Bethesda University, located in Anaheim, California, is a private Christian university that was founded in 1976 on the ideals of Pentecostal theology and was recognized as an accredited institution by the state. Their specific theology uniquely emphasizes a direct, experiential relationship with God through the Holy Spirit, and embodies a more literal interpretation of the Bible. According to the university, these values shape the mission and educational goals of the school.
In the early months of 2022, an internal dispute arose among the school’s board of directors when the president of the university wanted several board positions to be filled by non-Pentecostal members. Up until then, every university board member had been a follower of the Pentecostal faith. The president, however, had concerns over the accreditation status of the university because they lacked a diverse representation of religion on the board itself. The board then elected the new members to avoid any repercussions. A few months later the board discovered the president’s concerns did not have any legal justification and objected to the appointments of the new directors. After the president refused to remove the new directors from the board or hold another election, the majority of directors voted to fire him from his position and he was subsequently let go. He then filed a lawsuit, and a California trial court conducted a hearing under the Corporations Code to determine which group of board members should lead Bethesda and to protect the jobs of his new appointees.
Under the school’s bylaws, its board retains ultimate power to determine the religious principles and policies governing every aspect of its operations and instruction. Yet somewhere in the official language, the court found that this particular Pentecostal organization permits non-Pentecostals to occupy some of the highest leadership positions despite the school’s religious requirements. Therefore the new appointees who do not share the university’s founding faith cannot be demoted or fired solely because of their religious beliefs or lack thereof.
The constitutional question at hand is not whether or not the board members can be reevaluated, it is whether or not the court has the authority to interpret and act upon private religious universities’ bylaws and missions, especially when their ruling goes against what the founders had originally intended. The First Liberty Institute, who is defending Bethesda University in this case, argues that allowing the court to interpret the foundational documents of the university is an excessive entanglement of the church and state, as cited under the Lemon Test established in Lemon v. Kurtzman, and therefore is in violation of the Establishment Clause. They believe secular courts are prohibited by the First Amendment from involving themselves in the mission of religious organizations. If a court can evaluate the religious character of Bethesda University, it can also tell the local church who it must hire to preach their beliefs and allow outsiders to direct the mission of the church, regardless if it is out of step with the religious doctrines of the church.
The court claims to have acted neutrally towards Bethesda University by judging the bylaws based on face value and technical language, not the religious convictions of the Pentecostal ideology. Also the court could argue that the missions of religious universities have been interpreted, and in some cases challenged, in the past. A primary example of this can be found in Bob Jones University v. United States. Here, the court upheld the revocation of the university’s tax exempt status due to an interracial dating ban that went against the government’s policy interest. By ruling against them, the court clearly decided against Bob Jones and their religious mission.
In my opinion, the argument in favor of Bethesda is more convincing. The issue at hand is inherently different from the Bob Jones ruling because there is no compelling reason for the government to intervene in Bethesda University’s hiring practices or their mission as a private religious entity. The Establishment Clause protects religious institutions, including universities, from government overreach and excessive entanglement. There is no reason to treat Bethesda University differently from any other church or organization that holds religious beliefs, especially without a compelling interest motive. If we allow the court to interpret bylaws that are held and written by a religious institution, we are indirectly allowing the government to enforce these privately held laws (many of which are religious in nature) on their authors and supporters who have unique religious convictions and wish to see these convictions represented in their respective schools. While the court may be acting neutrally by interpreting the bylaws through a nondiscriminatory lens, the result of their ruling has negative implications for the future of religious freedom in a variety of religious institutions.
7 comments:
I think the distinction between Bethesda’s case from Bob Jones University v. United States is super importnat. Without a compelling government interest, court intervention here feels much harder to justify. It's one thing to intervene against racial discrimination, but it's another to interpret internal religious documents, even under a "neutral" lens, when that risks redefining a religious institution’s mission.
I also agree that even neutral interpretation can lead to unconstitutional entanglement, which the Lemon Test warns against. If courts can reinterpret religious bylaws now, it opens the door to more government interference later.
I agree with you! I believe that reviewing and judging Bethesda's bylaws and founding documents causes as excessive entanglement by government. While I see interest in examining these documents for the sake of the plaintiff, I find that interpreting these documents would be overstepping and would lead to blurring the line between church and state.
I see your argument, but I am leaning towards the opposing side based on the facts of the case. Similarly to what Dylan stated, it is important to recognize that the court is not judging the belief of Bethesda University. The court is just evaluating the bylaws the university has written and determining whether or not they have violated them. I would be able to see the entanglement if the court was deciding the ability of the university to deny board members who do not share the pentecostal faith this would be a different case. In general, I would agree that the government should stay out of the rules and guidelines of religious education. Yet Bethesda's bylaws clearly show non-pentecostal individuals can be on the board.
I partially agree with your argument based the fact that there is no compelling state interest for the government to step into review and judge Bethesda's bylaws and founding documents. However, Bethesda's bylaws state that non-pentecostal individuals can be on the board, and removing the non-pentecostal individuals because of their different convictions would be a clearly violation of their bylaws. If the school cannot adhere to their own bylaws, they should reevaluate. But ultimately i do agree that the government should prevent any excessive entanglement.
I agree that there's no compelling state interest to justify court intervention in Bethesda's internal affairs. However, the key issue seems to be whether the court simply interpreted neutral language in the bylaws or went further by stepping into theological grounds. Like Dylan and Payton pointed out, if the court genuinely remained neutral and focused solely on the text of Bethesda's own documents, it's within their jurisdiction. But if their ruling indirectly shapes Bethesda’s religious identity, that risks unconstitutional entanglement, mirroring concerns raised by Luke and Natalie. It's a balance, but overall, I agree that courts must tread carefully to preserve religious autonomy.
I believe courts should avoid interfering in the internal governance of religious institutions like Bethesda University, especially when such interventions could result in government entanglement with religious beliefs. This scenario differs greatly from the Bob Jones case, as there is no compelling government interest involved. Protecting religious autonomy is essential for maintaining First Amendment rights, and permitting courts to reinterpret religious bylaws might set a dangerous precedent for church-state relations in the future.
I agree with the argument in favor of Bethesda University. Courts should not interfere in the internal governance of religious institutions, especially when the dispute involves theological principles and leadership rooted in faith. While the court may claim neutrality, its involvement risks entangling government in religious affairs, violating the Establishment Clause. Protecting the autonomy of religious schools like Bethesda is essential to preserving the broader principle of religious freedom in the United States.
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