Narcoleptic Wakes Up Supreme Court

On October 5, 2011 the Supreme Court will face one of the most important religious liberties cases it has seen in over decades. Hosanna-Tabor Evangelical Lutheran Church and School v. Equal Employment Opportunity Commission (No. 10-553) addresses the ministerial exception and a religious institutions ability to discriminate against employees. The exception allows organizations to discriminate against ministerial personnel who violate their ideologies. In this case a teacher, Cheryl Perich, was fired after she returned from sick leave for narcolepsy. Even though Ms. Perich claimed to be fully recovered and her condition brought under control with medication, church officials requested she resign. She repeatedly refused and threatened the school with legal action. The church’s teachings state that disputes should be handled internally and not through the legal system. This insubordination led to her dismissal from the school. What the Court is examining is whether or not Ms. Perich’s responsibility were sacred or secular and if she should be included under the exemption.

What is under dispute specifically in the case may appear menial but its effects on the ministerial exemption and liberties of thousand of church employees can be massive. Hosana-Tabor v. EEOC does not serve as the clearest example for the violation of religious liberties, but it serves as an example of discrimination to occur within the workplace. A clearer example of this is would be what if a biology teacher at a religious school admitted to believing in evolution or a janitor in charge of cleaning the sanctuary came out as being homosexual. This ruling could give the church immunity against federal intervention on antidiscrimination laws. According to the Chronicle,

It would leave hundreds of thousands of teachers without the protection from discrimination and retaliation that Congress intended to afford them. They would be "unprotected against retaliatory dismissals" for activities such as reporting health violations or sexual abuse, or fighting for better pay. Nothing in the right of free association—or, indeed, in any right under the Religion Clauses—grants religious organizations such a sweeping exemption from neutral and generally applicable antidiscrimination laws.

I am very interested in seeing the outcome of the courts decision. In my opinion the church was not out of line for firing their employee after she threatened officials with legal action. There are reasons why institutions have policies such as Hosana-Tabor’s dispute process. Legal action brings about negative press to the church, which is why it prefers to deal with matters in house. Ms. Perich clearly violated this rule and her employment was appropriately terminated. What I fear is the free exercise of the church may expand too far. Should religious institutions be able to discriminate against whomever they want undermining the protections offered to employees by a wide variety of federal laws? Should have Reynolds been given the right to multiple wives?

Blasphemy and The Book of Mormon

The highly anticipated Broadway show The Book of Mormon opened on March 24^th and has been selling out shows ever since. Before its debut late March, the musical received some negative publicity – with people claiming that the play was “blasphemous” and “boundary pushing.” The play’s masterminds – Trey Parker and Matt Stone – were the reason for most of these accusations. Parker and Stone are the creators of South Park, a popular American animated sitcom often accused of offending various religious practices and beliefs.

After its opening show in March, The Book of Mormon received rave reviews, and did not stir the pot as much as many had anticipated. Rather than viciously mocking the Mormon faith, the musical used subtle and witty humor to take a closer look into the Mormon religion. This, in turn, has furthered conversation about religion, faith and what it means to be religious in society today. According to the show's page on broadway.com:

The Book of Mormon follows two young missionaries who are sent to Uganda to try to convert citizens to the Mormon religion… Upon their arrival in Africa, Elders Price and Cunningham learn that in a society plagued by AIDS, poverty and violence, a successful mission may not be as easy as they expected.

The show humorously assesses the Mormon faith by showing viewers what it’s like to be a Mormon living in society.

In her article for The Huffington Post, Silpa Kovvali assesses the boundary-pushing of The Book of Mormon. After viewing the show, she concludes that although the play does touch on some sensitive religious topics, it does not blatantly cross any serious lines. She said she was “entertained, not insulted” by the boundary-pushing of The Book of Mormon. She believes that the show poses tough questions that require complicated answers, and that there is no holy book “malleable or sophisticated enough” to provide these answers. Kovvali understands that a satirical musical cannot be a primary source for religious truth and understanding. The questions that religious faiths pose are too complex to be answered in a 3 hour musical. That being said, Kovvali appreciates the questions that The Book of Mormon suggests. She says:

How can someone armed solely with his scripture claim to know the best way to earthly salvation? Isn't it cruel in its recklessness to promote the notion that serious problems can be solved through religious belief, which after all can't fill empty stomachs or exterminate the maggots in one's scrotum?

