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The three liberal justices–Justice Stephen Breyer, Justice Sonia Sotomayor, and Justice Elena Kagan dissented from the decision that Maine was required to fund religious schools because the state subsidizes private schools where no public schools are available. The three of them concurred in a joint opinion and Justice Sotomayor wrote a separate dissent as well. Justice Breyer reviews the long history of separation of church and state and shows how deeply this principle is embedded is in our nation’s history, especially as it pertains to schools.

Justice Breyer shows that the many decisions of the Court about religious schools aimed to create a “course of constitutional neutrality” towards religion, neither supporting it nor hindering it. The founders were well aware of the long history of conflict and war in Europe, spurred by religious antagonisms. That is why they believed in separation of church and state and forbade any establishment of religion. While there has always been tension between the principle of freedom of religion and the prohibition of establishment of religion, he writes, neither principle is absolute; there has always been a “play in the joints” that enables both to survive intact.

Breyer writes:

This potential for religious strife is still with us. We are today a Nation with well over 100 different religious groups, from Free Will Baptist to African Methodist, Buddhist to Humanist. See Pew Research Center, America’s Changing Religious Landscape 21 (May 12, 2015). People in our country adhere to a vast array of beliefs, ideals, and philosophies. And with greater religious diversity comes greater risk of religiously based strife, conflict, and social division. The Religion Clauses were written in part to help avoid that disunion. As Thomas Jefferson, one of the leading drafters and proponents of those Clauses, wrote, “‘to compel a man to furnish contributions of money for the propagation of opinions which he disbelieves, is sinful and tyrannical.’ ” Everson, 330 U. S., at 13. And as James Madison, another drafter and proponent, said, compelled tax- payer sponsorship of religion “is itself a signal of persecution,” which “will destroy that moderation and harmony which the forbearance of our laws to intermeddle with Religion, has produced amongst its several sects.” Id., at 68– 69 (appendix to dissenting opinion of Rutledge, J.). To in- terpret the Clauses with these concerns in mind may help to further their original purpose of avoiding religious-based division.

He summarizes: In a word, to interpret the two Clauses as if they were joined at the hip will work against their basic purpose: to allow for an American society with practitioners of over 100 different religions, and those who do not practice religion at all, to live together without serious risk of religion-based social divisions.

Reviewing past decisions, he notes a problematic new note in this decision. Whereas the Court had ruled in the past that states “may” fund of specific functions of religious schools, in this decision, the majority ruled that they “must” provide funding for religious schools.

Justice Sotomayor added her own dissent, warning that this decision is a dangerous course for the Court, a course that began five years earlier. In the past, she wrote, religious excercise existed without sponsorship or interference by the state. But now the Court was requiring the state of Maine to engage in practices that many of its citizens might consider discrimination.

She writes: While purporting to protect against discrimination of one kind, the Court requires Maine to fund what many of its citizens believe to be discrimination of other kinds. See ante, at 16 (BREYER, J., dissenting) (summarizing Bangor Christian Schools’ and Temple Academy’s policies denying enrollment to students based on gender identity, sexual orientation, and religion).

What a difference five years makes. In 2017, I feared that the Court was “lead[ing] us . . . to a place where separation of church and state is a constitutional slogan, not a consti- tutional commitment.” Trinity Lutheran, 582 U. S., at ___ (dissenting opinion) (slip op., at 27). Today, the Court leads us to a place where separation of church and state becomes a constitutional violation. If a State cannot offer subsidies to its citizens without being required to fund religious exer- cise, any State that values its historic antiestablishment in- terests more than this Court does will have to curtail the support it offers to its citizens. With growing concern for where this Court will lead us next, I respectfully dissent.

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SUPREME COURT OF THE UNITED STATES

_________________

No. 20–1088 _________________

DAVID CARSON, AS PARENT AND NEXT FRIEND OF O. C., ET AL., PETITIONERS v. A. PENDER MAKIN

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT

[June 21, 2022]

JUSTICE BREYER, with whom JUSTICE KAGAN joins, and with whom JUSTICE SOTOMAYOR joins except as to Part I– B, dissenting.

The First Amendment begins by forbidding the govern- ment from “mak[ing] [any] law respecting an establishment of religion.” It next forbids them to make any law “prohib- iting the free exercise thereof.” The Court today pays al- most no attention to the words in the first Clause while giv- ing almost exclusive attention to the words in the second. The majority also fails to recognize the “ ‘play in the joints’ ” between the two Clauses. See Trinity Lutheran Church of ColumbiaInc. v. Comer, 582 U. S. ___, ___ (2017) (slip op., at 6). That “play” gives States some degree of legislative leeway. It sometimes allows a State to further antiestab- lishment interests by withholding aid from religious insti- tutions without violating the Constitution’s protections for the free exercise of religion. In my view, Maine’s nonsec- tarian requirement falls squarely within the scope of that constitutional leeway. I respectfully dissent.

