Rastafarian Man Demands Reprucussions for a Violation of His Nazarite Vow

    On December 28, 2020, Damon Landor was transferred to the Raymond Laborde Correctional Center (RLCC) to serve the last three weeks of his five-month sentence. Landor was a practicing Rastafarian and had taken the Nazarite vow, which, among other things, prohibited him from cutting his hair; a ritual he upheld for over two decades. Because of his beliefs, Landor had been permitted to keep his long dreadlocks at the other two correctional facilities he had been held in prior to the RLCC. However, upon his arrival at the RLCC, Landor, preemptively providing documents that should have permitted him to keep his dreadlocks as they had at the other two facilities, was shackled and his head shaved. The prison officials ignored his arguments that their actions were a violation of his First Amendment right to Free Exercise of Religion, even claiming judicial precedence, and proceeded to forcibly shave his head. 

    Upon his release, Landor immediately filed a lawsuit against the Louisiana Department of Corrections and Public Safety, its Secretary James LeBlanc, the correctional center, and Warden Marcus Myers on grounds that his rights granted by the Religious Land Use and Institutionalized Persons Act (RLUIPA) had been violated. Additionally, Landor claimed that there was judicial precedence from a case brought before the Fifth Circuit Court in 2017. The case in question, Ware v. Louisiana Department of Corrections, was a case almost identical to Landor’s. In this case, Christopher Ware, just like Landor, was a Rastafarian who had taken the Nazarite vow and had dreadlocks at the time of his incarceration. Unlike Landor, however, Ware was permitted to keep his dreadlocks because the Louisiana DOC “failed to satisfy its burden to show the policies are the least restrictive means of serving a compelling interest.” Therefore, Ware was permitted to uphold his vow throughout his incarceration. Given the result of this case, Landor argued before the cutting of his hair that he should be able to practice his beliefs and that the RLUIPA protected his practices. As it has been mentioned, the prison officials disregarded these arguments and presentations of evidence and proceeded to cut his hair. In doing so, Landor has claimed his liberties were breached and is in fact pursuing a recovery of monetary damages. However, when Landor’s case reached the Fifth Circuit Court, as did Ware’s, the court overruled his plea and stated that the RLUIPA did allow for monetary damages to be recovered from the prison officials who had violated his rights. 

    While, admittedly, the primary question before the Court is whether the RLUIPA allows monetary damages to be recovered from individual officials, it is important to note that what we are discussing is whether Landor’s religious liberties were violated by the prison officials. While Landor believes that they have been, an argument could be made that the prison officials were in fact attempting ensure the greater peace and good order of the facility. I believe that it is safe to say that the prison officials believed that they were adhering to Department of Corrections grooming guidelines and, therefore, that they were recognizing and enforcing a compelling state interest in the matter. While the Ware case had in some ways rewritten grooming policies (which should have protected Landor), there was still a loose guideline that required inmates to have short hair (no dreadlocks) and typically required a buzz cut upon entry into federal correctional facilities. It is argued and understood that these policies were established to preserve the greater peace and good order of the facility, and if put up to the Sherbert Test would regularly be recognized as the compelling state interest in most matters involving the free exercise of religion.  In this situation, it is clear to see that the officials deemed Landor’s actions to be a threat to this peace and good order; it just becomes a question of whether or not they were applying restrictions in the least restrictive manner as instituted by the Sherbert Test.

    While this case, unlike many regarding free exercise of religion, has a semi-clear answer when it comes to the question of whether religious rights were violated, it is still valuable to realize the complexity of compelling state interests and claims of religious rights violations. While the true question before the Court is concerning whether the Fifth Circuit Court of Appeals was correct in its ruling that the RLUIPA does not allow for monetary damages to be recovered from these prison officials, that to me is not the primary question we need to be discussing. I believe that even though it is highly likely that the Supreme Court will rule that Landor’s appeal is unconstitutional, it disregards the fact that Landor’s rights to uphold the Rastafarian Nazarite vow were violated in this sense. If the question before the Court was whether or not the officials violated Landor’s religious liberties, I think the outcome would be very different. 

https://www.oyez.org/cases/2025/23-1197

https://www.washingtonpost.com/politics/2025/06/23/supreme-court-louisiana-prison-guards-rastafarian-dreadlocks/

 

 

Public Funds and Private Faith: Oklahoma Funding For A Jewish Charter School

   On February 9th, the Oklahoma Statewide Charter School Board (SCSB) unanimously rejected a proposal by the Ben Gamla Jewish Charter School Foundation to open a virtual Jewish charter school within the state of Oklahoma. The school was projected to open in the fall of 2026, with 500 students and state funding of $2.6 million, estimated to grow to 1,500 students and funding of $8.3 million by 2030. Oklahoma is home to roughly 9,000 Jews, which is less than 1% of the state population. This small statewide presence has fueled skepticism among some Jewish leaders, who have questioned the need for the charter in the first place. 