For Kovvali, The Book of Mormon “humanized a religious minority that is often subject to mean-spirited parody and immature, unclever humor…” Instead of blatant name-calling and offensive religious slurs, Trey Parker and Matt Stone cleverly poked fun the Mormon religion, and showed their audience how it can often be tough to strictly abide to a particular faith such and Mormonism.

As we have seen in class, the concept of blasphemy is tricky to deal with from a legal perspective. The potential controversy that surrounded The Book of Mormon before its debut reminds us that religious topics are frequently debated once an issue gets the attention of the public. It also poses many questions involving the Constitution and the ever-evolving relationship that exists between church and state in the United States. Questions for discussion include: 1. Had The Book of Mormon been more blasphemous and offensive, should it have been allowed on Broadway? 2. Where do we draw the line legally with cases involving blasphemy today? Should a line exist at all? 3. Do the victims of blasphemy deserve a say when their faith is directly offended? 4. Should we allow complete freedom of speech regarding blasphemy cases, or should we protect the rights of those offended?

In my opinion, The Book of Mormon has had a positive effect on the often uncomfortable conversation that occurs between people of different faiths. There will always be controversy when people express what they believe in. What Trey Parker and Matt Stone have shown us is that, if done in the right way, we can all express our particular religious preferences without any legal conflict or controversy. Of course, blatant acts of blasphemy should still be reprimanded, but I believe that in order to promote religious freedom and tolerance, there needs to be communication between those of different faiths. The Book of Mormon, in my opinion, provides us with a wonderful way to communicate. The irony around the concept of blasphemy and The Book of Mormon is that three of the most controversial figures in entertainment today have created a show that, rather than being distasteful and offensive, promotes a civilized discussion regarding faith and religion in America, and proves that religion need not be a topic of such controversy in our country today.

Fighting Crime With Religion

A small town in southern Alabama has given local judges a new weapon in the war on crime: religion.

Bay Minette, Ala. has initiated Operation ROC: Restore Our Community; a program in which qualifying first time offenders of non-violent misdemeanors may choose to attend church services once a week for a year instead of going to jail or having to do community service. Under the program, pastors would partner with local law-enforcement by monitoring the attendance of participating offenders; if they complete the program and check-in all 52 weeks, then their case is dismissed. So far, 56 churches in the Bay Minette area have decided to participate in the program.

Supporters of Operation ROC have praised the program for being an alternative to the traditional punitive sentences facing most criminals, giving offenders a better chance to be rehabilitated. As the Bay Minette Police Chief Mike Rowland said, “its not a crime prevention program. It’s a crime intervention program.” He continued by saying “we’re hoping that through this program for the next year, we will take a substantial number who are sentenced and turn them around and let them become productive people in the community.”

Supporters also point to the fact that the program has the potential to save the taxpayers a substantial amount of money. Alabama has a high incarceration rate and faces prison overcrowding. By giving offenders an alternative to jail, the state may avoid incurring the cost of their incarceration (assuming the person in question completes the program).

While it is obvious that this program has nothing but the best of intentions, one must still question its constitutionality. Groups such as the Freedom From Religion Foundation and the American Civil Liberties Union have already criticized the program, claiming it violates the Establishment Clause of the First Amendment. The Freedom From Religion Foundation issued a statement that in part says that it is “a bedrock principle of constitutional law that the state cannot coerce citizens to participate in religious practices.” Supporters of the program have countered by arguing that participation in the program is strictly voluntary and that no one can be forced to attend church in lieu of incarceration.

So, the issue at hand here is “does offering a religious alternative to traditional sentences constitute an establishment of religion?” The ACLU says yes, but established legal precedent says no.

The arguments presented against Operation ROC are similar to those presented against Alcoholics Anonymous. For many years, judges would sentence offenders of alcohol-related crimes to mandatory AA meetings for a certain length of time in lieu of sending them to jail. However, several lawsuits were eventually filed due to discomfort felt by the offender in meetings because of the role of religion in AA (for instance, several of the program’s 12 steps mention God). Federal courts have ruled time and time again (or instance, in Griffin v. Coughlin (1997)) that mandatory AA attendance violates the Establishment Clause of the First Amendment because of the overt role of religion in the organization. However, those same courts ruled that presenting AA attendance as an alternative to incarceration and allowing offenders to choose between the two does not constitute an establishment of religion, nor does it constitute, as the Freedom From Religion Foundation put it, “coercion to participate in religious practices.”