I A

The First Amendment’s two Religion Clauses together provide that the government “shall make no law respecting an establishment of religion, or prohibiting the free exercise

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thereof.” Each Clause, linguistically speaking, is “cast in absolute terms.” Walz v. Tax Comm’n of City of New York, 397 U. S. 664, 668 (1970). The first Clause, the Establish- ment Clause, seems to bar all government “sponsorship, fi- nancial support, [or] active involvement . . . in religious ac- tivity,” while the second Clause, the Free Exercise Clause, seems to bar all “governmental restraint on religious prac- tice.” Id., at 668, 670. The apparently absolutist nature of these two prohibitions means that either Clause, “if ex- panded to a logical extreme, would tend to clash with the other.” Id., at 668–669. Because of this, we have said, the two Clauses “are frequently in tension,” Locke v. Davey, 540 U. S. 712, 718 (2004), and “often exert conflicting pres- sures” on government action, Cutter v. Wilkinson, 544 U. S. 709, 719 (2005).

On the one hand, the Free Exercise Clause “‘protect[s] religious observers against unequal treatment.’” Trinity Lutheran, 582 U. S., at ___ (slip op., at 6) (quoting Church of Lukumi Babalu AyeInc. v. Hialeah, 508 U. S. 520, 542 (1993); alteration in original). We have said that, in the education context, this means that States generally cannot “ba[r] religious schools from public benefits solely because of the religious character of the schools.” Espinoza v. Mon- tana Dept. of Revenue, 591 U. S. ___, ___ (2020) (slip op., at 9); see Trinity Lutheran, 582 U. S., at ___–___ (slip op., at 9–10).

On the other hand, the Establishment Clause “commands a separation of church and state.” Cutter, 544 U. S., at 719. A State cannot act to “aid one religion, aid all religions, or prefer one religion over another.” Everson v. Board of Ed. of Ewing, 330 U. S. 1, 15 (1947). This means that a State cannot use “its public school system to aid any or all reli- gious faiths or sects in the dissemination of their doctrines and ideals.” Illinois ex rel. McCollum v. Board of Ed. of School Dist. No. 71Champaign Cty., 333 U. S. 203, 211 (1948). Nor may a State “adopt programs or practices in its

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public schools . . . which ‘aid or oppose’ any religion.” Ep- person v. Arkansas, 393 U. S. 97, 106 (1968). “This prohibi- tion,” we have cautioned, “is absolute.” Ibid. See, e.g.McCollum, 333 U. S. 203 (no weekly religious teachings in public schools); Engel v. Vitale, 370 U. S. 421 (1962) (no prayers in public schools); School Dist. of Abington Town- ship v. Schempp, 374 U. S. 203 (1963) (no Bible readings in public schools); Epperson, 393 U. S. 97 (no religiously tai- lored curriculum in public schools); Wallace v. Jaffree, 472 U. S. 38 (1985) (no period of silence for meditation or prayer in public schools); Lee v. Weisman, 505 U. S. 577 (1992) (no prayers during public school graduations); Santa Fe Inde- pendent School Dist. v. Doe, 530 U. S. 290 (2000) (no pray- ers during public school football games).

Although the Religion Clauses are, in practice, often in tension, they nonetheless “express complementary values.” Cutter, 544 U. S., at 719. Together they attempt to chart a “course of constitutional neutrality” with respect to govern- ment and religion. Walz, 397 U. S., at 669. They were writ- ten to help create an American Nation free of the religious conflict that had long plagued European nations with “gov- ernmentally established religion[s].” Engel, 370 U. S., at 431. Through the Clauses, the Framers sought to avoid the “anguish, hardship and bitter strife” that resulted from the “union of Church and State” in those countries. Id., at 429; see also Committee for Public Ed. & Religious Liberty v. Nyquist, 413 U. S. 756, 795–796 (1973).

The Religion Clauses thus created a compromise in the form of religious freedom. They aspired to create a “benev- olent neutrality”—one which would “permit religious exer- cise to exist without sponsorship and without interference.” Walz, 397 U. S., at 669. “[T]he basic purpose of these pro- visions” was “to insure that no religion be sponsored or fa- vored, none commanded, and none inhibited.” Ibid. This religious freedom in effect meant that people “were entitled

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to worship God in their own way and to teach their chil- dren” in that way. C. Radcliffe, The Law & Its Compass 71 (1960). We have historically interpreted the Religion Clauses with these basic principles in mind. See, e.g.Nyquist, 413 U. S., at 771–772, 794–796; Walz, 397 U. S., at 668–670; Engel, 370 U. S., at 429–432.