    The application has been advanced by Peter Deutsch, a former congressman from Florida, who opened the first Ben Gamla charter school in Florida in 2007. The school operates as "Hebrew language and Jewish culture-themed", allowing students to be released during the school day for religious education. There are currently six active Ben Gamla charter schools in South Florida. Deutsch supported the Oklahoma application by noting that "The schools have consistently performed and been rated at the top 5 or 10% of public schools, not just charter schools, in the state of Florida", claiming that "The opportunity is probably the best in Oklahoma of any state". 

    The OSCSB's rejection derives from the legal precedent established by the Oklahoma Supreme Court in 2024, which held that religious charter schools are unlawful under the state's Constitution. The ruling arose when the Statewide Virtual Charter School Board approved a proposed virtual charter school by the Roman Catholic Archdiocese of Oklahoma City and Diocese of Tulsa. Oklahoma Attorney General Gentner Drummon sued the SVCSB, declaring the proposal to be in violation of state laws preventing establishment of religion. The Oklahoma Supreme Court then sided with Drummond, causing the SCSB to appeal to the U.S. Supreme Court. The board argued that the state's rejection of religious, publicly funded charter schools, solely because of their religious status, is exclusionary in nature. On May 22, 2025, the U.S. The Supreme Court issued a 4-4 split decision with one justice recusing, leading to an equally divided court. With this, the Supreme Court of Oklahoma's decision was affirmed by the split decision, and the proposal of the virtual Catholic school was rejected. 

A week before the unanimous decision, Americans United, the ACLU, the Education Law Center, and the Freedom From Religion Foundation authored a note that urged the SCSB to reject the Ben Gamla application. The letter circulates around the idea that while explicit religious education would occur off-campus during administered breaks, the school would still operate with religious purpose. This is inconsistent with the legal definition of a public charter school, which must be secular and open to all students, regardless of religion. The school would also create religious discrimination in admissions and hiring, which is contrary to law that requires public charter schools to be open to all students and staff. The letter additionally referenced the Oklahoma Statewide Charter School Board v. Drummond case to support their argument. With this, the Constitution’s Establishment Clause is clearly violated as the state endorses religious education and discriminates against the public. 

SCSB Chairman Brian Shellem spoke on the matter following the board’s decision, saying that he welcomes further action from the Legislature and Ben Gamla. He also notably added that he hopes the matter makes its way back to the Supreme Court following the lack of consensus that Drummond provided. 

The situation between the SCSB and Ben Gamla poses questions and implications regarding the Establishment and Free Exercise Clauses of the First Amendment. While the proposal was rejected, the operation of Ben Gamla schools in South Florida, as well as the split decision in Drummond clearly display that there are unresolved issues. This poses the question: Can a state operate a religious, public charter school without violating the Establishment Clause? If it refuses, is that a violation of the Free Exercise Clause?

This situation obviously directly relates to Drummond, but also to cases such as Espinoza v. Montana Department of Revenue. In Espinoza, the state of Montana created a tax-credit scholarship program that aided families in paying for private school tuition. The court struck the program down because the funds were being used at religious schools, leading parents to sue. This brought the issue to the Supreme Court, with the ruling being 5-4 in favor of the parents. The majority argued that once the state had created the public aid program, they could not exclude religious schools as doing so would be in violation of the Free Exercise Clause.

In my opinion, the proposal of the publicly-funded Ben Gamla Jewish Charter School should remain rejected, as accepting the proposal would be in violation of the Establishment clause. A substantial aspect of this case is weighing the Free Exercise and Establishment Clauses to determine which one is being violated. Espinoza is different because the public aid program provides neutral funds that can be used in whatever way the recipients choose to. The state of Montana does not endorse or establish religion by providing aid that can be used for the education of children in religious or secular schools. This situation is different because the school is directly funded by taxpayers. Students are given a designated period to leave campus to engage in explicit religious education, which is Constitutional as established in Zorach v. Clauson. Despite this, the school operates with religious purpose and instruction that while not explicitly taught on-campus, creates an environment of coercion for students that endorses the Jewish faith. Acceptance of the proposal would create long-term implications, as the creation of a publicly-funded Jewish school would mean that the state must accept proposals of all denominations. This would lead to public education being denominational, which clearly violates the Establishment Clause. Overall, the SCSB’s rejection of the Ben Gamla school upholds the Establishment Clause by refusing to endorse the Jewish faith through public funds, which is not exclusive.

Investigating Faith: First Choice Women's Resource Centers v. Platkin

The ongoing Supreme Court case First Choice Women’s Resource Centers v. Platkin presents crucial questions about religious protections and the state government’s right to investigate faith-based organizations. 

First Choice Women’s Resource Centers, shorthandedly known as First Choice, is a New Jersey-based nonprofit organization that began in 1985. First Choice provides pregnancy-related services to women in need, including but not limited to counseling, ultrasounds, and material items like diapers and baby clothes. The organization openly identifies as pro-life and faith-based, with its employees taking a vow of faith alongside close collaboration with ministry partners at churches.

