LifeWise Inc is a religious non-profit corporation that offers religious instruction to public school students, with over 400 chapters in over 400 school districts nationwide. With parental permission, LifeWise staff members check students out of school during non-mandatory instruction, such as lunch or recess, and transport them offsite for religious instruction. The religious instruction consists of “biblical literacy and character development,” including “lessons in virtues like courage, honesty, kindness, and forgiveness.”
In January 2025, LifeWise began offering these programs to students attending Emerson Elementary School in the Everett Public School District. LifeWise provided religious instruction off-campus two days per week to Emerson students with parental permission. More than sixty children attending Emerson Elementary School were enrolled in the LifeWise program. LifeWise does not use school resources or property for its lessons, and the LifeWise staff members pick up students from Emerson in a LifeWise-owned bus and transport them to and from a nearby church. LifeWise ensures that all of its staff and volunteers pass comprehensive background checks before working with students. In September 2025, the school board implemented new permission slip policies that limit students' access to the LifeWise programs, by requiring a new permission slip for each student every time they attended LifeWise instruction.
In May 2025, Emerson held its annual Community Resource Fair which “is a District-sponsored event organized by the Family Engagement Team for the purpose of providing access to resources such as legal, health, mental health, special education services, immunizations, and services provided through the Washington State Department of Social and Health Services to families of vulnerable students.” The school district denied LifeWise’s request to obtain a booth at this event because the district does not allow religious organizations to partake in school-sponsored events.
During the spring of 2025, LifeWise displayed flyers in the lobby at Emerson Elementary. On June 13, 2025, Everson Elementary principal Blythe Young informed LifeWise that they would no longer be able to display their flyers in Emerson's lobby. Young cited the school board policy regarding promotional material that states students may “distribute materials, including religious materials, before and after school,” but non-students “are prohibited from distributing materials on campus, and students are not allowed to distribute materials on behalf of groups or individuals who are not students.” LifeWise then submitted an electronic flyer for distribution which was rejected by the school district, requiring “a few changes” before it was distributed.
At the beginning of the 2025-2026 school year, Principal Young began receiving complaints about non-religious students being encouraged to attend LifeWise classes. Teachers at Emerson have also raised concerns about students distributing religious material to other non-religious students in the class. In response, the school district began requiring students to keep all material received from their LifeWise education in a sealed envelope in their backpacks during the school day. LifeWise filed suit against the District on December 18, 2025, alleging that the new RTRI guidelines adopted in September 2025 violate the First Amendment Free Exercise Clause.
The constitutional question regarding religion in this case is whether the School District violated the Free Exercise rights of the students and their parents through the implementation of its new RTRI guidelines.
The most relevant Supreme Court precedent regarding this case is Zorach v. Clauson (1952). This was a similar religious release time case in New York public schools. In Zorach, the Supreme Court held that parents can have public schools release their children during the school day to obtain religious instruction as long as the religious instruction is conducted off school property, is privately funded, and parents give their permission. LifeWise represents a similar but not exact constitutional question regarding religion. Zorach focused mainly on if allowing students to leave for religious instruction violated the Establishment Clause, whereas LifeWise focuses on if the school district's RTRI policies violate the Free Exercise Clause.
In this case, I believe the Court will rule that the school district did violate the Free Exercise Clause of the students and their parents. I believe that there are two reasons for this violation: the policy requiring students to keep all religious material to be kept in a sealed envelope, as well as the policy requiring extensive permission slips for students to attend LifeWise programs. I believe that requiring students to conceal all religious material suppresses their right to express and practice their religious beliefs. I also believe that this is not a neutral policy since it only applies to students who are attending LifeWise instruction and does not include students of other religious denominations. The School District could argue that students have been using this religious material to coerce other students into believing in certain religious practices or doctrines that they do not hold. I do not believe that this is a strong enough argument to limit the students' right to exercise their religion freely, and that there may be less restrictive ways of trying to achieve their goal.
Regarding the permission slip process, I believe that these policies limit students' ability to attend LifeWise instruction. I believe that adding these extra steps to obtain permission may discourage parents from sending their children to LifeWise due to administrative discouragement of these programs. It also requires students to obtain permission every time they want to participate in practicing their religion which I believe places a substantial burden on them and violates the Free Exercise Clause. In conclusion, I believe these policies place unnecessary burdens on the students seeking to attend LifeWise’s programs, violating their First Amendment rights. While I do believe schools have compelling interests in preventing religious coercion, I do not believe the school approached this by implementing policies using the least restrictive means.
Sources
https://firstliberty.org/cases/lifewise-everett-washington/#simple1
https://law.justia.com/cases/federal/district-courts/washington/wawdce/2:2025cv02604/356406/43/
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