And in applying these Clauses, we have often said that “there is room for play in the joints” between them. Walz, 397 U. S., at 669; see, e.g.Norwood v. Harrison, 413 U. S. 455, 469 (1973); Cutter, 544 U. S., at 719; Locke, 540 U. S., at 718–719; Trinity Lutheran, 582 U. S., at ___ (slip op., at 6); Espinoza, 591 U. S., at ___ (slip op., at 6). This doctrine reflects the fact that it may be difficult to determine in any particular case whether the Free Exercise Clause requires a State to fund the activities of a religious institution, or whether the Establishment Clause prohibits the State from doing so. Rather than attempting to draw a highly reticu- lated and complex free-exercise/establishment line that varies based on the specific circumstances of each state- funded program, we have provided general interpretive principles that apply uniformly in all Religion Clause cases. At the same time, we have made clear that States enjoy a degree of freedom to navigate the Clauses’ competing pro- hibitions. See, e.g.Cutter, 544 U. S., at 713, 719–720. This includes choosing not to fund certain religious activity where States have strong, establishment-related reasons for not doing so. See, e.g.Locke, 540 U. S., at 719–722. And, States have freedom to make this choice even when the Establishment Clause does not itself prohibit the State from funding that activity. Id., at 719 (“[T]here are some state actions permitted by the Establishment Clause but not required by the Free Exercise Clause”). The Court to- day nowhere mentions, and I fear effectively abandons, this longstanding doctrine.

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B

I have previously discussed my views of the relationship between the Religion Clauses and how I believe these Clauses should be interpreted to advance their goal of avoiding religious strife. See, e.g.Espinoza, 591 U. S., at ___–___ (dissenting opinion) (slip op., at 13–20); Van Orden v. Perry, 545 U. S. 677, 698–705 (2005) (opinion concurring in judgment); Zelman v. Simmons-Harris, 536 U. S. 639, 717–729 (2002) (dissenting opinion). Here I simply note the increased risk of religiously based social conflict when gov- ernment promotes religion in its public school system. “[T]he prescription of prayer and Bible reading in the public schools, during and as part of the curricular day, involving young impressionable children whose school attendance is statutorily compelled,” can “give rise to those very divisive influences and inhibitions of freedom which both religion clauses of the First Amendment” sought to prevent. Schempp, 374 U. S., at 307 (Goldberg, J., concurring).

This potential for religious strife is still with us. We are today a Nation with well over 100 different religious groups, from Free Will Baptist to African Methodist, Bud- dhist to Humanist. See Pew Research Center, America’s Changing Religious Landscape 21 (May 12, 2015). People in our country adhere to a vast array of beliefs, ideals, and philosophies. And with greater religious diversity comes greater risk of religiously based strife, conflict, and social division. The Religion Clauses were written in part to help avoid that disunion. As Thomas Jefferson, one of the lead- ing drafters and proponents of those Clauses, wrote, “‘to compel a man to furnish contributions of money for the propagation of opinions which he disbelieves, is sinful and tyrannical.’ ” Everson, 330 U. S., at 13. And as James Mad- ison, another drafter and proponent, said, compelled tax- payer sponsorship of religion “is itself a signal of persecu- tion,” which “will destroy that moderation and harmony

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which the forbearance of our laws to intermeddle with Re- ligion, has produced amongst its several sects.” Id., at 68– 69 (appendix to dissenting opinion of Rutledge, J.). To in- terpret the Clauses with these concerns in mind may help to further their original purpose of avoiding religious-based division.

I have also previously explained why I believe that a “rigid, bright-line” approach to the Religion Clauses—an approach without any leeway or “play in the joints”—will too often work against the Clauses’ underlying purposes. Espinoza, 591 U. S., at ___ (dissenting opinion) (slip op., at 18); see also Van Orden, 545 U. S., at 669–700 (opinion con- curring in judgment). “[G]overnment benefits come in many shapes and sizes.” Espinoza, 591 U. S., at ___ (slip op., at 16) (dissenting opinion). Not all state-funded pro- grams that have religious restrictions carry the same risk of creating social division and conflict. In my view, that risk can best be understood by considering the particular benefit at issue, along with the reasons for the particular religious restriction at issue. See ibid.Trinity Lutheran, 582 U. S., at ___ (slip op., at 1) (BREYER, J., concurring in judgment). Recognition that States enjoy a degree of constitutional lee- way allows States to enact laws sensitive to local circum- stances while also allowing this Court to consider those cir- cumstances in light of the basic values underlying the Religion Clauses.

