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Supreme Court Rulings

Here, we delve into the key Supreme Court cases that are pertinent to our advocacy for religious freedom and parental rights within the Eaton Community School District (ECS). These cases provide the legal foundation 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.

Establishment Clause: Key Cases

1. Everson v. Board of Education (1947)

Summary:

The Supreme Court upheld a New Jersey law allowing public funds to be used for transportation to religious schools. The decision emphasized the need to maintain a wall of separation between church and state.

Relevance:

This case underscores that public funds cannot directly support religious activities. Applying this to the Second Step curriculum, which incorporates Buddhist principles, suggests that ECS must ensure its programs do not endorse or promote religious practices with taxpayer dollars.

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Everson v. Board of Education, 330 U.S. 1 (1947) Everson v. Board of Education: Although the Establishment Clause does require governments to avoid excessive entanglement with religion, it is permissible for a state to reimburse the costs of transportation for students in parochial schools. supreme.justia.com⁠

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2. Engel v. Vitale (1962)

Summary:

The Supreme Court ruled that government-directed prayer in public schools violates the Establishment Clause.

Relevance:

This case highlights the prohibition of religious activities in public schools. The incorporation of mindfulness practices in the Second Step curriculum, which are rooted in Buddhism, may be seen as promoting religious activities, thus violating the Establishment Clause.

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Engel v. Vitale, 370 U.S. 421 (1962) Engel v. Vitale: The state cannot hold prayers in public schools, even if it is not required and not tied to a particular religion. supreme.justia.com⁠

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3. Abington School District v. Schempp (1963)

Summary:

The Court held that Bible readings and other religious exercises in public schools are unconstitutional.

Relevance:

Similar to Engel, this case further supports the argument that any form of religious practice in public schools, including Buddhist mindfulness exercises, must not be endorsed by the school district.

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Abington School District v. Schempp, 374 U.S. 203 (1963) School Dist. of Abington Tp. v. Schempp: Public schools cannot sponsor Bible readings and recitations of the Lord’s Prayer under the First Amendment’s Establishment Clause. supreme.justia.com⁠

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4. Lemon v. Kurtzman (1971)

Summary:

Established the Lemon Test to determine whether a law violates the Establishment Clause. The test has three prongs:

The law must have a secular purpose.

The primary effect of the law must neither advance nor inhibit religion.

The law must not result in an excessive government entanglement with religion.

Relevance:

The Second Step program must pass the Lemon Test. If its mindfulness practices, rooted in Buddhist principles, advance a particular religion, it may fail the test and thus violate the Establishment Clause.

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Lemon v. Kurtzman, 403 U.S. 602 (1971) Lemon v. Kurtzman: The test for determining whether a law meets the requirements of the Establishment Clause is whether it has a legitimate secular purpose, does not have the primary effect of either advancing or inhibiting religion, and does not result in an excessive entanglement of government and religion. supreme.justia.com⁠

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5. Edwards v. Aguillard (1987)

Summary:

The Court struck down a Louisiana law requiring that creationism be taught alongside evolution in public schools, ruling it violated the Establishment Clause.

Relevance:

This case reinforces that public school curricula must be secular and not promote religious views. The Second Step curriculum’s Buddhist underpinnings could be seen as promoting a religious perspective, similar to how creationism was seen in Edwards.

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Edwards v. Aguillard, 482 U.S. 578 (1987) Edwards v. Aguillard: Public schools violate the Establishment Clause by teaching creationism. supreme.justia.com⁠

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Free Exercise Clause: Key Cases

1. Zorach v. Clauson (1952)

Summary:

The Supreme Court upheld a New York program allowing students to leave school during school hours for religious instruction, recognizing that accommodating religion does not equate to establishing it.

Relevance:

This case is a cornerstone for the LifeWise Academy argument. It establishes that students can participate in religious education during school hours without violating the Establishment Clause, directly supporting the inclusion of the LifeWise program in ECS.

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Zorach v. Clauson, 343 U.S. 306 (1952) Zorach v. Clauson supreme.justia.com⁠

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2. Sherbert v. Verner (1963)

Summary:

Established the Sherbert Test, which requires the government to show a compelling interest before restricting religious practices.

Relevance:

ECS must demonstrate a compelling interest to prohibit the LifeWise Academy. Given that the program aligns with established legal precedents for religious education, ECS's prohibition likely fails the Sherbert Test.

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Sherbert v. Verner, 374 U.S. 398 (1963) Sherbert v. Verner: The Free Exercise Clause prohibits the government from setting unemployment benefits eligibility requirements such that a person cannot properly observe key religious principles. supreme.justia.com⁠

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3. Wisconsin v. Yoder (1972)

Summary:

The Court ruled that compulsory school attendance laws could not force Amish children to attend public school beyond the eighth grade, recognizing the parents' rights to free exercise of religion.

Relevance:

This case underscores the rights of parents to direct the religious upbringing and education of their children. It directly supports the argument that ECS should allow the LifeWise Academy, as parents have the right to choose religious education for their children.

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Wisconsin v. Yoder, 406 U.S. 205 (1972) Wisconsin v. Yoder: Under the Free Exercise Clause of the First Amendment, a state law requiring that children attend school past eighth grade violates the parents' constitutional right to direct the religious upbringing of their children. supreme.justia.com⁠

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4. Employment Division v. Smith (1990)

Summary:

The Court ruled that generally applicable laws that incidentally burden religious practices do not violate the Free Exercise Clause.

Relevance:

While generally applicable laws are upheld, ECS’s prohibition of LifeWise is not a general law — but a specific policy targeting religious education. Therefore, it infringes on the Free Exercise Clause, especially when alternative secular programs like Second Step are allowed.

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Employment Division v. Smith, 494 U.S. 872 (1990) Employment Div. v. Smith.: A law is constitutional under the Free Exercise Clause if it is facially neutral and generally applied. supreme.justia.com⁠

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Conclusion

The Supreme Court cases discussed provide a robust legal foundation for our advocacy against the Second Step curriculum under the Establishment Clause and for the LifeWise Academy during school hours under the Free Exercise Clause. These precedents highlight the need for ECS to respect both the prohibition of religious endorsement and the protection of religious practices.

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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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