Oakwood Adventist Academy is a Seventh-day Adventist private school in Hunstville, Alabama. The Seventh-day Adventist Church follows a form of Protestant Christianity that believes the 7th day of the week is a day of rest and observance. They believe the 7th day of the week falls on Saturday on the modern calendar. Their Sabbath lasts from Friday at nightfall to Saturday and nightfall. Parochial schools have a high emphasis on their sports teams. The Oakwood Adventist Academy basketball team enjoyed an outstanding season and made it to the playoffs. The problem was their game was scheduled to be at 4:30 pm on Saturday, which conflicted with the time of the players' Sabbath. During the Sabbath, one may not participate in any work or schooling; basketball falls under that category. The Sabbath is one's time to focus on their prayer and connection with God.
The school made efforts to switch the time of the game to a time that did not interfere with their time of rest so that their players would get a chance to play. They requested to switch the game to at 7:30, only 3 hours after their original game was supposed to be played. The time switch was approved by all schools involved but was rejected by Alabama High School Athletic Association (AHSAA), forcing the team to forfeit the game. The Oakwood is a Seventh-day Adventist school that filed suit claiming the action of forcing their players to play during their Sabbath was a direct burden on their players. They claimed it violated their First Amendment rights to freedom of religion. This case is currently being heard by U.S. District Court for the Middle District of Alabama.
The main question here is whether the Alabama High School Atheltic Association is not letting the Oakwood Adventist Academy Basketball team change the time of their playoff game and discriminating against the players' religious beliefs, putting a direct burden on them. The Oakwood Adventist Academy believes it does and has requested in the suit that the AHSAA provide religious accommodations for their players and other religious academies going forward. The Academy officials also stated that this was not just for themselves; it was for other groups, such as the Orthodox Jews, who believe the Sabbath lands on Friday night through Saturday night. The NCAA, an organization, respected worldwide for how they govern Collegiate Student-Athletes, already has accommodations such as these in place so that no one will ever have to choose between their faith and playing their sport.
A case very similar to this is Nakashima v. Oregon State Board of Education. The Oregon School Activities Association (OSAA) sets the schedules for private and public school teams. The OSAA did not schedule games on Sundays. The Portland Adventist Academy, similar to Oakwood Adventist Academy, follows the teachings of The Seventh-Day Adventist Church. The Portland Adventist Academy requests accommodations that they would not have to play on Saturdays, and up to this point, the OSAA respected that request. The OSAA had received complaints from other institutions involved in the tournament and had informed the Portland Adventist school they could no longer grant their accommodation as previously stated. The OSAA appealed this decision and brought the case to the Oregon Supreme court. The Oregon Court of Appeals found that the OSAA did discriminate against the students by not allowing their accommodations. The OSAA argument was that allowing this accommodation would be giving The Portland Adventist Academy special treatment violating the U.S. Constitution and the Oregon Constitution. The court agreed with the finding of the Oregon Court of Appeals that granting this accommodation did not violate the U.S. Constitution or the Oregon Constitution. The Supreme Court also found the OSAA violated the rights of the students as it discriminated against their religion.
The Nakashima v. Oregon State Board of Education decision will help the Oakwood Adventist Academy in their case of Oakwood Adventist Academy vs. Alabama High School Athletic Association case. Although the cases themselves have differences, the main principles are the same. By the AHSAA not granting the school and its students accommodation to not have to play during their time of Sabbath, the AHSAA discriminates directly against the student's religion. This is a direct violation of the Student-Athlete's First Amendment rights of freedom of religion. The Oakwood Adventist case is not only fighting for their religious freedom but all groups with religious beliefs that could interfere with the ability to participate in sports. The decision of this case will have future implications as if they are allowed religious accommodations, other religions also must be granted the same accommodations for their beliefs. This is a significant issue because these student-athletes chose to attend this private school to practice their religious beliefs. Any Student-Athlete must have equal opportunity to participate in athletic events regardless of their beliefs. Not granting these students the accommodations they need to participate in their specific sport makes it so that there is not equal opportunity for athletes to participate, violating the athlete's rights as Americans.