In a word, to interpret the two Clauses as if they were joined at the hip will work against their basic purpose: to allow for an American society with practitioners of over 100 different religions, and those who do not practice religion at all, to live together without serious risk of religion-based social divisions.

II

The majority believes that the principles set forth in this Court’s earlier cases easily resolve this case. But they do

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not.
We have previously found, as the majority points out,

that “a neutral benefit program in which public funds flow to religious organizations through the independent choices of private benefit recipients does not offend the Establish- ment Clause.” Ante, at 10 (citing Zelman, 536 U. S., at 652– 653). We have thus concluded that a State may, consistent with the Establishment Clause, provide funding to religious schools through a general public funding program if the “government aid . . . reach[es] religious institutions only by way of the deliberate choices of . . . individual [aid] recipi- ents.” Id., at 652.

But the key word is “may.” We have never previously held what the Court holds today, namely, that a State must (not may) use state funds to pay for religious education as part of a tuition program designed to ensure the provision of free statewide public school education.

What happens once “may” becomes “must”? Does that transformation mean that a school district that pays for public schools must pay equivalent funds to parents who wish to send their children to religious schools? Does it mean that school districts that give vouchers for use at charter schools must pay equivalent funds to parents who wish to give their children a religious education? What other social benefits are there the State’s provision of which means—under the majority’s interpretation of the Free Ex- ercise Clause—that the State must pay parents for the re- ligious equivalent of the secular benefit provided? The con- cept of “play in the joints” means that courts need not, and should not, answer with “must” these questions that can more appropriately be answered with “may.”

The majority also asserts that “[t]he ‘unremarkable’ prin- ciples applied in Trinity Lutheran and Espinoza suffice to resolve this case.” Ante, at 9. Not so. The state-funded program at issue in Trinity Lutheran provided payment for

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resurfacing school playgrounds to make them safer for chil- dren. Any Establishment Clause concerns arising from providing money to religious schools for the creation of safer play yards are readily distinguishable from those raised by providing money to religious schools through the program at issue here—a tuition program designed to ensure that all children receive their constitutionally guaranteed right to a free public education. After all, cities and States normally pay for police forces, fire protection, paved streets, munici- pal transport, and hosts of other services that benefit churches as well as secular organizations. But paying the salary of a religious teacher as part of a public school tuition program is a different matter.

In addition, schools were excluded from the playground resurfacing program at issue in Trinity Lutheran because of the mere fact that they were “owned or controlled by a church, sect, or other religious entity.” 582 U. S., at ___ (slip op., at 2). Schools were thus disqualified from receiv- ing playground funds “solely because of their religious char- acter,” not because of the “religious uses of [the] funding” they would receive. Id., at ___, ___, n. 3 (slip op., at 10, 14, n. 3). Here, by contrast, a school’s “ ‘affiliation or associa- tion with a church or religious institution . . . is not dispos- itive’ ” of its ability to receive tuition funds. 979 F. 3d 21, 38 (CA1 2020) (quoting then-commissioner of Maine’s De- partment of Education). Instead, Maine chooses not to fund only those schools that “ ‘promot[e] the faith or belief system with which [the schools are] associated and/or presen[t] the [academic] material taught through the lens of this faith’ ”—i.e., schools that will use public money for religious purposes. Ibid. Maine thus excludes schools from its tui- tion program not because of the schools’ religious character but because the schools will use the funds to teach and pro- mote religious ideals.

For similar reasons, Espinoza does not resolve the pre- sent case. In Espinoza, Montana created “a scholarship

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program for students attending private schools.” 591 U. S., at ___ (slip op., at 1). But the State prohibited families from using the scholarship at any private school “ ‘owned or con- trolled in whole or in part by any church, religious sect, or denomination.’” Id., at ___ (slip op., at 3) (quoting Mont. Admin. Rule §42.4.802(1)(a) (2015)). As in Trinity Lu- theran, Montana denied funds to schools based “expressly on religious status and not religious use”; “[t]o be eligible” for scholarship funds, a school had to “divorce itself from any religious control or affiliation.” 591 U. S. at ___–___ (slip op., at 10–11). Here, again, Maine denies tuition money to schools not because of their religious affiliation, but because they will use state funds to promote religious views.