In November 2023, New Jersey Attorney General Matthew Platkin issued a “sweeping subpoena” to First Choice. Essentially, a sweeping subpoena is an extensive legal demand for documents and data to investigate what the state government deems a “large-scale” issue. The compelling state interest of New Jersey’s Division of Consumer Affairs was in investigating concerns that First Choice’s public websites may have omitted important information to mislead clients and donors about its services, staff qualifications, and medical credibility. In particular, the state was interested in investigating First Choice’s claims regarding abortion pill reversal (APR) and questions of whether unlicensed individuals were providing services that required credentials. 

The subpoena ordered by Platkin required First Choice to present ten-year’s worth of documents, including internal, private communications, advertising materials, donor information, and communications with partner ministries and organizations. However, First Choice firmly objected to the subpoena, especially to the release of donor information, claiming that it violated their First Amendment right to Free Exercise of their religious practices. 

The litigation in this case soon became complicated. In state court, a judge ruled to end the subpoena, instead encouraging both sides to renegotiate the scope of the Division of Community Affairs’s investigation. Simultaneously, First Choice filed a federal lawsuit to prevent enforcement of the subpoena on the grounds that it violated their constitutional rights. However, both the federal district court and the Third Court of Appeals dismissed the case, labeling it as “unripe”. This label means that the Court did not see a need for legal intervention, as there was not yet a renegotiated demand for compliance. Yet, the Supreme Court agreed to First Choice’s request to hear their case on June 16, 2025, and it was argued on December 2 of the same year.

The Platkin case raises a core constitutional issue: 

Does the New Jersey Attorney General’s subpoena to First Choice, a nonprofit, faith-based pregnancy center, violate the organization’s First Amendment right of Free Exercise by forcing them into Court over their religious beliefs?

In past cases, the Supreme Court has historically recognized that religious institutions’s internal decision-making must be constitutionally protected. For example, in Hosanna-Tabor Evangelical Lutheran Church v. EEOC (2012), the Court ruled that the government cannot interfere with a religious organization’s minister selection, as doing so infiltrates their Free Exercise rights. Similarly, in Our Lady of Guadalupe School v. Morrissey-Berru (2020), the Court ruled that civil authorities are not able to question judgments that are important to a religious organization’s identity. Essentially, both of these cases established a precedent that the First Amendment’s Free Exercise Clause protects religious organizations’ autonomy over their mission activities, without state interference.

This case is important because it conveys how Free Exercise debates are centered around real, human lives, beyond the traditional settings frequently discussed by the Court, such as schools, churches, or workplaces. First Choice was created to assist women in vulnerable, often isolating situations as a faith-based organization seeking to do good in the public sphere. If Free Exercise protections are not made generally available, then organizations like First Choice may find their core missions subject to state control and monitoring. How the Court rules in Platkin will determine whether these protections extend to lived religious services. 

In my opinion, this case is more complex than merely deciding whether First Choice should be exempt from state investigations. The state of New Jersey does have a legitimate compelling interest in protecting consumers from misleading information and questionable medical credibility, concerns that should not be ignored because an organization is faith-based. However, simultaneously, the broad scope of Platkin’s subpoena raises constitutional concerns. Requesting several years’ worth of communications and private donor data risks extending beyond neutral oversight and into the internal functioning of the organization. The Free Exercise Clause should not allow faith-based organizations to be exempt from safety regulations, but it also cannot be so restricted that it allows the government to inappropriately investigate how those organizations define and carry out their missions. 

Given this layered perspective, as well as the precedents set in both EEOC and Morrissey-Berru, I think that the Supreme Court is likely to rule in favor of First Choice. The Court has recently shown a willingness to protect religious organizations from government overstepping into internal religious processes. However, while I do think the Court will find Platkin’s subpoena a government intrusion, I do not think that they will disregard the state’s right to investigate specific, reasonably-questionable concerns within religious organizations. A ruling of this sort would uphold First Choice’s First Amendment Free Exercise protections while resisting an absolute exemption from the compelling interest of consumer protections. 

Sources:

https://becketfund.org/case/first-choice-womens-resource-centers-v-platkin/

https://www.oyez.org/cases/2025/24-781

https://www.scotusblog.com/cases/case-files/first-choice-womens-resource-centers-inc-v-platkin/

https://www.oyez.org/cases/2011/10-553

https://www.oyez.org/cases/2019/19-267

Zoning Regulations for Religious and Non-Religious Organizations

 The Holy Trinity Ukrainian Catholic Church, located in Collier Township, Pennsylvania, proposed plans to create a new chapel on their 41-acre plot, which currently holds a cemetery, to expand their religious practices. The land was originally acquired by the church in the 1950s when Catholic refugees from Ukraine settled into the town to continue their customs and traditions. The church spent significant time and money on constructing their plans, even working with the director of planning, zoning, and development to create adjustments, who stated no objections at the time. The township’s planning commission rejected these plans and added restrictions for the church that do not apply to non-religious organizations. These restrictions include limited church bell ringing, who is allowed to have memorial services, and restricting the size and height of the proposed building. 

