When Caleigh Wood was a junior in high school, she took a world history course which was required for graduation. In the class, one of the lesson topics was “The Muslim World” and Islam. During the lesson which spanned over the course of approximately a week, Wood was exposed to a PowerPoint slide which included the statement “Most Muslim’s faith is stronger than the average Christian”. The slide was being used to contrast peaceful Islam with radical fundamental Islam. In addition to the PowerPoint presentation, one of the assignments that Wood was required to complete included a fill-in-the-blank section about the shahada which is an Islamic declaration of faith. The statement read “There is no god but Allah and Muhammad is the messenger of Allah”. After seeing the assignment, Wood’s father encouraged her not to complete any other work that was contrary to the family’s Christian beliefs. As a result, Wood received a lower grade, but it did not severely affect her final grade in the course.
This case has implications for the Establishment Clause of the First Amendment, the Free Exercise Clause of the First Amendment, and the Compelled Speech Doctrine of the First Amendment. For the interest of time and based on this week’s case readings, I will be focusing on the Establishment Clause perspective of this case. The issue is whether the lessons and assignments given to Wood can be considered as an establishment of religion and therefore unconstitutional. In the end, the judges decided in favor of the school district, ruling that there was no establishment of religion that violated the First Amendment.
Wood’s parents took the issue to court and argued that the materials clearly lacked a secular purpose and were promoting and endorsing Islam. Wood and others argued that it not only promoted Islam but degraded Christianity and forced Wood to write things that she did not believe. The school district argued that religious education is necessary because it is history and cannot be separated or ignored. Rather, the way to teach about religion is from a secular perspective. However, in the decision, the court did include that the school’s content specialist had deemed the slide in question as inappropriate and would have advised the teacher to either change it or not include it in the lesson.
Charles C. Haynes, a founding director of the Religious Freedom Center cited the constant fears of terrorism since 9/11 and the continually growing fear of Islam as greatly influencing how Islam is treated in public schools and education as a whole. Haynes argued that even with poor phrasing, a single presentation or assignment may not be unconstitutional unless there is a clear pattern. Similar to many other educational related court cases, courts tend to steer away from making judgements on every single issue, and instead defer to educators to make calls on what and what is not appropriate. The judges in this case agreed with putting school authorities in charge of the classrooms rather than the courts. The judges believed that if they were to examine each and every statement made by teachers, academic freedom and exploration would be in jeopardy.
In this case, I believe that that court made the correct decision in favoring the school district. Education and specifically public schools represent such a combative and stressful environment for such laws, so there are many facts to consider in deciding this case. The school district focused on the course’s entire curriculum instead of simply the presentation and assignments for the study of Islam. I agree with their decision because focusing on such an individual statement would create a slippery slope scenario and set a dangerous precedent. If this simple assignment and/or slide presentation were to be deemed as establishments of religion, it would open up the court to unlimited issues surrounding most likely any study of religion at public schools. Additionally, Wood was not compelled to state any beliefs or statements against her will as the assignment had the purpose of testing the students’ understandings of the lessons.
In the case Illinois ex. rel. McCollum v. Board of Education, the Supreme Court found that the use of public-school property for religious classes violated the Establishment Clause of the First Amendment. In the case, the school was allowing an outside program to bring in religious teachers to teach during the regular school day. That is not the case here. Here, the lesson was part of a public-school curriculum, specifically a world history course, and it did not take away from the regular school hours as it was built into the schedule. In this case, no aid, direct or indirect, is provided to the schools by the government, maintaining a separation of church and state.
A strong counter argument can be made that the statements not only promoted Islam, but degraded Christianity, a fact which might have had Justice Douglas from Zorach v. Clauson, a case which dealt with New York City public schools allowing children to leave during school hours to attend religious institutions, to argue that this event did classify as an establishment of religion. However, I believe that the court was right to examine this occurrence as a part of the course curriculum and see if there appeared to be an establishment of religion in the course as a whole. However, in Engel v. Vitale, the Supreme Court ruled that the reading aloud of prayers in public school violated the Establishment Clause and Justice Black referenced the First Amendment as the ultimate safe guard to ensure that the government could “control, support, or influence” the prayers of the American people (Munoz 106). In this case, Wood had no governmental pressure to say anything against her religion. Despite the specific statements which were deemed inappropriate for the lesson, the lack of a pattern of pro-Islam and/or anti-Christianity ideals, the lack of governmental aid or support of the course, and the status of the course as a public school world history class denote this case as not a violation of the Establishment Clause of the First Amendment.
11 comments:
I agree with Ariel’s take on this case and think she really hit the nail on the head with all the main points. I also think the founders, although large supporters of Christianity, believed religion is such an integral part of society and so, they would also likely agree with this decision based on the importance of educating students on the many world religions to gain a better understanding of society overall. Another part of the case I think is interesting is that the family argues the school is “disfavoring” Christianity. It makes me wonder if their feelings on Christianity being taught in school would be different and if they would view that as disfavoring other religions. I am going to say most likely not.