These distinctions are important. The very point of the Establishment Clause is to prevent the government from sponsoring religious activity itself, thereby favoring one re- ligion over another or favoring religion over nonreligion. See Engel, 370 U. S., at 430 (“Under [the Establishment Clause] . . . government in this country, be it state or fed- eral, is without power to prescribe by law . . . any program of governmentally sponsored religious activity”); Walz, 397 U. S., at 668 (“[F]or the men who wrote the Religion Clauses . . . the ‘establishment’ of a religion connoted . . . [any] ac- tive involvement of the sovereign in religious activity”);Everson, 330 U. S., at 15 (States may not “pass laws which aid one religion, aid all religions, or prefer one religion over another”). State funding of religious activity risks the very social conflict based upon religion that the Religion Clauses were designed to prevent. And, unlike the circumstances present in Trinity Lutheran and Espinoza, it is religious ac- tivity, not religious labels, that lies at the heart of this case.

III A

I turn now to consider the Maine program at issue here.

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Maine’s Constitution guarantees Maine’s children a free public education by requiring that all towns provide “for the support and maintenance of public schools.” Art. VIII, pt. 1, §1; see also Me. Rev. Stat. Ann., Tit. 20–A, §2(1) (2008). Because of the State’s rural geography and dispersed popu- lation, however, over half of Maine’s school districts do not operate public secondary schools. App. 70. To fulfill its con- stitutional promise, Maine created a program that provides some parents in these districts with a monetary grant to help them educate their children “at the public school or the approved private school of the parent’s choice.” Me. Rev. Stat. Ann., Tit. 20–A, §5204(4) (Cum. Supp. 2021). The pro- gram’s “function is limited to authorizing the provision of tuition subsidies to the parents of children who live within school [districts] that simply do not have the resources to operate a public school system, and whose children would otherwise not be given an opportunity to receive a free pub- lic education.” Hallissey v. School Administrative Dist. No. 77, 2000 ME 143, ¶16, 755 A. 2d 1068, 1073.

Under Maine law, an “approved” private school must be “nonsectarian.” §2951(2). A school fails to meet that re- quirement (and is deemed “sectarian”) only if it is both (1) “‘associated with a particular faith or belief system’” and also (2) “‘promotes the faith or belief system with which it is associated and/or presents the [academic] material taught through the lens of this faith.’ ” 979 F. 3d, at 38 (quoting Maine’s then-education commissioner). To deter- mine whether a school is sectarian, the “‘focus is on what the school teaches through its curriculum and related activ- ities, and how the material is presented.’ ” Ibid. (emphasis deleted). “ ‘[A]ffiliation or association with a church or reli- gious institution . . . is not dispositive’” of sectarian status.Ibid.

The two private religious schools at issue here satisfy both of these criteria. They are affiliated with a church or religious organization. See App. 80, 91. And they also teach

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students to accept particular religious beliefs and to engage in particular religious practices.

The first school, Bangor Christian, has “educational ob- jectives” that include “‘lead[ing] each unsaved student to trust Christ as his/her personal savior and then to follow Christ as Lord of his/her life,’” and “‘develop[ing] within each student a Christian world view and Christian philoso- phy of life.’ ” Id., at 84. Bangor Christian “does not believe there is any way to separate the religious instruction from the academic instruction.” Id., at 85. Academic instruction and religious instruction are thus “completely intertwined.” Ibid. Bangor Christian teaches in its social studies class, for example, “‘that God has ordained evangelism.’” Id., at 87. And in science class, students learn that atmospheric layers “‘are evidence of God’s good design.’” Id., at 89.

The second school, Temple Academy, similarly promotes religion through academics. Its “educational philosophy ‘is based on a thoroughly Christian and Biblical world view.’ ” Id., at 92. The school’s “objectives” include “‘foster[ing] within each student an attitude of love and reverence of the Bible as the infallible, inerrant, and authoritative Word of God.’” Ibid. Andtheschool’s“‘academicgrowth’objectives” include “‘provid[ing] a sound academic education in which the subjec[t] areas are taught from a Christian point of view,’” and “‘help[ing] every student develop a truly Chris- tian world view by integrating studies with the truths of Scripture.’ ” Id., at 93. Like Bangor Christian, Temple “pro- vides a ‘biblically-integrated education,’ which means that the Bible is used in every subject that is taught.” Id., at 96. In mathematics classes, for example, students learn that “a creator designed the universe such that ‘one plus one is al- ways going to be two.’” Ibid.

The differences between this kind of education and a purely civic, public education are important. “The religious education and formation of students is the very reason for the existence of most private religious schools.” Our Lady

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of Guadalupe School v. Morrissey-Berru, 591 U. S. ___, ___ (2020) (slip op., at 2). “[E]ducating young people in their faith, inculcating its teachings, and training them to live their faith,” we have said, “are responsibilities that lie at the very core of the mission of a private religious school.” Id., at ___ (slip op., at 18). Indeed, we have recognized that the “connection that religious institutions draw between their central purpose and educating the young in the faith” is so “close” that teachers employed at such schools act as “ministers” for purposes of the First Amendment. Id., at ___, ___ (slip op., at 2, 21); see also Hosanna-Tabor Evan- gelical Lutheran Church and School v. EEOC, 565 U. S. 171 (2012).

