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Lyle C. May

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In a large concrete room on Central Prison’s death row in North Carolina, to my knowledge, I became the first incarcerated person in the state to take the Law School Admission Test (LSAT). 

It was November 2025, and I felt proud to be an academic trailblazer in the last place anyone expects academic success. A case manager from the prison’s programs department served as the testing proctor. He opened a large, gray storage container and withdrew thick, sealed envelopes. He began the LSAT by reading the instructions aloud.

I arrived at the LSAT under unusual circumstances. 

I was first incarcerated in 1997 at the age of 19 for a double homicide I did not commit. However, I was ultimately convicted and sentenced to death in 1999. A few years later, I was offered an opportunity to access college courses inside. With only a GED earned in a Maine youth detention center, I enrolled in University of North Carolina at Chapel Hill correspondence courses sponsored by a local Catholic church. Correspondence courses were slow-paced, and the funding limited me to two or three courses each year. But I stuck with it, finding refuge in education from the pains of imprisonment. By the spring of 2025, I was on the cusp of earning my Bachelor of Arts degree in interdisciplinary studies. With graduation approaching, I knew I needed a new academic plan.

A friend who runs a reentry program in Minnesota sent me an application for the Prison to Law Pipeline (PLP), a program that creates a potential pathway for incarcerated people to obtain paralegal and law degrees approved by the American Bar Association. The PLP was created in 2022 by The Legal Revolution, a nonprofit that grants scholarships to incarcerated people who meet specific requirements to virtually attend Mitchell Hamline Law School in St. Paul. 

More than anything, I wanted one of those scholarships. 

For incarcerated applicants, one of the biggest hurdles can be obtaining support from prison administrators who control access to testing and educational programs. The PLP program also prioritizes applicants who are serving lengthy sentences, the idea being that they would complete law school while still inside and apply what they learned to help themselves or others in prison. 

Typically, college prison programs in North Carolina are reserved for people with release dates. That restriction—even with the return of Pell grants for incarcerated people—excludes most people serving death or life sentences. This leaves only college correspondence courses paid for by family, friends, or a private party. But being able to cover the costs doesn’t guarantee access, because some prison administrators simply refuse to support the rehabilitative efforts of people serving life or sentenced to death. 

Advanced degree programs for people in prison are rare. Adams State University in Colorado maintains a correspondence-based Master of Business Administration program. Universities across the U.S. have graduate programs accessible to some prisons. California State University, Dominguez Hills began the state’s first master’s degree program for incarcerated students in 2023, but it faces an uncertain future due to funding issues. California has long been a leader in offering educational opportunities to people inside, while other states such as North Carolina are tepid in their embrace of rehabilitation for those on death row or serving life. 

The PLP, on the other hand, does not deny applicants on the basis of their sentence. At the time I applied, I knew of at least four candidates already accepted by Mitchell Hamline were lifers. I knew that earning one of The Legal Revolution’s scholarships would be difficult, but not impossible. I’ve already overcome impossible odds for someone on death row, including completing a B.A. degree and an Advanced Paralegal Certificate and publishing two books, law review articles, and several reported stories as an incarcerated journalist. 

No protection, no guarantee 

During my 10-minute break between sections of the LSAT, the test proctor expressed interest in my academic journey. He congratulated me on completing a bachelor’s degree. “Kudos to you, Mr. May. You should be proud of yourself for trying and getting this far,” he said. The unexpected compliment made my eyes briefly water and magnified the importance of the task at hand. I shoved aside my feelings and focused. 

To say that the LSAT is precisely timed, highly structured, and leaves no room for error is an understatement. There’s an entire industry of prep tests, guidebooks, and tutors, all promising to help test-takers improve their LSAT score and get into a prestigious law school. After 10 months of studying for the test from my cell, pouring over guidebooks sent by The Legal Revolution, and taking prep tests, I felt as prepared as I could be.

The LSAT is a highly specialized standardized test that focuses entirely on memorized content. Oddly, the LSAT has few questions pertaining to the law or common knowledge. What makes preparation extremely challenging is that the test relies on the ability to understand the logic of arguments, recognize flawed reasoning, and digest dense passages of writing on a variety of topics under intense time constraints. The job of the test-taker is to read between the lines.

There is some debate as to whether the LSAT actually determines a student’s ability to succeed in law school. For those who don’t test well, a low LSAT score effectively bars admission to many law schools, regardless of an undergraduate GPA. On the other hand, the LSAT attunes prospective law school students to the structure of their arguments and sharpens their critical reasoning abilities, which are essential for practicing law. Some law schools now make the LSAT optional, instead requiring the Graduate Readiness Exam (GRE) used for graduate school.

After completing the first section of the LSAT, the proctor gave me the essay prompt for the second and final section. I was halfway through the prompt, when a programs department supervisor came into the room and announced my time was up.

The proctor rushed to quiet the supervisor, explaining that I was still testing. “His time is up, and he needs to return to his cell block,” the supervisor said.

The proctor rushed to quiet the supervisor, explaining that I was still testing. “Well, that has nothing to do with me,” the supervisor said. “His time is up, and he needs to return to his cell block.” She stood there, smiling.