Sources:
https://www.becketlaw.org/case/oakwood-adventist-academy-v-alabama-high-school-athletic-association/
https://www.aclu-or.org/en/cases/nakashima-v-board-education
https://classroomlaw.org/wp-content/uploads/2018/09/Case-Study-Nakashima-v-Oregon-State-Bd-of-Ed.pdf
10 comments:
I enjoyed reading your court case pertaining to the violation of the player’s First Amendment right to freedom of religion. I agree that the AHSAA is discriminating against the players religious beliefs in not wanting to play the game according to their Sabbath. I liked how you gave the example of the NCAA respecting college athletes by how they work around these religious days and providing accommodations for such practices. It goes to show that the AHSAA should be willing to accomadate especially if a larger, and more important organization can make it work. From the similar court case Nakashima v. Oregon State Board of Education, the court should rule in favor of the player’s and that the AHSAA is violating their religious freedom because these cases have a similar sport and religious conflict.
This case is very interesting to me and my first question pertains to if AHSAA ever commented on the reasoning behind not allowing Oakwood Aventist Academy to switch their game time. Was it because by doing so they were respecting the establishment of religion or was the request rejected due to a reason that doesn't pertain to religion at all (i.e. staffing issues, no courts available, etc..) Another part of your case brief I want to bring into question is when you state, "The Academy officials also stated that this was not just for themselves; it was for other groups, such as the Orthodox Jews, who believe the Sabbath lands on Friday night through Saturday night" (Guy). Is Oakwood Adventist Academy only challenging this in order for the AHSAA to respect those who observe days of rest on Saturday's, or are they raising the question on behalf of all schools who might observe various days of rest throughout the week that coincide with their religion. Finally, I don't think what AHSAA did was unconstitutional in the sense of directly prohibiting the athletes from expressing their religion. They are taking away their ability to play sports, but by not moving the game time they are not prohibiting the students from freely expressing their religious beliefs. Similar to the Braunfeld v. Brown case we discussed last week, not granting the schools request to move the game only leaves students with a difficult ultimatum to make. However, it in no way directly prohibits them from expressing their religious beliefs.
I agree with you that Oakwood player's First Amendment rights were violated. Students should not have to choose between their faith and their sport, especially when all of the other schools in the tournament were willing to accommodate their request. While the tournament having all their games on a Saturday might seem neutral, it is only impacting those who have a Saturday Sabbath. Moving the game back only three hours is a reasonable request that would allow all players who earned a spot in the playoffs to play.
I found this to be a very interesting case and I was very surprised that the AHSAA was not willing to move the game especially when the other teams were willing to make the accommodation. Not only are the actions of the AHSAA unconstitutional, but they are forcing students to choose between their faith and their sport. If the NCAA, an extremely large organization, is able to figure out how to make religious accommodations for a much larger population, then the AHSAA should be able to make similar accommodations for the districts of Alabama. Even though the AHSAA isn’t saying that the players aren’t allowed to practice their religion, they are creating a schedule that is facially neutral but disparately impacts certain religious groups, ultimately violating their First Amendment right to freedom of religion.
I think it is fairly obvious that the Alabama Highschool Athletic Association violated the free exercise clause when they did not allow an exemption for the Oakwood's basketball team. First, based on precedent in Oregon, the exemption should have been granted, and also because the organization had no good reason to not grant the exemption. It was clear that the game schedule interfered with the religious practices of the team, and that there was an easy solution to fix the situation, allow the game to be played three hours later. There is no meaningful claim of state interest overriding the freedom of these players to exercise their religion, as there was already an easy and widely accepted workaround and precedent supporting the school.