By contrast, public schools, including those in Maine, seek first and foremost to provide a primarily civic educa- tion. We have said that, in doing so, they comprise “a most vital civic institution for the preservation of a democratic system of government, and . . . the primary vehicle for transmitting the values on which our society rests.” Plyler v. Doe, 457 U. S. 202, 221 (1982) (citation and internal quo- tation marks omitted). To play that role effectively, public schools are religiously neutral, neither disparaging nor pro- moting any one particular system of religious beliefs. We accordingly have, as explained above, consistently required public school education to be free from religious affiliation or indoctrination. Cf. Edwards v. Aguillard, 482 U. S. 578, 583–584 (1987) (“The Court has been particularly vigilant in monitoring compliance with the Establishment Clause in elementary and secondary [public] schools”).

Maine legislators who endorsed the State’s nonsectarian requirement recognized these differences between public and religious education. They did not want Maine taxpay- ers to finance, through a tuition program designed to en- sure the provision of free public education, schools that would use state money for teaching religious practices. See, e.g., App. 104 (Maine representative stating that “[f]rom a

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public policy position, we must believe that a religiously neutral classroom is the best if funded by public dollars”); id., at 106 (Maine senator asserting that the State’s “lim- ited [tax] dollars for schools” should be spent on those “that are non-religious and that are neutral on religion”). Under- lying these views is the belief that the Establishment Clause seeks government neutrality. And the legislators thought that government payment for this kind of religious education would be antithetical to the religiously neutral education that the Establishment Clause requires in public schools. Cf. Epperson, 393 U. S., at 106; McCollum, 333 U. S., at 211. Maine’s nonsectarian requirement, they be- lieved, furthered the State’s antiestablishment interests in not promoting religion in its public school system; the re- quirement prevented public funds—funds allocated to en- sure that all children receive their constitutional right to a free public education—from being given to schools that would use the funds to promote religion.

In the majority’s view, the fact that private individuals, not Maine itself, choose to spend the State’s money on reli- gious education saves Maine’s program from Establishment Clause condemnation. But that fact, as I have said, simply permits Maine to route funds to religious schools. See, e.g.Zelman, 536 U. S., at 652. It does not require Maine to spend its money in that way. That is because, as explained above, this Court has long followed a legal doctrine that gives States flexibility to navigate the tension between the two Religion Clauses. Supra, at 4. This doctrine “recog- nize[s] that there is ‘play in the joints’ between what the Establishment Clause permits and the Free Exercise Clause compels.” Trinity Lutheran, 582 U. S., at ___ (slip op., at 6) (quoting Locke, 540 U. S., at 718). This wiggle- room means that “[t]he course of constitutional neutrality in this area cannot be an absolutely straight line.” Walz, 397 U. S., at 669. And in walking this line of government

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neutrality, States must have “some space for legislative ac- tion neither compelled by the Free Exercise Clause nor pro- hibited by the Establishment Clause,” Cutter, 544 U. S., at 719, in which they can navigate the tension created by the Clauses and consider their own interests in light of the Clauses’ competing prohibitions. See, e.g.Walz, 397 U. S., at 669.

Nothing in our Free Exercise Clause cases compels Maine to give tuition aid to private schools that will use the funds to provide a religious education. As explained above, this Court’s decisions in Trinity Lutheran and Espinoza prohibit States from denying aid to religious schools solely because of a school’s religious status—that is, its affiliation with or control by a religious organization. Supra, at 7–9. But we have never said that the Free Exercise Clause prohibits States from withholding funds because of the religious use to which the money will be put. Cf. Trinity Lutheran, 582 U. S., at ___ (slip op., at 12). To the contrary, we upheld in Locke a State’s decision to deny public funding to a recipient “because of what he proposed to do” with the money, when what he proposed to do was to “use the funds to prepare for the ministry.” Trinity Lutheran, 582 U. S., at ___ (slip op., at 12); see also Espinoza, 591 U. S., at ___ (slip op., at 13) (characterizing Locke similarly). Maine does not refuse to pay tuition at private schools because of religious status or affiliation. The State only denies funding to schools that will use the money to promote religious beliefs through a religiously integrated education—an education that, in Maine’s view, is not a replacement for a civic-focused public education. See 979 F. 3d, at 38. This makes Maine’s deci- sion to withhold public funds more akin to the state decision that we upheld in Locke, and unlike the withholdings that we invalidated in Trinity Lutheran and Espinoza.