Despite these rules and denial of development for the cemetery, secular organizations have not faced any restrictions and continue to advance their properties. To illustrate, there is a carpenters’ union a mile away from the cemetery, which contains event spaces, offices, classrooms, a cafeteria, and more. Zoning for secular uses also allows large projects such as fitness centers, ice rinks, and country clubs. All of these regulations are applied within the same zoning district, since both the cemetery and carpenters’ union are located near each other. 

The church filed a federal lawsuit and motion for preliminary injunction for the township in January 2026, meaning that they requested that the restrictions be stopped while the case takes place. The church claims that their religious freedom is being restricted with no compelling state interest, meaning that identified community concerns have not been shared, because they cannot use their own land to further their religious practices by building a new chapel. The pastor of the church, Father Jason Charron, stated, “We are a parish that seeks to worship freely and serve the needs of the community while being treated fairly and equally as all organizations in the Township” (First Liberty). 

This case raises a concern under the free exercise clause because the church seeks to expand a space for religious exercises and prayers to be conducted, and the township is preventing it from doing so by enacting a law that only applies to non-secular organizations. The central constitutional question is whether these restrictions violate the church’s right to exercise religion freely, and whether the township can justify its actions by showing compelling state interest. It is not only about the township regulating land use, but also about whether they are allowed to do it in a way that limits religious practice without significant justification. 

The Religious Land Use and Institutionalized Persons Act states that no government can impose or implement a land use regulation in a manner that creates a substantial burden on religious exercise. This Act is relevant here because the regulations imposed on the Holy Trinity Ukrainian Catholic Church’s ability to build a new chapel directly affect how the church continues its religious traditions. Restrictions on bell ringing and who qualifies to hold memorial services interfere with their established practices. This prevention supports the argument that the township’s restrictions substantially burden the church. 

At the same time, it is important to consider the townships' reasoning. Local governments are responsible for concerns such as traffic and parking, public safety, water and sewer supplies, and the need for commercial space. These concerns could be qualified as compelling state interests because they relate to the general welfare of the community. Specific concerns that the township has for the developments are noise and traffic concerns. However, there is a contradiction in the way these concerns are applied. The carpenters’ union is developing within the same zoning district which even has an event space large enough for 400 people. Even after the church scaled down in size on its original development plans, proposals were also denied. This difference in treatment raises the issue of disparate treatment, showing that the church is unfairly under stricter limitations than non-religious organizations.

I perceive the township’s restrictions to violate the free exercise clause because they are imposing a substantial burden on the church’s ability to practice religion on its own property. While I understand the logistical concerns the town put forward about traffic and noise, it is difficult to justify because secular organizations are being approved for large developments in the same zoning district, which creates the same problems. This is an inconsistent application of development rules and supports the church's claim that they are being unfairly restricted in religious freedom. 

This issue connects to other interpretations of free exercise, such as the Sherbert test and the Religious Land Use and Institutionalized Persons Act, as stated earlier. Both emphasize that the government cannot significantly burden religion unless it demonstrates a compelling interest and uses the least restrictive means possible. The township's actions fail this test because restrictions are disproportionately targeting religious organizations, with no compelling interest shown. Governments must apply regulations neutrally and consistently, especially in cases that directly affect the exercise of religious freedom.

Case: https://firstliberty.org/cases/holy-trinity-ukrainian-catholic-church/

Other Links: 

https://www.standingforfreedom.com/2026/01/28/pa-church-sues-collier-township-rluipa-zoning-worship/

https://www.justice.gov/crt/religious-land-use-and-institutionalized-persons-act-2000 

https://www.churchlawcenter.com/church-law/how-zoning-laws-can-affect-a-church/#:~:text=Churches%20can%20sometimes%20find%20themselves,with%20sewers%20or%20water%20supplies

Church Rights and Ministerial Exceptions: Union Gospel Mission of Yakima Washington v. Nick Brown

The Union Gospel Mission of Yakima is a Christian nonprofit organization that helps people experiencing homelessness, offers support for those dealing with addiction, and provides health services through partnerships with local care centers. They are centered around the idea of Christian values, and the belief in those values will help people come out of homelessness. In the past, they have only hired people who share the organization's Christian values. However, Washington state has a law called the Washington Law Against Discrimination, or “WLAD”, which prohibits discrimination in employment based on several different grounds, including sexual orientation. However, Union Gospel expects all of its employees, including non-ministerial positions, to follow the idea that they should abstain from sexual activities until married, and the only relationship acceptable is between a man and a woman. (A ministerial exception was a First Amendment-based doctrine that states that religious institutions cannot interfere with a church’s choice of minister, which allows the church to choose ministers who would best fit their religious purposes.) 

Union Gospel sued Nick Brown and other state officials, arguing that the WLAD violates the church autonomy clause, which is protected in the First Amendment. The WLAD used to be a much more lenient law, where most religious exemptions were granted, but Washington State has recently become stricter about it. The state changed the hiring rule to apply only to religious belief for ministerial positions. 

