The After School Satan Club was denied establishment in Northern Elementary School, a school in York County Pennsylvania. The idea was proposed by a mother at the school, Samantha Groome, who wanted an alternative for her children to the Joy El Christian Club. This club meets during school days, off campus and is for third to eighth graders. The club trains the students in Bible memory work and scripturally based character instruction. The Joy El Christian Club takes place during the school day and students are dismissed and bussed there. Groome did not want her children to have to miss out on extracurricular activities during the school day, but there were no secular options. The school board voted on the establishment of the organization and all but one member voted no. School officials also told the club discretely that if they remove the word “satan” from the club name they would have a better chance of being established. Despite the perception of the club, the Temple says their goal is not to convert students to Satanism. Their goal is to teach students about “the natural wonders surrounding them, not a fear of everlasting other-worldly horrors” (New York Post). Following the denial of their establishment, the Satanic Temple is suing. They are suing on the grounds that Northern Elementary School violated their constitutional rights by not allowing them to establish themselves despite the existence of other clubs at the school.
This case brings up multiple constitutional issues involving religious rights. There is both the issue of an establishment of religion, as well as the issue of free exercise of religion. First, although it is not the purpose of the lawsuit that has been filed, there seems to be an issue of an establishment of religion. In McCollum v. Board of Education, the question of released time was addressed when there was only one option and some students felt ostracized for not attending. Groome says that the reason she wanted to establish the club is because her children did not have a secular option for when the students left school to go to a religious club. The reason that one would likely argue that it is constitutional, despite the feeling of ostracization for not attending, is that the club took place off public school grounds. In Zorach v. Clauson, the court decided that if the release time took place off school grounds then there was no constitutional violation in place. There is then the question of whether the denial of the After School Satan Club is a violation of the Free Exercise Clause. The first case to look at to answer this is Good News Club v. Milford Central School. In this case, the court decided that a club could not be denied access based on the viewpoints of the club. They decided that all groups should have equal access to a limited open forum regardless of their religious viewpoints. The counter argument that someone may make to this is that the Satanic Temple is not a legitimate religious organization and therefore they should not be given the same rights. Even if someone does not believe in the validity of the Satanic Temple, in United States v. Ballard, the court decided that it was not up to the courts to decide whether a religion was true or false, only the sincerity of the religious practice.
Sources:
https://www.usatoday.com/story/news/education/2022/04/20/after-school-satan-club-denied/7382508001/
https://nypost.com/2022/04/23/pennsylvania-northern-elementary-school-rejects-after-school-satan-club/
https://globalnews.ca/news/8784117/satanic-temple-sues-school-after-club-rejected/
5 comments:
I agree in your assessment that this brings up the question of not only the establishment of religion, but also the question of free exercise. I see both sides as this clubs just wants to be established, but the school is also worried about the fact that if they allow this it could look like an establishment of religion. I do think it is difficult because they have allowed another religious club to meet and to deny this club permission could look like a violation of free exercise. Another compelling point was some teachers or faculty
telling them to take the name satan out of their club name so they might have a better chance. I see why they would say this, but this ended up giving more ammunition to the club to claim that their right to free exercise was being infringed upon.
I disagree, while the club isn't made to convert anyone to satanism, it does have the expressed goal of dissolving the religion of students. this club is repugnant and including the name of satan itself shows that the club does not have any secular purpose. While the club may be teaching about "natural wonders" then why is the inclusion of satan necessary? It isn't, the club is a farce and is only trying to be provocative and disrupt society. Further, the club and religion of satanism isn't a legitimate religion nor should it be recognized because they do not believe in a diety or higher power of any kind. the sole purpose is to be provocateurs.
This is a fascinating case because the After School Satan Club is seemingly asking to be treated the same as the Joy El Christian Club. They are not acking for special treatment, rather they are asking for fair and equal treatment. I agree with your analysis of this case. The facts make it clear that the Joy El Chistian Club was established as a club, but the After School Satan Club was denied because it has the name satan in its club name. This is discrimination based on religious viewpoint, which is impermissible. As you state, the United States vs. Ballard case determined that the court is not allowed to decide the validity of a religious belief. In addition, there is risk of coercion when the school only permits the Joy El Christian Club and denies other alternative viewpoints. While I do not intend to support satanism, I believe the request by the Satan Club is permissible under the First Amendment of the Constitution.
In this case, I agree in the fact that both clubs should be given equal treatment. I also want to note that there are children involved in the case, and most times, they are not the ones choosing to partake in the club, it's the parent's choice. With this being said, it is a fair argument that students may be coerced into joining a club, and therefore obtain certain viewpoints. From a Constitutional standpoint in which all clubs should be treated equally, I can see how the school may be discriminatory towards the After School Satan Club from a religious standpoint.
I agree that the After School Satan Club should be allowed under the circumstances. In your analysis, it did not seem as though the school had any guidelines on granting after school clubs. Therefore, it must treat them all equally and grant permission on similar grounds. Since the Joy El Christian Club is allowed to meet without any hesitation, the Satan Club should as well. So long as this club does not teach violent or illegal actions, I believe that the school, a public entity, cannot discriminate based upon the viewpoint of the organization. Further, the government does not have the right to deem a religious belief as a "farce" without substantial evidence. If there is no compelling state interest to deny this club, which I do not believe there is, then the school should be required to treat it as equal to the other clubs. Additionally, I find that the school will better uphold the Establishment Clause if it maintains this diversity in terms of club permission.
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