The Free Exercise Clause thus does not require Maine to fund, through its tuition program, schools that will use pub-

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BREYER, J., dissenting

lic money to promote religion. And considering the Estab- lishment Clause concerns underlying the program, Maine’s decision not to fund such schools falls squarely within the play in the joints between those two Clauses. Maine has promised all children within the State the right to receive a free public education. In fulfilling this promise, Maine en- deavors to provide children the religiously neutral educa- tion required in public school systems. And that, in signif- icant part, reflects the State’s antiestablishment interests in avoiding spending public money to support what is es- sentially religious activity. The Religion Clauses give Maine the ability, and flexibility, to make this choice.

B

In my view, Maine’s nonsectarian requirement is also constitutional because it supports, rather than undermines, the Religion Clauses’ goal of avoiding religious strife. Forc- ing Maine to fund schools that provide the sort of religiously integrated education offered by Bangor Christian and Tem- ple Academy creates a similar potential for religious strife as that raised by promoting religion in public schools. It may appear to some that the State favors a particular reli- gion over others, or favors religion over nonreligion. Mem- bers of minority religions, with too few adherents to estab- lish schools, may see injustice in the fact that only those belonging to more popular religions can use state money for religious education. Taxpayers may be upset at having to finance the propagation of religious beliefs that they do not share and with which they disagree. And parents in school districts that have a public secondary school may feel indig- nant that only some families in the State—those families in the more rural districts without public schools—have the opportunity to give their children a Maine-funded religious education.

Maine legislators who endorsed the State’s nonsectarian requirement understood this potential for social conflict.

16 CARSON v. MAKIN BREYER, J., dissenting

They recognized the important rights that religious schools have to create the sort of religiously inspired curriculum that Bangor Christian and Temple Academy teach. Legis- lators also recognized that these private schools make reli- giously based enrollment and hiring decisions. Bangor Christian and Temple Academy, for example, have admis- sions policies that allow them to deny enrollment to stu- dents based on gender, gender-identity, sexual orientation, and religion, and both schools require their teachers to be Born Again Christians. App. 82–83, 89, 93, 98. Legislators did not want Maine taxpayers to pay for these religiously based practices—practices not universally endorsed by all citizens of the State—for fear that doing so would cause a significant number of Maine citizens discomfort or displeas- ure. See, e.g.id., at 101 (Maine representative noting that “private religious schools discriminate against citizens of the State of Maine,” such as by “not hir[ing] individuals whose beliefs are not consistent with the school’s religious teachings,” and asserting that “it is fundamentally wrong for us to fund” such discrimination); id., at 104 (Maine rep- resentative stating that “the people of Maine” should not use “public money” to advance “their religious pursuits,” and that “discrimination in religious institutions” should not be funded “with my dollar”); id., at 107 (Maine senator expressing concern that “public funds could be used to teach intolerant religious views”). The nonsectarian requirement helped avoid this conflict—the precise kind of social conflict that the Religion Clauses themselves sought to avoid.

Maine’s nonsectarian requirement also serves to avoid re- ligious strife between the State and the religious schools. Given that Maine is funding the schools as part of its effort to ensure that all children receive the basic public education to which they are entitled, Maine has an interest in ensur- ing that the education provided at these schools meets cer- tain curriculum standards. Religious schools, on the other

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hand, have an interest in teaching a curriculum that ad- vances the tenets of their religion. And the schools are of course entitled to teach subjects in the way that best re- flects their religious beliefs. But the State may disagree with the particular manner in which the schools have de- cided that these subjects should be taught.

This is a situation ripe for conflict, as it forces Maine into the position of evaluating the adequacy or appropriateness of the schools’ religiously inspired curriculum. Maine does not want this role. As one legislator explained, one of the reasons for the nonsectarian requirement was that “[g]overnment officials cannot, and should not, review the religious teachings of religious schools.” Ibid. Another leg- islator cautioned that the State would be unable to “recon- cile” the curriculum of “private religious schools who teach religion in the classroom” with Maine “standards . . . that do not include any sort of religion in them.” Id., at 102.

Nor do the schools want Maine in this role. Bangor Chris- tian asserted that it would only consider accepting public funds if it “did not have to make any changes in how it op- erates.” Id., at 90. Temple Academy similarly stated that it would only accept state money if it had “in writing that the school would not have to alter its admissions standards, hiring standards, or curriculum.” Id., at 99. The nonsec- tarian requirement ensures that Maine is not pitted against private religious schools in these battles over curriculum or operations, thereby avoiding the social strife resulting from this state-versus-religion confrontation. By invalidating the nonsectarian requirement, the majority today subjects the State, the schools, and the people of Maine to social con- flict of a kind that they, and the Religion Clauses, sought to prevent.

