In the case of Tatel v. Mt. Lebanon School District, a set of parents are plaintiffs against the education they are receiving from a first-grade teacher, Megan Williams. The parents claim that Williams, with permission of the public school district, pursued an agenda outside of the curriculum showing the first-grade students videos, books, and transgender topics, without parental permission. As the parents were aware of the situation, they filed complaints against the school district where the school district backed Williams by the "de facto" policy where Williams did not need parental permission, and the parents were not able to opt their children out of transgender discussions. Williams has a transgender child who during the 2021-2022 school district, was in the first grade. Williams has strong views as a teacher as she claims she will teach the children what they need to learn, did not let her class recite the Pledge of Allegiance for 52 days, and denied a parent's request from exempting her child from watching a certain cartoon. The parents were not pleased with Williams' teaching methods, so they seek justice on five counts of constitutional justice on the First and Fourteenth Amendment against Williams and the School Board, as well as one count from Pennsylvania Code against the District. The questions of law that I will be focusing on this blog post is: is Williams violating Fourteenth Amendment rights of the parents by infringing on the right to familial privacy? Is Williams violating the free exercise of religion rights of the parents by not following school curriculum and teaching first-graders about transgender topics as well as denying exemption from these topics?
The first factor in the case that needs to be considered is if Williams is violating the right to familial privacy with her teaching methods. In one instance, a set of parents were displeased with Williams as she told a boy that she had private discussions with a boy about the similarities between he and her transgender child, and that the boy could dress with a dress and hair like his mother. The defiance of parents was also seen as Williams denied a mother's ask to exempt her child from a cartoon due to it not being age appropriate. Williams teaches at a public school, where the parents' tax dollars are paying her salary, so it seems very unreasonable that she has the right to deny these wishes. Since Williams has broken school curriculum and is having private conversations with first-grade students about their sexual-orientation, it is natural to ask when can parents step in for the sake of their child?
The next aspect that I will consider is whether or not Williams actions as a teacher violate the parents rights of free exercise of religion. In order to adequately answer this question, one must observe the case of Lasche v. New Jersey. In this case, the Lasche's are foster parents. The Lasche's oppose same-sex marriage, and had their foster child removed and suspended their foster license removed due to their Christian views against same-sex marriage. The court eventually allowed to Lasche's to continue their case to the lower court. The opinion provided included the quotes, "...the Lasche's allege two forms of of constitutionally protected activity - one involving religious belief, and the other, action inspired by religious belief." The opinion given in this case shows similarities to the Tatel v. Mt. Lebanon School District case. The phrase of the ruling "action inspired by religious belief" shows how the parents should have the right to protect their children from learning about transgender topics at six years old by being allowed to opt out of this part of the instruction that Williams provides. This case, along with Wisconsin v. Yoder, show the parental right to instill the religious views into their own children and not from a public school district.
I understand that Williams is allowed to have her own views on transgender topics, and that she also is protected under the free exercise clause to practice these as she pleases. However, she has assumed the right of a government worker through tax-payer dollars by having the profession of an educator. The court ruled against her and the School Board for denying the free exercise right of the parents to opt their first grade children form transgender topics in a public classroom, and I could not agree with the decision more. I see similarities to Stone v. Graham, where the Ten Commandments had to be removed from classrooms in Kentucky. Although this case was an establishment issue, the precedent that children have impressionable minds remains the same. Williams is entitled to have the views she wants about transgender issues, but she can not teach first grade kids these views in public school hours. without giving way for allowing parents to opt out of these lessons.
Bibliography
CARMILLA TATEL, STACY DUNN and GRETCHEN MELTON, individually and as parents and natural guardians of their children, Plaintiffs, v. MT. LEBANON SCHOOL DISTRICT, THE MT. LEBANON SCHOOL BOARD, MEGAN WILLIAMS, DR. TIMOTHY STEINHAUER, DR. MARYBETH D. IRVIN, BRETT BIELEWICZ, JACOB W. WYLAND, VALERIE M. FLEISHER, TODD W. ELLWEIN, ANDREW D. FREEMAN, ERIN C. GENTZEL, CLAIRE B. GUTH, DR. JUSTIN D. HACKETT, ANAMARIA A. JOHNSON, and SARAH L. OLBRICH, (IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA October 27, 2022).
Stone v. Graham, 449 U.S. 39 (1980). Justia Law. (n.d.). Retrieved October 31, 2022, from https://supreme.justia.com/cases/federal/us/449/39/
Yoder, K. (2022, October 27). Foster parents can share religious views with children, Appeals Court rules. Catholic News Agency. Retrieved October 31, 2022, from https://www.catholicnewsagency.com/news/250597/appeals-court-foster-parents-can-share-religious-views-with-children
4 comments:
Really interesting case! You did a great job of incorporating the relevant cases and class material! I agree with your opinion in this case. I think the strongest evidence here is the impressionable nature of the students that Williams is relaying these teaching onto. It also seems as though the teachings or William's method in particular is quite coercive, as Williams individually pulled a student aside and encouraged them to pursue these lessons in their own life by changing their clothes, hair, etc. without discussing this with the student's parents. Furthermore, since the parents are in legal control of their children at this age and are paying for this education through tax payer funds, I think the parent's right to free exercise and familial privacy was violated when Williams denied exemptions from these teachings. In this case, they are no asking Williams to stop teaching these topics, but allow exemptions for those who religious beliefs are inconsistent with these teachings.
Great job covering this case! I agree with you here. I think it is important to allow every student to express themselves however they'd like, and I think that the teacher should create a safe space for them to do so. However, I do not think the teacher needs to be initiating conversation about six year old's gender expression. It has been made clear that she is allowed to teach about gender expression, so I think that if parents are uncomfortable with this, there should be an option to opt out. I liked the point you made about tax dollars going to the school. If a teacher is teaching a topic that may be controversial there should be an opt out option given that it is a public school.
I agree with your analysis of this case. The teacher in this class allowed her personal beliefs into the classroom. The other issue is that are these parents objecting the viewpoint due to religious beliefs or political,moral, and social reasons? If the beliefs are firmly held due to their religious background then a public school cannot force students to be subjected to material the violates their freedom of expression. This was set precedent in West Virginia State Board of Education v. Barnette when students were allowed to not salute the flag if it violated religious beliefs. That being said the teacher should not engage in unprompted questions regarding students sexuality and gender expression especially at such a young age. In addition to that and this being a public school there is a certain standard of education and lack of bias that should be removed.
This was a great post. I fully agree with you. I think your use of Stone vs. Graham was also a great comparison. Although teachers are allowed to have an opinion on issues such as this and may even be allowed to share those views directly adding them to the curriculum is not right. You also have to look at the private vs public school argument. This is a public school and therefor the things they are allowed to say or share in the classroom are much more censored then a private school.
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