So, if participation in Alcoholics Anonymous is an acceptable alternative to incarceration if presented to offenders as part of a choice of possible punishments, why can’t Operation ROC be an acceptable alternative as well? There isn’t really much of a difference between the two: both are religiously oriented rehabilitative programs offered as alternatives to incarceration that offenders have the choice to participate in. If one program is acceptable, the other should be as well.

I thought it was interesting that neither side of the debate addressed the issue of “what if a person’s denomination (or religion as a whole, in the case of Muslims, Jews, etc.) is not represented in the group of participating churches?” If that is the case, the person has a couple options. First, they can choose not to participate in the program if they do not feel comfortable with any of the participating churches. It is after all a voluntary program, both for the offender and for the churches. Just as the court cannot force someone to attend church, it also cannot force a place of worship to participate in the program; both would be unconstitutional. The other option available to the offender is to just do the bare minimum to complete the program. The only stipulation of the program is to attend one of the participating churches once a week for a year; it does not say anything about believing anything you hear while you are there or having to participate in any activities while in attendance. If a person wanted to check-in with the pastor and then take a nap in the back pew every week for a year, they would still satisfy the requirements of the program (although they would be missing the point of participating in it entirely). This isn’t a make it or break it issue, but if this program is ever challenged in court, it will surely be addressed.

My Freedom of Speech or Your Freedom of Speech

There was a Israeli diplomat, Michael Oren, speaking at UC Irivine about Israeli relations. During his speech, 10 Muslim men stood up and spoke; their comments were individual and included “propagating murder is not an expression of free speech”. Their interruptions were choreographed, and speeches preplanned. This event went to court. In Orange County a judge found them guilty of disruption and sentenced them to 56 hours of community service and 3 years of informal probation. The judge said that this situation did not require jail time and the probation could be reduced if executed within the year.



The issue at hand is both free exercise and freedom of speech. Was it right for the judge to convict these individuals for exercising their right to express their religious views? Was this conviction a direct infringement on a person’s right to free speech? For me, this case is more about free speech. Was what they did, rude? Absolutely. But, I do not think that it was unconstitutional. Of course, these Muslims did block Oren’s chance to speak freely. But what they did does not justify a court ruling, let alone finding them guilty. Technically, the court is judging whose free speech trumps whose.

Some have offered their opinions on the matter. An Islamic Shura Council of Southern California commented that this ruling is evidence that islamaphobia is present in Orange County. He argued that this is going to cause a “slippery slope” as a reason for justifying the suppression of freedom of speech and further phobia in the country. I agree with him. This court ruling has likely set the standard. I wonder how the court would have judged if it was an Islamic extremists speaking and Christians stood up and spoke their beliefs. I don’t know if it would have been the same ruling. It is important to keep in mind that this event is occurring post-9/11. Circumstance has much to do with this event.

One aspect of the incident that I wish that I had more information on is what exactly were these individuals saying. If they were making comments that pushed people to think that they were going to harm others or themselves in the near future, they I might argue that this ruling is justified. But, if they were making comments that simply went against the views of Oren and were strictly political, then it’s a different story.

In conclusion, I think that more information needs to be researched as to the specific comments. But, to me, it does seem like the court did actively suppress these Muslims freedom of speech.

Religious Beliefs and Driver's License Photos

In Norman, Oklahoma Kaye Beach is suing the Oklahoma Department of Public Safety for not allowing her an alternative to a high-resolution biometric photo for her driver’s license. The Department of Public Safety in Oklahoma requires all new drivers’ license photos to be taken with a high-resolution biometric camera and the photo to be stored in a database that can be accessed by international organizations. Beach, a devout Christian, strongly believes that Christians should not participate in any global numbering identification systems and sites passages from the Book of Revelation as her evidence for objecting to having the photo taken.