The question at hand is the following: Can Washington State require a religious organization to hire people for non-ministerial roles who don’t follow the same beliefs that they do?

On January 6, 2026, the Ninth Circuit Court sided with Union Gospel, saying that the law violated the organization’s religious rights. Before they made a decision, they referenced three points as to why the Union Gospel should be allowed to hire solely Christian believers; they are a religious organization, they sincerely believe that only Christian employees will help them with their mission, and the hiring process is based on that belief. The Court cites the religious clauses in the First Amendment, specifically the church autonomy doctrine, which holds that the government may not interfere with religious organizations' internal processes.

The Court admits that hiring solely based on religious beliefs does technically break the law that they have already passed, but the law conflicts with people’s First Amendment rights, specifically the Free Exercise Clause, therefore allowing the Union Gospel to hire strictly Christian believers. They also added that even with an exception for religious bias in hiring, they are not allowed to discriminate based on anything other than religious grounds. Ultimately, the court affirmed an injunction, which would allow the Union Gospel to hire based on religion despite the law still being in effect. 

I have conflicting views about the case. I agree with the court’s decision solely based on the fact that the WLAD violates the religious freedoms, specifically the Free Exercise Clause and the church autonomy doctrine, stated in the First Amendment. The WLAD prevented the Union Gospel from hiring exclusively Christian employees, which directly interferes with a religious organization's hiring process. However, this case may create situations in which the government has to make controversial decisions on determining whether an organization is worthy of exemptions like this. 

By allowing an exemption to the Union Gospel, the Court allows for potentially fraudulent organizations to hire based on certain traits that they may favor. Part of the reason they issued a preliminary injunction is that they determined the sincerity of the Union Gospel was sincere enough. But this may allow for other organizations to use this case as a precedent for other discriminatory practices that may not be rational. Additionally, the ruling was made for people who don’t necessarily have religious roles. I think the court needs to stick to one definition of a “ministerial exception.”

To be deemed a neutral law, the Court would have to offer exemptions to every religious group that wants to hire, regardless of position, based on religious background. There is also a question of how they determine sincerity. Historical background, actions and time spent, and numerous other factors all have to be considered when determining sincerity. But the lingering question is which of those factors matters most to the court?

Ultimately, the exemption leads to a slippery slope that would lead the courts to judge organizations based on different factors, and would also open the door for potential fraudulent religious organizations with discriminatory hiring practices that may not fall within their religion. 

Resources: 24-7246.pdf

Yakima Union Gospel Mission

Private Faith and Public Funds: What does Youth 71Five Ministries v. Williams Means for the First Amendment

 The Ninth Circuit Court’s decision and the subsequent petition to the Supreme Court for the case of Youth 71Five Ministries v. Williams forces the confrontation of a difficult yet important constitutional question: if a religious organization applies for public funding, can the state require it to comply with nondiscrimination rules that might interfere with religious hiring practices? 

Oregon’s Youth Development Division is responsible for administering the Youth Community Investment Grant Program, which is designed to support at-risk youth in order to promote educational success. To be eligible for funding for the program, applicants must certify that they do not discriminate in employment or admission on a variety of protected identities, including religion. 

Youth 71Five Ministries, or 71Five, is a nonprofit Christian ministry whose stated purpose is described as to “teach and share about the life of Jesus Christ.” 71Five primarily runs youth centers, mentoring programs, and other community-oriented services. While it does in fact serve youth regardless of faith, it does require all employees to affirm a “Christian Statement of Faith” and verify that they have active involvement in a local church. For multiple years, Oregon’s YDD provided funding for 71Five’s programs. But after the implementation of the non-discriminatory hiring requirement, the state withdrew its public funding. 71Five then sued the state on the grounds that the withdrawal of the grant violated the Free Exercise Clause and autonomous religious practices. 

The Ninth Circuit Court gave a mixed ruling after deciding on the case. It held that Oregon’s nondiscrimination rule was fundamentally neutral and generally applicable due to the fact that the rule applied to all who apply for public funding. Due to the grant’s rules being applied to both religious and secular institutions, it does not single out any particular religion for biased treatment. The Court also rejected 71Five’s claim of religious autonomy on the basis that ministerial exemptions serve to function as a defense in employment litigation, not as affirmative claims to unconditional public funds. 

Ultimately, the court drew an important line: while Oregon could use conditional grants to enforce nondiscrimination requirements, it could not extend those requirements to 71Five’s privately funded programs. However, the ruling in this case brings up questions regarding expressive association status and unconstitutional conditions.

The strongest issue concerns expressive action and unconstitutional conditions. The Ninth Circuit Court mentioned Boy Scouts of America v. Dale’s ruling that organizations engaged in expressive activity must tailor their membership to support their ultimate purpose and message. 71Five argued that by not requiring active participation in a local church and the affirmation statement, the organization's religious expression might be altered. While the Ninth Circuit agreed in part, it ultimately stuck to its ruling that Oregon’s rule was reasonable and neutral, but any further extension beyond funded initiatives would violate the doctrine of unconstitutional conditions. 