In prison, tests come in many forms. During my time on death row, I’ve spent years dealing with obstruction, pettiness, and arbitrary rules from program staff. Usually, I worked around the interference to accomplish my goal. However, this would not be one of those times. Anger squeezed my chest, but I took a deep breath and told myself to let it go. I was promptly escorted back to my cell. 

We also have no right to education in prison. Whether funded by Pell grants, the state budget, or a nonprofit organization such as The Legal Revolution, access to education is largely based on the whims of prison officials. Because nothing protects or guarantees our ability to access education, random prison administrators have the ability to unilaterally deny or undermine education inside. This signals to incarcerated people that no matter how hard they try, how closely they follow the rules, or how much they achieve against the odds, there will always be an authority figure who does not care and can derail their progress with any excuse. In the face of such opposition, many stop trying. 

The North Carolina Department of Adult Correction (NCDAC) did not respond to requests for comment. 

After I was prevented from completing the LSAT, I contacted the director of The Legal Revolution and explained what had happened. She told me not to worry, reminding me that I could retake the test up to five times. In a follow-up call, she informed me that the Law School Admission Council, which administers and scores the LSAT, agreed to let me complete the final section. Until then, I wouldn’t know my score. 

As it turned out, the associate warden of programs, an administrator who previously tried to halt my access to higher education, told The Legal Revolution director that I would not be allowed to complete or retake the LSAT because prison staff needed to focus on GED testing. 

It was a nonsensical excuse—and an ironic one.

A rehabilitative crossroads

As part of North Carolina’s mandatory prison education policy, intellectually capable people who do not have a high school diploma or GED are required to enroll in a High School Equivalency (HSE) program for a minimum of six months. 

The policy only applies to those held in the general population, meaning it excludes people on death row such as Marcus Mitchell, who spent almost two decades advocating for people on death row to be able to access educational opportunities. Mitchell said officials consistently told him that he was not in prison to be rehabilitated. Frustrated, in 2023 he wrote then-Gov. Roy Cooper, stating his case. He assumed it would be another effort that went nowhere.

However, months after writing the governor, Mitchell received a visitor: Brooke Wheeler, the superintendent of NCDAC’s Education Services. Wheeler informed Mitchell that Cooper heard his plea—and agreed. NCDAC would bring an HSE program to death row. 

Sadly, the effort stalled not long after it began in late 2023. Wake Tech, the community college that agreed to serve as a partner, notified prison officials that due to federal regulations, it could not move forward. The school’s plan was to use the Workforce Innovation and Opportunity Act to fund the HSE program. However, the law was designed to help job seekers, and it prioritized the use of funds for incarcerated people set to be released within five years of participating in the program. Therefore, people on death row were not eligible under the law. 

NCDAC and the warden of Central Prison were unwilling to fund the HSE program through another avenue. Instead, the 20 or so men on death row who planned to participate in the HSE program were given donated books and access to temporary student volunteers. There are still no educational programs for North Carolina’s death row—not even proctors for self-funded college correspondence courses.

When I was effectively barred from finishing the LSAT, it was basically the end of education on death row—unless “education” means using a tablet to access unaccredited educational content that provides no oversight or guidance; cannot be used as a credential; and does not lead to a diploma, degree, or trade certification. Those are opportunities reserved for people with release dates.

Recent changes to NCDAC education policy further restrict education on death row, giving the Central Prison warden control over all programs. Decision-making is often then delegated to the associate warden of programs, a person who, in my experience, has long held anti-intellectualist views and antipathy toward the prison population—especially for those of us on death row. 

North Carolina’s prison system is at a rehabilitative crossroads. In 2024, the state became a part of Reentry 2030, an initiative by the Council of State Governments Justice Center to unite government and community leaders to reduce recidivism 30% by 2030. Only seven other states have signed on. In North Carolina’s strategic plan for the initiative, one of the primary objectives is to increase the number of high school diplomas, high school equivalencies, and continuing education credentials earned by eligible people in adult and juvenile secure custody facilities by 75%.

Access to education in prison is essential to North Carolina’s success as part of Reentry 2030. But of equal importance is the institutional support required to implement these opportunities; the initiative will only be as effective as prison administrators allow it to be. If administrators are not fully committed, or they allow prejudices to cloud their judgment, or are simply bad at their jobs and never held accountable, it will only create additional and unnecessary barriers that undermine rehabilitation and public safety.

California Department of Corrections and Rehabilitation Commissioner Robert Burton was previously a prosecutor who saw the failures of the broken criminal legal system. In a 2017 TEDx talk when Burton was California’s inspector general, he said that rehabilitation—if made real—can have more of an impact on public safety and society than any other purported function of the criminal legal system, including punishment and deterrence. Transforming incarcerated people is a process, one that should grant them the choice to be better, make smarter decisions, turn the light of accountability on, and decide to change. Access to education in prison enables that change.

One day I will retake the LSAT and continue pursuing my dream of attending law school. In the meantime, I am encouraged to know there are prisons that provide unilateral support for incarcerated learners, instead of reluctance and hostility.

The Right to Write (R2W) project is an editorial initiative where Prism works with incarcerated writers to share their reporting and perspectives across our verticals and coverage areas. Learn more about R2W and how to pitch here.

Editorial Team:
Tina Vasquez, Lead Editor
Carolyn Copeland, Top Editor
Rashmee Kumar, Copy Editor