In March, Beach applied to renew her driver’s licenses and upon learning that biometric photographs were used she sought out the Department of Public Safety and tried to arrange for an accommodation to be made, specifically stating that the reason for her not getting the photograph taken was for religious beliefs. Beach even offered to submit a low-resolution photograph to be used instead of the high-resolution biometric photograph. The Department of Public Safety denied her request for submitting a low-resolution photo and did not offer any other alternatives to her. Beach therefore, does not have a valid driver’s license which means that she is being deprived of common benefits and services such as, being able to obtain prescription medications, rent a hotel room, or use her debit card. Beach claims that by not granting her an exception the state is in violation of the Oklahoma Religious Freedom Act, specifically claiming that having high-resolution biometric photographs does not serve a compelling state interest and therefore, her right to religious freedom is being denied.

The clause of the Oklahoma Religious Freedom Act that is being challenged is section 51-253 that states, “No governmental entity shall substantially burden a person’s free exercise of religion unless it demonstrates that application of the burden to the person is: essential to further a compelling governmental interest, and the least restrictive means of furthering that compelling governmental interest”.

I believe that Beach will win this case. By not allowing her to renew her license with anything less than a high-resolution biometric photograph, Beach’s rights are being infringed upon. She sincerely has a religious belief that restricts her from getting a biometric photograph taken and then entered into database that could be accessed internationally. The state should allow her to submit a low-resolution photo to be used for her driver’s license. While I understand the desire of the state to use a high-resolution biometric photograph for drivers’ licenses it should not be the only option. Requiring all drivers’ license photographs to be a high-resolution biometric photograph is not “the least restrictive means of furthering that compelling governmental interest”. So, due to her religious beliefs, Beach does not have a valid driver’s license and consequently, she is being deprived of everyday liberties that many of us take for granted. Therefore, the Oklahoma Department of Public Safety is substantially burdening Kaye Beach and is in violation of the Oklahoma Religious Freedom Act.

Muslim Students "Disrupting" Speech

In Santa Ana, California, Orange County Superior Court sentenced fifty-six hours of community service and three years of informal probation to ten Muslim students convicted of disrupting a speech by the Israeli ambassador, Michael Oren, at the University of California Irvine during his speech about U.S. – Israeli relations. Each man stood up, one by one, and shouted various prepared statements. One such statement included “propagating murder is not an expression of free speech.” Judge Peter J. Wilson claimed that the episode did not merit jail time, and that the probation period had potential to be reduced if the community service was completed by the end of January 2012. The ten students were guilty of two misdemeanors to conspire and then disrupt the ambassador’s speech.

Prosecutors claim that the men interfered with Oren’s right to free speech. Defenders of the students, however, point to another incident of “Islamophobia”. This phobia specifically characterizes those prejudiced, or those who experience hatred against Muslims, or an irrational fear of Islamic culture, particularly after September 11, 2011.

This incident garnered national attention over free-speech rights particularly because the trial centered on conflicting views of who was being censored. Prosecutors posited that Michael Oren’s speech was “shut down” once the students interrupted his talk. It appears that this incident goes beyond free-speech rights. It would have made more sense if the students were convicted of “disrupting the peace.” Typically crimes of this sort are defined as unsettling proper order in a public space through one’s actions by creating loud noises or using offensive words likely to incite violence. The news article gave very few specific details about what each student called out during the speech, but perhaps some of their statements fostered violent behavior. If so, the school dealt with these students correctly.

Certainly this incident calls into question the interpretation of the First Amendment, which guarantees that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech…” Both parties, the ten students and Michael Oren, obtained the right to freedom of speech. I am still unclear though as to what specific law the ten students broke. Undoubtedly it was incredibly rude of them to shout during a public speaking event, but shouldn’t they just have been asked to leave if they were disrupting the presentation? It seems a little excessive to be subject to community service as well as an extended period of probation. Furthermore, this verdict discourages political expression by demonstrating that speaking out will certainly lead to negative consequences. Other Muslim students also potentially feel ostracized and worry they will be treated differently from other students. It is important to note that similar outbursts have occurred during speeches by Israeli officials on other college campuses, yet have not prompted disciplinary actions from either the university or law enforcement officials.

Shakeel Syed, executive director of the Islamic Shura Council proclaimed, “the heart of America has died today.” Syed refers to the fact that the right to protest and the right to free speech challenge tenets of democracy. This verdict eclipsed both of these rights for all ten Muslim students.