71Five also argued that it was excluded because of its religious status, invoking cases that were previously mentioned on this blog, such as Trinity Lutheran Church of Columbia, Inc. v. Comer, which prohibit the state from denying public funds based on religious status. The Ninth Circuit distinguished the differences between cases, establishing that Oregon did not deny 71Five funding because of their religious status, but because of their employment practices. 

Personally, I find that the Ninth Circuit’s ruling was very persuasive. In regard to the neutrality of the law, Oregon’s grant framework would also disqualify an atheist group from public funds if it required employees to renounce their belief in a god. The symmetry of the rule supports the court’s ultimate conclusion that the state did not target a religious group in particular. Under the current doctrine, the Free Exercise Clause does not guarantee exemptions from neutral rules to obtain public funding. 

Secondly, obtaining public funding generally carries obligations to the public. When a state grants public funds to serve at-risk youth, there is a legitimate state interest in ensuring that participation in the programs is not religiously cohesive. While I agree that the Constitution protects religious liberty from coercion, it does not guarantee exemptions to public funding based on religion. 

However, the court was correct in limiting the state of Oregon’s authority beyond public grant programs.  If the state could expand its conditional grants on the condition of abandoning its faith-based hiring practices across all operations, it would have significant financial leverage to reshape religious identities. The doctrine previously mentioned of the unconstitutional conditions doctrine exists to prevent that type of government overreach. 

Ultimately, this case illustrates tensions between expanding religious institutions' ability to obtain public funds while maintaining neutral regulations. It will be interesting to see if and when this case is ruled on by the Supreme Court, as public funding surrounding religious institutions continues to be a relatively constant issue being brought up.

See Primary Article & Resources Here

Trueblood v. Valley Cities Counseling and Consultation

Trueblood v. Valley Cities Counseling and Consultation

In the state of Washington, Dorothy Trueblood was terminated from Valley Cities Counseling and Consultation (VCCC) as a 'WISe Program parent partner’ on July 19, 2022. Trueblood, a Christian woman, was hired in 2012 and signed onto VCCC’s Staff principles, acknowledging that they would govern her work. She openly expressed her Christian faith and stated she felt her views were respected until her termination. On June 29, 2022, Trueblood requested workplace accommodations from Human Resources based on ‘religious beliefs and freedom of speech’ to not work with clients with preferred pronouns, not include pronouns in her introductions and email signatures, and to use clients' and coworkers’ names rather than their preferred pronouns.

Trueblood previously expressed to the WISe Program program manager that her religious beliefs conflicted with VCCC’s policies of using clients' and staff’s preferred pronouns. Trueblood and the manager discussed the potential harm that can be done to clients when they’re not referred to properly following inciting incidents with two non-gender-conforming clients. She was informed that Washington regulation 162-32-040 states that intentional misuse of an individual’s name, form of address, or pronouns is prohibited in places of employment and public accommodation. As a result, her accommodations were denied, and her employment was terminated.

VCCC is described as a nonprofit mental healthcare provider that offers support with anxiety, depression, substance use, gender dysphoria, and more, and operates the WISe Program to help with family mental health support. The program stated that youth clients have “complex behavioral health issues, some of which relate to sexual orientation and gender identity.” (Google Scholar) Youth Clients would have a peer or a parent partner, but VCCC stated that the youth is the client at all times, not the parent. VCCC also advised services to accommodate mental health needs with the parental and clients’ consent.

Trueblood was assigned two non-conforming gender youths in 2022. Despite the first client having preferred pronouns, Trueblood told the client’s mother her intention of using their assigned pronouns at birth, which was agreed upon by the client’s mother and a WISe team facilitator, as she was a parent partner and not a peer counselor. The second client’s parent requested that their child’s preferred pronouns be respected due to discrimination against their gender identity, and Trueblood offered to leave the client’s care team, raising her religious beliefs as the reason. Trueblood continued to engage with clients in ways that violated VCCC policies and was told that three out of five accommodations were discriminatory based on gender identity, i.e., using the correct pronouns only when people’s biology matched, but refusing to use preferred pronouns any other time.

While Trueblood claimed to have never refused cooperation with a client or co-worker due to gender identity, VCCC fired her on the basis that employees are required by state and federal laws to abide by gender identity, and refusing to use proper pronouns is discrimination. Trueblood cited that her accommodations stemmed from the freedoms of speech and exercise of religion, but since VCCC is a non-profit, amendments don’t apply in the same manner as a government institution. She denied her termination being a mutual agreement and filed a lawsuit against VCCC, accusing them of failing to accommodate her religion under Title VII, “the burden shifts to the employer to prove that it made good faith efforts to accommodate that employee's religious belief,” unless it would bring about an undue hardship on the employer, and the Washington Law Against Discrimination.