I agree that the school curriculum about Islam or other religions is not establishing a religion in public schools. The information given about Islam, in this case, has a secular purpose and is presented in an effort to educate, not proselytize. The class curriculum does not require students to participate in religious practice or express religious belief. Rather, the religious information is given to students in a neutral way which only serves the purpose of educating the student on the religion, not forcing that religion upon the student. The assignment referring to the Islamic religious doctrine is not unconstitutionally forcing students to profess a belief because it is stating the religious belief in the context of a fact about Islam (ex. "Part of the Islamic creed states, 'Allah...").
I agree with the courts decision in this case. The education on a widely held religious belief is important to any course on world history. I suspect a similar course on classics that taught the beliefs of pagan religions of Greece and Rome would not be so scrutinized by he student or her parents. However I do agree that such a statement of opinion as “Most Muslim’s faith is stronger than the average Christian” need not be included in a secular education on the religion and it's history. In the eyes of the court however, it is clear cut that this lesson was not an attempt at an establishment of religion.
I agree with Ariel’s analysis. In many of the recent cases that we have studied about Establishment Clause, such as Engel v. Vitale, the issue has come down to the coercive nature of prayer or religious instruction in public schools. Wood received a lower grade for not completing the assignment, but that does not amount to the institutional or social pressure that the Supreme Court was concerned about in Engel v. Vitale. Additionally, the Islamic prayer Wood was assigned to complete for class did not ask her to affirm or support the statement, but complete it for an educational purpose.
I concur that the court made the right decision in this case. It seems that this issue had not yet reached the threshold of legal action and that rather, the family should have brought their complaint to the teacher or school district first. The statement in question certainly degrades Christianity and for that it is problematic. However, the presence of a content specialist in the school who determines if certain educational materials are appropriate, seems to solve the problem adequately.
I believe that the court made the correct decision in this case. The school itself is not a religious institution. The school was not designed for the purpose of promoting the ideals of any particular religion. Even if a teacher or class did this, then neither that class, nor the teacher are wholly representative of the institution. The slide with the questionable statement on it I believe was taken out of context, but nonetheless understand the parents concern for its content.
I agree with the Court's decision. Although the class was mandatory for the student's graduation, the class is not religious in nature but historical. If the class is mandatory, the school authority must believe it is essential content for their students to learn. The course is not encouraging or preaching religion but rather educating the students on the historical significance of Islam. I do not believe that the class or slideshow is unconstitutional, and if it was deemed so, I believe that would result in a slippery slope and dangerous precedent. Despite the fact that the school specialist did believe that the slide was questionable, I am personally not compelled that the statement is unconstitutional.
I agree with the decision that the court made. This class is about teaching history and Islam and the Islamic world has a lot to do with ancient world history. I would also argue that the parents' complaint is more rooted in the disfavoring of Christianity rather than the promotion of Islam. Free exercise is designed to protect all people from an establishment of any one religion but the information presented doesn't strike me as establishment. It sounds like these Islamic teachings and explaining how Muslims feel about Allah is just one unit in a curriculum designed to teach beliefs, customs, history, and culture from all around the world, which I'm sure includes Christianity as well as Islam. I think the case can be made that the one slide comparing beliefs was in bad taste but it hardly constitutes an establishment of religion.
I agree with Ariel's analysis and the court's decision. The purpose of teaching about Islam is a secular purpose. History can't be taught without religion and learning about Islam does not take away from one's own beliefs. This was one small unit that only spanned a week,and the purpose was not to promote Islam but to educate about Islam
I also agree with the decision of the court and Ariel that the public school was in no way establishing a religion, rather incorporating an educational lesson about a religion that not everyone in the school may practice. However, if I were to consider the free exercise aspect of this case, I might have a different opinion. The girl who refused to participate in the class lesson or fill-in-the-blank worksheet was doing so because she felt it went against her religious beliefs, which she has the freedom to act upon. Receiving a lower grade because she was defending her religious beliefs is definitely a different situation than the school establishing any type of religion. But in terms of establishment, the week long lesson on Islam in a world history class was only temporary and within the means of the school to teach. The lesson was no included to promote one religion over the other, rather teach the class about the history of Islam and its importance in the world and its history.
After reading Ariel’s analysis with the facts and opinions she exhibited, I firmly agreed with her Opinion aligning with the courts opinion that the court made the correct decision in favoring the school district in this case. I do not believe that the school was trying to endorse Islam in this case, and that is evident in the fact that this was not the only religion that was taught to the students in the class. If you do look at the Muslim faith, it is apparent that it is more active and involved than Christianity, so on that basis alone I do believe that the statement that was made by the school was not in an effort to establish any sort of religion upon the students.
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