Pulpit Politicking: An IRS No-No

The city of Memphis, TN is currently going through a municipal election, and many organizations are endorsing a slate of candidates for office that best promotes their values. This includes the Bellevue Baptist Church. This endorsement by the church, however, is apparently illegal.

On the website of the Bellevue Baptist church, there is a link to another website that endorses candidates that have “stood for strong family values.” The church’s website reads: “Please access the Family Action Council of Tennessee website (www.familyactiontn.org) and click on the Memphis City Council Elections for a list of those councilmen who have stood strong for our values on this issue and are being strongly opposed by the TEP Political Action Committee.” This church based opposition has stemmed from the Tennessee Equality Project’s (TEP) push to replace some of the anti-gay council members with more gay rights-friendly members.

Now, while the church may believe themselves to have found a loophole by not directly endorsing these candidates on their own website, the IRS has warned houses of worship about linking to campaign related sites. This would not have been a problem if they chose to link to a non-partisan site, or if they linked to the sites of all candidates running for office and encouraged their church members to do their own political research. But, because they linked to a site that specifically endorses certain candidates over others, they are in violation of the IRS’s regulations. According these regulations the church, a 501(C)(3) tax-exempt organization, is prohibited from intervening in politics while the Family Action Council of Tennessee (the group that runs the linked website), a 501(C)(4) organization, is allowed to participate in political discourse. This violation could cause the Bellevue Baptist church their tax-exempt status.

I wholeheartedly agree with the author and feel that the IRS should investigate these issues. The political intervention ban was proposed by Sen. Lyndon Johnson and passed by Congress in 1953. Over the years it has only gotten stronger. Most recently, in 1987, congress updated the language to clarify the prohibition of statements from these organizations opposing candidates. However, the law does not prohibit churches from participating in politics entirely. The IRS lays out ways that these types of organizations can promote civic engagement and political awareness, fore example linking to a non-partisan website, encouraging members to do their own political research, etc.

This regulation is a very good measure imposed by the IRS because it tries to keep church authority and governmental authority separate. However, similar to the child-benefit theory, if a church wishes to promote the overall societal good (heightened, unbiased political awareness, etc.) then the government allows for such engagement. The issue comes when a church tries to impose their political beliefs on their members. This problem seems to be an inverse of the incidence where a math teacher tried to display banners related God in his classroom. Whereas he was prohibited from using “his public position as a pulpit from which to preach his own views on the role of God,” the church, too, should be prohibited from using its religious position as a pulpit from which to preach its own views on the role of candidates in government. The separation of church and state is a two way street. If the government is not allowed to establish a religion, then the church should not be allowed to establish a government.

Jesus or Jail?

In 2006, convicted drug offender Janene Cowles was given the option of spending one year in the Ada County Jail or participating in a discipleship program at the Boise Rescue Mission. This program is a Christian one, and requires that all participants share in that common faith. Although Cowles was not a Christian, she wrote a letter to the facility explaining that she was looking to regain a sense of inner peace and to change her life “through God.” After being informed of the intense nature of the work done at the mission, and after having accepted these conditions, Cowles was admitted into the program.

While living at the mission, Cowles states that she was “expected to pray, sing hymns, lay hands on the afflicted and even take part in exorcisms to cast out demons…” She was not permitted to listen to secular music or read secular books, and she was required to attend church every Sunday. Cowles, after complaining of being uncomfortable with the Pentecostal structure of the program, and the duties that were expected of her, was removed from the program and returned to jail.

Citing the federal Fair Housing Act, Cowles and another mission resident sued the organization on the basis of religious discrimination in a place of residence. They were backed by the Intermountain Fair Housing Council.

A district court ruled in favor of the mission, and the 9^th Circuit Court has affirmed the ruling. It cites a religious exemption within the Fair Housing Act that allows religious organizations to limit access to their charitable services to those who practice the same religion. The full ruling of the 9^th Circuit Court may be found here.

In the Americans United op-ed, Rob Boston states that he would agree with the court’s ruling if the Rescue Mission were a “purely privately funded operation with no ties to the state.” Because the state offered no non-religious alternative to prison, according to the article Janene Cowles was given the option to “become a Pentecostal Christian or continue to sit in [her] cell. That simply isn’t right.”