In Groff v. DeJoy, Groff requested Sundays for religious reasons, but USPS continued to schedule him. Groff was disciplined, resigned and then sued under Title VII of the Civil Rights Act of 1964. The Supreme Court unanimously ruled that the employer forcing other employees to work would not constitute an undue hardship on business, and undue hardship shouldn’t be based on employee animosity or perceived inconvenience towards religious accommodations.

In Trueblood's case, while there was an argument made that VCCC failed to give Trueblood a reasonable accommodation alternative, VCCC argues three of the five accommodations would have caused hardship as it risks violating state and federal laws on gender discrimination, stating that neither Title VII nor the WLAD can accommodate a discriminatory practice. The District Court for the Western District of Washington dismissed Trueblood’s claim with prejudice.

I agree with the court’s ruling because even though Trueblood sought the protection of the First Amendment, VCCC being a private institution means that it doesn’t apply directly. Trueblood signed off on VCCC's principles, which required staff to accommodate clients’ mental health needs and identities, which she failed to do. Finally, she put undue hardship on VCCC as discrimination based on gender identity in a place of accommodation is a liability for a place that's meant to provide mental health care tailored to individuals of all ethnicities, sexual orientations, religions and gender identities.

The Constitutional Tension: Government Neutrality vs Free Exercise Protection

     In 2020, Colorado voters approved a proposed program that would provide funding for voluntary, universal preschool in the State. The program was later created in 2022, when Colorado's Department of Early Childhood established the “universal” preschool program that allows prekindergartners to have 15 hours of school time per week. The only requirement was compliance with an equal opportunity agreement that prohibited discrimination against students or their families based on race, religious affiliation, sexual orientation, gender identity, income, or disability. This would guarantee that all children and their families would be free from facing any stigma or discrimination. The program was advertised as universal and was offered to all public, private, and religious institutions on the condition that they agreed to the equal opportunity requirement. Two catholic institutions were excluded from the program due to their refusal of the requirement and brought the case, St. Mary Catholic v. Roy, to court, alleging discrimination in violation of the free exercise and the free speech clauses of the First Amendment.

       Does the equal opportunity requirement, by requiring religious schools to accept policies that conflict with their doctrine, infringe upon the church’s religious exercise? Is the equal opportunity requirement a neutral policy in its effort to provide universal preschool?

       If we refer to previous cases, we can see that decisions vary on what neutrality is when it comes to the church’s rights to religious establishment. In a case like Carson v. Makin, Judges ruled in favor of the families. The government’s requirement was ruled against because it barred families from using funding for any religious institution. The difference between these two cases lies in the restriction it places; in St. Mary Catholic v. Roy, the restriction placed was that funding would not be given without a formal agreement to the equal opportunity requirement. It still allows institutions of both secular and religious backgrounds to apply and get the funding, thus giving a neutral opportunity to all parties. In Makin, the restriction was that no religious institution could be funded at all, and this was an exclusion of religion as a whole. Ultimately, violating the family’s right to free exercise under the First Amendment.

       Similarly, in Trinity Lutheran Church of Columbia, Inc. v. Comer, Justice Thomas found that the free exercise clause of the First Amendment was clearly created to prohibit laws that discriminate against religion. If the courts found that the state's requirement was an infringement on the church's free exercise clause, then the case would be handled differently. In Comer, the issue held was the states’ singling out religion itself and was ruled unconstitutional. However, in Roy, the law is seen as neutral because it doesn’t single out a specific religious faith or institution. Instead, it is willing to fund all preschools that sign up as long as they agree to the equal opportunity requirement, which many religious and secular schools have done.

        Furthermore, in the Espinoza v. Montana Department of Revenue case, Judge Ginsburg states that the precedent set by the court established that neutral government action is not unconstitutional solely because it doesn’t benefit religious exercise. This ultimately implies that Judge Ginsburg is conveying that the government does not owe or have to give special benefits, such as allowing exemption from equal opportunity policies, to religion, and as long as a law remains neutral and treats all religions the same, then it is constitutional. The case also found that the government cannot deny public benefits solely because an institution is religious, but is that really what is occurring in this case?

        I believe that the ruling should be in favor of the state, the requirements provided by the state, and the program itself are neutral and do not favor or pressure any religion. The state's actions in this case cannot be seen as targeting religion due to the fact that the separation of church and state in this case is already breached, as they allow all preschools of varying religions to receive funding. The state is not banning religious participation but conditioning funding on compliance with a neutral equal-opportunity policy.

        The focus of the issue is neutrality and the exclusion of one religious group due to an unwillingness to sign the equal opportunity requirement. In the case that it is not a law that the church must agree to the requirement, they can choose not to, but they would have to forfeit receiving the funding. The program presented by Colorado’s DOEC should and does fund all schools, as the program was presented to the community as a universal program. While the exclusion of some churches is upsetting, it has been promulgated that the requirement is necessary to receive funding. 

