CODEPENDENCE - DEAN AMORY

groups are spiritual, and not religious. Some members of 12-step groups are also
members of a wide variety of religious bodies. Nearly every meeting begins with
the { HYPERLINK "http://en.wikipedia.org/wiki/Serenity_Prayer" \o "Serenity
Prayer" }, a prayer addressed to "God." Some critics also question the idea of
giving up on self-reliance, which, they argue, results in a form of idealized
despair. Others acknowledge a debt to the twelve-steps movement but do not
have a culture of belief in God.
Court-mandated Twelve-step attendance
The success of twelve-step programs in aiding the recovery of { HYPERLINK
"http://en.wikipedia.org/wiki/Addiction" \o "Addiction" } is an argument of
significance in jurisdictions of some criminal justice systems. The { HYPERLINK
"http://en.wikipedia.org/wiki/Criminal_justice_system" \o "Criminal justice
system" } of the { HYPERLINK "http://en.wikipedia.org/wiki/United_States" \o
"United States" } has ordered attendance at 12-step meetings to convicted {
HYPERLINK "http://en.wikipedia.org/wiki/Criminals" \o "Criminals" } as well as
inmates as a condition of { HYPERLINK "http://en.wikipedia.org/wiki/Parole" \o
"Parole" }, condition of shortened sentence, or as an element of a sentence. Four
courts have ruled that { HYPERLINK
"http://en.wikipedia.org/wiki/Alcoholics_Anonymous" \o "Alcoholics Anonymous"
} groups are { HYPERLINK "http://en.wikipedia.org/wiki/Religious" \o "Religious"
} organizations.
{ HYPERLINK "http://en.wikipedia.org/wiki/Twelve-step_program" \l "_note-PEELE2000#_note-
PEELE2000" \o "" } The New York Court of Appeals ruled in { HYPERLINK
"http://www.law.cornell.edu/nyctap/comments/i96_0137.htm" \o
"http://www.law.cornell.edu/nyctap/comments/i96_0137.htm" } that doing so
compromises the { HYPERLINK
"http://en.wikipedia.org/wiki/Establishment_Clause" \o "Establishment Clause" }
of the { HYPERLINK "http://en.wikipedia.org/wiki/United_States_Constitution" \o
"United States Constitution" } on the grounds that A.A. practices and doctrine
are (in the words of the district court judge who wrote the decision)
"unequivocally religious". The { HYPERLINK
"http://en.wikipedia.org/wiki/Supreme_Court_of_the_United_States" \o
"Supreme Court of the United States" } denied { HYPERLINK
"http://en.wikipedia.org/wiki/Certiorari" \l "United_States_Law" \o "Certiorari" }
and allowed the New York court's decision to stand. Such a denial "imports no
expression of opinion upon the merits of the case, as the bar has been told many
times." { HYPERLINK "http://en.wikipedia.org/wiki/Missouri_v._Jenkins" \o
"Missouri v. Jenkins" }, { HYPERLINK
"http://supct.law.cornell.edu/supct/html/93-1823.ZS.html" \o
"http://supct.law.cornell.edu/supct/html/93-1823.ZS.html" } ({ HYPERLINK
"http://en.wikipedia.org/wiki/1995" \o "1995" }). Denial of certiorari means that
no { HYPERLINK "http://en.wikipedia.org/wiki/Binding_precedent" \o "Binding
precedent" } is created, and that the lower court decision is authoritative only
within its area of jurisdiction -- in this case the State of New York. However, the
decision does create a { HYPERLINK
"http://en.wikipedia.org/wiki/Persuasive_precedent" \o "Persuasive precedent" }
for other jurisdictions.