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Lower Court Rulings and Precedents

This page examines significant lower court cases that provide further context and support for our arguments against the Second Step curriculum under the Establishment Clause and for the LifeWise Academy during school hours under the Free Exercise Clause. These cases build on the principles established by the Supreme Court and offer detailed insights into how lower courts have interpreted and applied these constitutional protections.

Establishment Clause: Lower Court Rulings

1. Doe v. Porter (6th Cir. 2004)

Summary:

The Sixth Circuit Court of Appeals ruled that a public school’s practice of allowing a religious group to teach a Bible class during school hours violated the Establishment Clause.

Relevance:

This case underscores that public schools must not endorse or promote religious activities. The Second Step program's mindfulness practices, rooted in Buddhism, may similarly be viewed as endorsing a particular religious perspective, thus violating the Establishment Clause.

2. Stone v. Graham (1980)

Summary:

The Supreme Court struck down a Kentucky law requiring the posting of the Ten Commandments in public school classrooms, ruling it violated the Establishment Clause. Although a Supreme Court case, its application by lower courts is significant.

Relevance:

The case sets a precedent that religious content in public school classrooms is unconstitutional. The principles from this case can be applied by lower courts to scrutinize the religious aspects of the Second Step program.

3. Kitzmiller v. Dover Area School District (M.D. Pa. 2005)

Summary:

The Middle District of Pennsylvania ruled that teaching intelligent design in public school science classes violated the Establishment Clause, as it constituted a religious view.

Relevance:

This case emphasizes that public school curricula must be secular. The Second Step program’s incorporation of mindfulness, associated with Buddhism, could be similarly challenged for introducing religious concepts into a public school curriculum.

4. Smith v. Board of School Commissioners of Mobile County (S.D. Ala. 1987)

Summary:

The Southern District of Alabama ruled that a textbook series promoting secular humanism constituted a religion and thus violated the Establishment Clause.

Relevance:

This case highlights that not only overtly religious programs but also those promoting specific worldviews can violate the Establishment Clause. The Second Step program’s Buddhist principles could be seen as promoting a specific religious worldview.

Free Exercise Clause: Lower Court Rulings

1. Roberts v. Madigan (10th Cir. 1990)

Summary:

The Tenth Circuit Court of Appeals ruled that a teacher's display of religious books and a Bible on his desk in a public school classroom violated the Establishment Clause.

Relevance:

Although primarily an Establishment Clause case, it demonstrates the fine line between personal religious expression and perceived endorsement. In the context of LifeWise, the Free Exercise Clause protects the right to religious education outside the classroom setting, such as during release time.

2. Hicks v. Halifax County Board of Education (E.D.N.C. 1992)

Summary:

The Eastern District of North Carolina upheld the right of students to be excused from school for religious instruction during school hours, recognizing the importance of the Free Exercise Clause.

Relevance:

This case supports the argument that students should be allowed to participate in religious education during school hours, aligning with the principles supporting the LifeWise Academy program.

3. Cheema v. Thompson (9th Cir. 1995)

Summary:

The Ninth Circuit Court of Appeals ruled that a school district must accommodate Sikh students' religious practice of carrying a kirpan (a ceremonial dagger) as long as it does not pose a threat to safety.

Relevance:

This case demonstrates the need for schools to accommodate religious practices. Similarly, ECS should accommodate the LifeWise Academy, respecting parents' and students' religious rights under the Free Exercise Clause.

4. Fowler v. Rhode Island (1953)

Summary:

The Supreme Court ruled that a city ordinance prohibiting religious services in a public park was unconstitutional as applied to a Jehovah's Witness, reinforcing the Free Exercise Clause. Although a Supreme Court case, its application by lower courts is noteworthy.

Relevance:

This ruling underscores the protection of religious practices in public spaces. Applied by lower courts, it supports the argument for allowing religious instruction during school hours, as it does not infringe upon others' rights and is an exercise of religious freedom.

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State Ex Rel. Holt v. Thompson State Ex Rel. Holt v. Thompson - 225 N.W.2d 678, 66 Wis. 2d 659 law.justia.com⁠

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Smith v. Smith, 391 F. Supp. 443 (W.D. Va. 1975) Smith v. Smith, 391 F. Supp. 443 (W.D. Va. 1975) case opinion from the US District Court for the Western District of Virginia law.justia.com⁠

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Implications for the Second Step Program and LifeWise Academy

Establishment Clause Implications for Second Step

The lower court rulings reinforce that public school programs must remain secular and not promote or endorse religious practices. The Second Step program’s incorporation of mindfulness practices rooted in Buddhism may be seen as advancing a specific religious perspective, violating the Establishment Clause. ECS must ensure that any program implemented in public schools does not favor or promote religious ideologies.

Free Exercise Clause Implications for LifeWise Academy

The lower court rulings support the protection of religious practices and the rights of parents and students to choose religious education. The Free Exercise Clause ensures that ECS cannot prohibit the LifeWise Academy from operating during school hours if it respects legal precedents and parental rights. Accommodating the LifeWise program aligns with the principles of religious freedom and parental choice upheld by these rulings.

How You Can Help

Educate Yourself and Others:

Familiarize yourself with these lower court decisions and share this knowledge with your community.

Get Involved:

Join our advocacy efforts by attending public meetings, signing petitions, and participating in our campaigns.

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Sign the Petition

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Eaton Community School Board Must Uphold the 1st Amendment - Online petition In recent months, the Eaton Community School District (ECSD) has found itself at the center of a significant controversy involving the infringement of First Amendment rights, particularly those pertaining to religious freedom under both the establishment and free exercise clauses. The actions taken by the school district have not only caused emotional distress but have also infringed upon the fundamental rights of parents to direct the religious upbringing of their children. This situation has p www.openpetition.org⁠

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Together, we can make a difference.

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