Crucifix Controversy: Marisol Arroyo-Castro and the Establishment Clause

    Marisol Arroyo-Castro, a teacher from New Britain, Connecticut, was placed on leave by the Consolidated School District of New Britain in mid-December of 2024 after refusing to remove a crucifix displayed near her desk. The school’s vice president claimed he had received complaints from two individuals and asked Arroyo-Castro to move the crucifix under her desk, out of public view. She complied for a day. She was approached again and asked to move it, but refused. The next day, Arroyo-Castro was asked not to come back to the classroom. 

    Arroyo-Castro has been a teacher for 32 years and has had the crucifix up for the last 10 years. She was suspended without pay for two days before being placed on paid administrative leave. According to her legal team, Arroyo-Castro was instructed to remove the crucifix or be charged with insubordination. Her legal team also sent a letter to the school district, “Ms. Castro’s treatment is a clear violation of her constitutional right to freely exercise her faith under the United States Constitution and the Connecticut Constitution," the letter reads. "But the District’s actions also violate several other of Ms. Castro’s constitutional and statutory rights, under both state and federal law.”(Fox News) The school asserts that the display of religion in this way violates the rights of students and parents in the district by incorporating Arroyo-Castro’s personal beliefs into neutral ground–a school. 

    In March of 2025, after months of paid administrative leave, she was sent to work in an administrative office–not the school classroom. Arroyo-Castro felt that the tasks assigned to her in this position were demeaning. She also seemed to compare the display of her crucifix to other staff’s items, “They have pictures of their family, and to me, Jesus is my father,” she said. “Pictures of their dogs. The Patriots sign. The Yankees sign. They even have Christmas trees.” (NY Post) In November of 2025, a federal judge ruled against Arroyo-Castro and upheld the school district’s punishment. The judge based his decision on Arroyo-Castro’s behavior, “...acted pursuant to her official duties when she posted items on the classroom wall that students would see during instructional time. The classroom wall decorations are thus speech pursuant to Ms. Castro’s official duties and subject to the District’s control.”(WFSB) 

    A separate, independent investigation done in September found that in addition to displaying her crucifix, Castro also made religious comments to students like, “I hope papa God helps you with your lies,” or “Go find God.” (WFSB)

    Arroyo-Castro’s legal team believes that the action taken against her by the New Britain school district is a clear contradiction to the precedent set by a similar case ruled on by the Supreme Court in 2022: Kennedy v. Bremerton School District. Joseph A. Kennedy of the Bremerton School District sued his school district after being asked not to pray with students during and after football games. Kennedy, a football coach, adopted the practice of praying in the middle of the field after games, and eventually, students began to join him. The school board, nervous that Kennedy’s actions would be seen as violating the separation of church and state, attempted to negotiate with Kennedy to pray privately. Kennedy continued to pray after the game publicly and was put on paid leave by the district superintendent. He did not return to the school. The Supreme Court, in a 6-3 vote, found that the school’s actions violated Kennedy’s First Amendment rights of Free Speech and Free Exercise Clauses. 

    At the center of this case is the controversial question of whether or not a teacher’s actions in their classroom are protected speech or subject to the school’s control. Since public schools are supposed to remain neutral in all matters concerning religion, the crucifix displayed in a classroom could be perceived as an endorsement of a particular religion. In my opinion, I believe that Arroyo-Castro’s behavior demonstrated a clear violation of school policy in addition to potentially infringing on the rights of her students. Arroyo-Castro was asked first to remove the cross from public view, NOT remove it from her classroom. She purposefully disregarded the request from her supervisor and was suspended. In addition, since the walls of a public school are owned by the school, not Arroyo-Castro, religious objects cannot be displayed in the classroom to the students. Arroyo-Castro was made aware of the Establishment Clause and informed that it does, in fact, extend to teachers as they are employees of the school, and the display of her crucifix on the walls, owned by the Consolidated School District of New Britain, could be perceived as the endorsement of a religion by the district, therefore violating the Establishment Clause. I believe that Arroyo-Castro's actions were in violation of the Establishment Clause, and therefore, the action taken was appropriate. 

 References: 

https://okcfox.com/news/nation-world/connecticut-teacher-on-leave-for-refusing-to-remove-crucifix-from-classroom-marisol-arroyo-castro-consolidated-school-district-of-new-britain

https://nypost.com/2025/08/02/us-news/ct-teacher-put-on-leave-for-refusing-to-remove-crucifix-has-still-not-settled-lawsuit/

https://www.wfsb.com/2025/11/04/federal-judge-rules-against-new-britain-teachers-placed-leave-refusing-remove-crucifix-classroom/

https://www.wfsb.com/2025/09/20/report-released-teacher-put-administrative-leave-having-crucifix-classroom/

https://www.oyez.org/cases/2021/21-418

https://constitutioncenter.org/the-constitution/supreme-court-case-library/kennedy-v-bremerton-school-district

https://ecf.ctd.uscourts.gov/cgi-bin/show_public_doc?2025cv0153-88