available instead.
“You don’t lose your First Amendment rights when you become involved with the criminal legal system,” said Victoria Anderson, 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.”
Federal courts, including multiple circuit courts of appeal, have held that forcing people into twelve-step programs as a condition of supervision violates the Establishment Clause. Even so, the requirement remains common in parole and probation systems nationwide. Many Americans report fear that pushing back on these requirements by requesting an alternative or asserting their constitutional rights could cost them their freedom.
In 2023, American Atheists won a legal victory for Andrew Miller, a West Virginian who was repeatedly denied parole after refusing to participate in pervasively religious twelve-step programming while incarcerated. Following a preliminary injunction that ordered the removal of the requirement, Andrew was released.
“We believe no one should be forced into a religious twelve-step program. And today, I’m proud that the state of Colorado agrees,” said Sheryl Kallivrousis, co-chair of the Colorado Secular Advocacy Team. “The Secular Advocacy Team, backed by American Atheists and with the help of Rep. Lori Goldstein (D–District 29), brought the Department of Corrections to the table, and we got this done.”
“This didn’t happen overnight. Our team spent several years building relationships with Legislators and key stakeholders. This is how organizing works, and it’s how we protect people with the least power to say no. Parole is checked off our list, but we’re not done. Probation is next. I hope Colorado is the model for organizers in every state,” added Kallivrousis.
The Colorado Department of Corrections has also committed to working with American Atheists and other secular advocates to address the unique problems faced by nonreligious and religious minority Coloradans under supervision. Coalition members will meet with the department regularly to raise these issues and work toward solutions.
American Atheists wishes to thank its partners in the Recovery Options coalition, including Colorado Alternative Defense Counsel, Interfaith Alliance of Colorado, SMART Recovery, LifeRing, and Front Range Defense and Legal Counsel PLLC.