Therefore, the question that I will focus on here is one that outlines perhaps the most salient issue at stake in this case, and which was not considered by the court. Does the offering of this religious program by the government as an alternative to prison without a secular alternative constitute an establishment of religion? Rob Boston of Americans United says yes. I agree with this position at least in part, but the issue is much more complex than it seems on the surface.

This situation is extremely important for our understanding of establishment. What exactly constitutes an establishment of religion and how should we adjudicate in different circumstances? These are the questions to which I now turn.

Janene Cowles was convicted on counts of drug offense, of which the ordinary punitive response is prison. The op-ed states that the government was attempting to establish a religion, specifically Christianity, by offering an alternative to prison whose purpose was to indoctrinate its participants in this religion. It bases its opinion primarily on the fact that no secular alternative was offered, but it overlooks the fact that prison is itself an alternative. Ms. Cowles was in no way forced to participate in the program. In fact, she was actually discouraged by the mission’s requirement that all participants must be Christian. Still, she wrote a letter explaining her desire to change her life “through God,” and therefore made a personal choice, no coercion involved.

The argument could be made, however, that the state is funneling individuals into this program because the mission is far more attractive that “sitting in your cell for a year,” and this may indeed be true. Any religious and secular options offered by the government should be equally intense punitively and no added benefits should be provided for choosing a religious option.

I feel that this issue hinges on the question of whether secular drug rehabilitation programs were offered within the prison setting that would allow individuals an equal alternative to the religious option. If this program was merely a religious mission that sought to heal drug offenders through God, and no secular equivalent was offered as an alternative, then I strongly believe that this would constitute an establishment of religion. However, I do not feel that this religious alternative in itself constitutes establishment. The nature of the alternatives is key in considering issues such as these.

Does the option to participate in this Christian-based mission constitute an establishment of religion by the government even if secular alternatives are offered? Is the government attempting to “funnel” individuals into Christianity through this program? What do you think?

Obama and Perry, Speaking “Christianese” during 2012 Presidential Rallies

As the 2012 presidential elections draw near, the pressure is on for the possible candidates. Rallies and tours are in full swing and speeches are being written to appeal to the audiences at hand, even the Christians and Evangelicals. As shown in previous elections, the Evangelical Christian vote is an important crowd to win over, since their approval of a candidate can have a great effect on the votes.

Most recently, Texas governor, Rick Perry, visited Liberty University in Lynchburg, VA, the largest Christian University in the world. Liberty was founded by the late Jerry Falwell, a well known evangelical pastor. With a large group of Liberty student as the audience, Perry spoke openly about his Christian faith and the importance of their vote as Christian teenagers and young adults. He also encouraged the students to become involved in the voting process, since the election not only affected their future but the future of the United States. There, Perry also discussed his decision to become a Christian, during his 20's, and openly explained how he “turned to God” after leaving the Air Force. During his closing remarks, Perry reminded the student that God, “doesn’t require perfect people to execute his perfect plan” which can be found numerous times throughout the Bible.

Another candidate using their Christian faith to win over crowds is current President, Barack Obama. Keeping in mind his aspiration of becoming re-elected, Obama most recently quoted both Psalm 46 and Psalm 30 at “secular” 9/11 memorials in NYC and DC.

In 2007, Obama announced his candidacy for the 2008 presidential race after being welcomed by a Gospel choir. Then, once elected, Obama mentioned “unbelievers” in his inaugural address. During his presidency, Obama was quoted saying, “We are one nation under God, we always have been and always will be” during a televised speech. The president of the United States told the American citizens, on live television, that they were one nation under God.

While these presidential rallies are taking place, where candidates are expressing their religious views, public school teachers are being fired for posting religious banners in their classroom. Does this seem “Constitutional” to you? Just this past week, a public school teacher was forced to take down “religious” posters in his classroom because it could make the students in the classroom feel uncomfortable. But when the President speaks of his religious beliefs on live television he doesn’t make anyone feel uncomfortable?

Why is it that the President of the United States can broadcast a live speech to the American public stating this nation is, “Under God” and a public school teacher cannot wear a cross in the classroom? Better yet, why can a presidential candidate speak to college students about their decision to follow Christ during their 20’s and public school science teachers cannot state that God was possibly the creator of the world?

It is extremely unfair that the President can openly express their religious views in the workplace but a public school teacher cannot. If the government is going to ban religious activity in the public schools, the government officials also need to follow these rules in their workplace.