In Moody Bible Institute of Chicago v. Board of Education of the City of Chicago, the ongoing debate over the role of religion, and Free Exercise thereof, in public education continues.
The Moody Bible Institute is a not-for-profit, Christian-based higher education institution located in Chicago, Illinois. As put forward in their mission statement, “Moody exists to proclaim the gospel and equip people to be biblically grounded, practically trained, and to engage the world through gospel-centered living.” This mission became a point of concern for the Chicago Board of Education in relation to Moody’s Elementary Education degree program. Through this biblically centered, state-approved program, Moody trains future elementary school teachers by requiring students to spend varied amounts of time participating in classroom observations, practicums, and some form of student teaching. In order to better help students meet these requirements, Moody attempted to join the Chicago Public Schools’ (CPS) student-teaching program but was denied on the grounds that allowing them to use the CPS’s resources would result in an excessive entanglement of church and state. Therefore, Moody was told they must give up their religious hiring policies before they would be able to participate in the CPS’s student-teacher program. With this ultimatum, Moody, along with the help of the Alliance Defending Freedom, filed a lawsuit that would attempt to allow them to maintain their hiring practices and still participate in the government-provided programs. Their primary argument was that, seeing as their hiring policies were in strict accordance with a religious mission, the government could not penalize them without threatening their Free Exercise of Religion.
It is important to note that in the end, this case was settled outside of court before moving to trial, and Moody was permitted to partake in the CPS’s student-teacher program without having to give up their hiring policies. That does not, however, take away from the contribution this case brings to the ongoing debate and deliberation over Supreme Court Free Exercise cases.
This case wrestles with the difficulties of both the Free Exercise and Establishment Clauses of the First Amendment. The Constitutional question that was at hand was whether or not a government entity could deny a generally accessible public service/benefit to a religiously affiliated institution without violating the Free Exercise Clause and Establishment Clause.
Moody and their student teachers never had the express intention to go out and directly spread the gospel through their student-teacher placements. While Moody’s Elementary Education degree would teach its student-teachers biblically centered doctrines in conjunction with its education requirements, its explicit student-teacher policy required that any student working at a school must comply with the rules, policies, and district regulations of their designated school. In practice, this meant that just like the CPS, Moody was attempting to avoid the excessive entanglement of church and state with their teachers and their placements. Furthermore, because of these internal policies put in place by Moody, the CPS’s discrimination begins to be viewed in a much poorer light.
To provide some legal precedent for this debate, I will briefly explain the Supreme Court cases, Carson v. Makin and Locke v. Davey. In Carson v. Makin, the Supreme Court determined that a religious institution cannot be excluded from partaking in public benefits of the state. If the Moody case had proceeded to trial, any ruling that would deny these benefits would be seen by the Supreme Court as an unconstitutional discrimination against the religious institution. While any state benefits or funds that these institutions could utilize have the potential to indirectly support religious instruction, they cannot allow the state to block the allocation of benefits to these institutions. Conversely, in Locke v. Davey, the court ruled that it is permissible to refuse allocation of benefits to deeply religious activities, the most prominent being direct religious instruction. While this case seemingly provides a base for the opposition to stand on in their argument, it is difficult to know whether or not the argument would stand against Moody’s actions. Seeing as Moody was not sending student-teachers to actively facilitate direct religious instruction in their school placements, because they were coming from an institution where they themselves received direct religious instruction, it is reasonable for the CPS to have concerns about establishing one religion over another.
I believe that this case allows for a very poignant conversation and reflection about the way in which we as individuals interpret our Free Exercise. While the case never made it to any high court, let alone the Supreme Court, I still believe that 1) this case was handled in such a way that adds a semi-new layer of legal precedence to Free Exercise cases, and 2) had the most optimal outcome in constitutional terms. In this case, I believe that the result of the settlement to allow Moody to partake in the CPS’s program was the correct and most constitutional course of action. The key issue I recognized as I was researching and contextualizing the case was what the Moody students’ intentions were with these programs if allowed to participate? I believe that the Moody students saw a deficit of teachers in the CPS and decided that it was their right to lend their talents and experiences to ensure that every student had equal access to education. In the end, that could only be provided if the teachers themselves were provided equal opportunities to teach whether they had a religiously affiliated background or not. Moody wasn’t pursuing preferential treatment from the CPS, but rather equal treatment.
https://www.moodybible.org/about/
9 comments:
I agree with Graiden and the court's decision here. This program has the ultimate goal of improving access to education. This means that any improvement gained by the church would be indirect, making this a good outcome.
I agree with your analysis as well as the court's decision. I think that this is a public benefit that religious institutions should be allowed to partake in. I do not believe this qualifies as "excessive entanglement" as you mentioned in the early part of your response. However, I do acknowledge why this could be considered unconstitutional, as some view any aid to religious institutions, either direct or indirect, as a violation of the Establishment Clause of the First Amendment.
I agree with your opinion on the case. Since this program is designed to further education and requires that any student working at a school must comply with the rules, policies, and district regulations of their designated school, I believe its primary mission is not to advance religion, but rather to advance education. I do not believe that public funding to this organization would create excessive entanglement between church and state.
I agree. Moody Bible Institute (“Moody”) should constitutionally be able to participate in Chicago Public Schools (“CPS”) student-teaching program. Their rights are protected via the Locke v. Davey (“Locke”) precedent, as the government can only refuse organizations with deeply religious activities. Moody was not deeply religious, as its student-teacher policy required compliance with district and school rules. Therefore, Moody wanted neutral treatment, and its constitutional rights under the Free Exercise and Establishment Clause were abridged.
I agree with the analysis you provided here as well. I think the primary focus of this program is to further students education, not advance religion. The funding towards the organization, based on your analysis, I believe is not going directly to aid religion and is more indirect and therefore is constitutional.
I agree with the Graiden's conclusion that the settlement reached in the Moody case was the right decision. The Chicago Public Schools’ decision to exclude Moody from a generally available student-teaching program burdened his religious exercise without sufficient justification. Especially since Moody students were required to follow all rules and were not engaging in direct religious instruction.
Thanks for this Graiden! I agree with your analysis. I think one way of framing this argument would be to emphasize the public benefit that is created by allowing Moody to participate in the CPS student-teacher program. In this case, more teachers = better education. That way, you are framing this not as a religious argument, but as a secular goal that needs to be fulfilled.
I agree with your perception of this case. Neutral treatment is not advancement and Moody Bible Institute should be treated as such.
I agree with your analysis of this case, and I like how you connected it to Carson v. Makin. This really highlights the shift towards protecting equal access for religious institutions. In my view, it is meant to advance education and not religion. Therefore, I think that this is a public benefit that all should be able to participate in, including religion.
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