Great post! I thought you did a good job of outlining the facts of the case and relating it to other relevant cases that deal with the intersection of sports and religious accommodations/exemptions. When reading the facts, my main consideration concerns what the reasoning was behind why the Alabama High School Athletic Association denied the request to change the game, as this exemption applies to all players of the Orthodox Jewish faith and all teams would be aware of the time change failing to provide any team/player with a competitive edge. In other words, whether or not it is a direct burden, I would be interested to know if there was a sufficient reason for denying the game change in the first place. In my opinion, I do believe that the AHSAA’s denial without sufficient reasoning would violate their free exercise of religion, as it seems to directly seek to prohibit them from refraining from exercise on that day. However, if there was a compelling interest on the part of AHSAA to keep the game at the scheduled time, I believe it might be a different story, as the current schedule fails to privilege any religion in providing exemptions for other days of the week (i.e. Sundays for Christians). Additionally, I do recognize that it doesn’t entirely force them into engaging in the game and violating their beliefs. However, I believe all means to ‘work with’ teams that have players that need certain religious accommodations should be exhausted first, embracing our constitutional history with regards to religion.
Great post, Jake! You outlined this case and relevant issues very clearly and concisely. I agree with your argument and I believe that the league should make an effort to accommodate the team. As we discussed recently in the case US v. Seeger (1965), the Constitution (and the law) favors religion. Thus, the league should reflect this and make an effort to accommodate the religious teams.
While reading, I began to wonder what may happen in the event that two different religious groups with conflicting Sabbath days each requested accommodations in order to avoid playing sports on their day of rest (e.g. Saturday for Orthodox Jews, Sunday for Evangelical Christians). If these two teams happened to be in the same league, would they simply not be able to play against each other? How does this inhibit the goals and purpose of the league itself? The Constitution provides that laws and policies must be neutral between religions, so it would be unconstitutional to allow play on one of the weekend days. I wonder if this might be part of the reason why the AHSAA denied the team an accommodation; if an accommodation is given to this team, who else is allowed an accommodation? This touches on the issue of slippery slope.
Excellent post! I a question that I would bring up about this case is the difference to believe and the difference to act. I see the perspective that the AHSAA had their playoff schedule set in stone, for every team in the state regardless of who made that playoff game. By moving the game for Oakwood, would that be giving a precedent for their religion. In an unpopular opinion, I would see moving the game as a violation of the Establishment Clause. The NFL does not change their gamely from Sunday for religious purposes, if a team or individual does not want to play due to religious purposes, that is their right. Sporting events around the world for Muslims fasting during Ramadan, so I do not see why the AHSAA should accommodate too Oakwood.
While I am sympathetic to the Adventists' unfortunate circumstance, I am unable to see how the actions of AHSAA violated Oakwood Academy's constitutional right to free religious exercise in any way. Firstly, the AHSAA is a voluntary federation of interscholastic athletic programs that is tax exempt, but otherwise does not receive federal funding or any government support. As such, the organization can, for the most part, set its own rules and regulations with impunity, and certainly has no obligation to accommodate every school's scheduling requests that might arise. Furthermore, the AHSAA decision being examined, establishing a certain playoff game on a Saturday, is a facially neutral action that was almost certainly made with logistical feasibility in mind, rather than an intent to discriminate against Oakwood. If AHSAA was legally obliged to accommodate every school in the federation's religious worship needs, it is possible that they would NEVER be able to schedule any games at all.
Nice post, Jake! I agree with your argument and the court's ruling that the AHSAA violated the Oakwood Academy's players' rights. Their sincerity is certainly evident here, since they are a large group all attending a school of one religion. Because their religion mandates rest on the sabbath day, it is ultimately unconstitutional for the AHSAA not to move the game. Moving the game would not be the same as moving it for a mere scheduling issue, as an entire team of players' free-exercise is being inhibited. Students should not have to choose between sports and practicing their religion, and in accordance with the first amendment, the actions of the AHSAA in this case were ultimately unconstitutional.
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