I emphasize the problems that may arise out of today’s decision because they reinforce my belief that the Religion Clauses do not require Maine to pay for a religious educa- tion simply because, in some rural areas, the State will help

18 CARSON v. MAKIN BREYER, J., dissenting

parents pay for a secular education. After all, the Estab- lishment Clause forbids a State from paying for the practice of religion itself. And state neutrality in respect to the teaching of the practice of religion lies at the heart of this Clause. See, e.g.Locke, 540 U. S., at 721–722 (noting that there are “few areas in which a State’s antiestablishment interests come more into play” than state funding of minis- ters who will “lead [their] congregation[s]” in “religious en- deavor[s]”). There is no meaningful difference between a State’s payment of the salary of a religious minister and the salary of someone who will teach the practice of religion to a person’s children. At bottom, there is almost no area “as central to religious belief as the shaping, through primary education, of the next generation’s minds and spirits.” Zel- man, 536 U. S., at 725 (BREYER, J., dissenting). The Estab- lishment Clause was intended to keep the State out of this area.

***

Maine wishes to provide children within the State with a secular, public education. This wish embodies, in signifi- cant part, the constitutional need to avoid spending public money to support what is essentially the teaching and prac- tice of religion. That need is reinforced by the fact that we are today a Nation of more than 330 million people who as- cribe to over 100 different religions. In that context, state neutrality with respect to religion is particularly important. The Religion Clauses give Maine the right to honor that neutrality by choosing not to fund religious schools as part of its public school tuition program. I believe the majority is wrong to hold the contrary. And with respect, I dissent.

Cite as: 596 U. S. ____ (2022) 1 SOTOMAYOR, J., dissenting

SUPREME COURT OF THE UNITED STATES

_________________

No. 20–1088 _________________

DAVID CARSON, AS PARENT AND NEXT FRIEND OF O. C., ET AL., PETITIONERS v. A. PENDER MAKIN

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT

[June 21, 2022]

JUSTICE SOTOMAYOR, dissenting.

This Court continues to dismantle the wall of separation between church and state that the Framers fought to build. JUSTICE BREYER explains why the Court’s analysis falters on its own terms, and I join all but Part I–B of his dissent. I write separately to add three points.

First, this Court should not have started down this path five years ago. See Trinity Lutheran Church of Columbia, Inc. v. Comer, 582 U. S. ___ (2017). Before Trinity Lu- theran, it was well established that “both the United States and state constitutions embody distinct views” on “the sub- ject of religion”—“in favor of free exercise, but opposed to establishment”—“that find no counterpart” with respect to other constitutional rights. Locke v. Davey, 540 U. S. 712, 721 (2004). Because of this tension, the Court recognized “ ‘room for play in the joints’ between” the Religion Clauses, with “some state actions permitted by the Establishment Clause but not required by the Free Exercise Clause.” Id., at 718–719 (quoting Walz v. Tax Comm’n of City of New York, 397 U. S. 664, 669 (1970)); see ante, at 4 (BREYER, J., dissenting). Using this flexibility, and consistent with a rich historical tradition, see Trinity Lutheran, 582 U. S., at ___–___ (SOTOMAYOR, J., dissenting) (slip op., at 11–16), States and the Federal Government could decline to fund

2 CARSON v. MAKIN SOTOMAYOR, J., dissenting

religious institutions. Moreover, the Court for many dec- ades understood the Establishment Clause to prohibit gov- ernment from funding religious exercise.*

Over time, the Court eroded these principles in certain respects. See, e.g., Zelman v. Simmons-Harris, 536 U. S. 639, 662 (2002) (allowing government funds to flow to reli- gious schools if private individuals selected the benefiting schools; the government program was “entirely neutral with respect to religion”; and families enjoyed a “genuine choice among options public and private, secular and reli- gious”). Nevertheless, the space between the Clauses con- tinued to afford governments “some room to recognize the unique status of religious entities and to single them out on that basis for exclusion from otherwise generally applicable laws.” Trinity Lutheran, 582 U. S., at ___ (SOTOMAYOR, J., dissenting) (slip op., at 9).

Trinity Lutheran veered sharply away from that under- standing. After assuming away an Establishment Clause violation, the Court revolutionized Free Exercise doctrine by equating a State’s decision not to fund a religious organ- ization with presumptively unconstitutional discrimination on the basis of religious status. See id., at ___–___ (slip op., at 10–11). A plurality, however, limited the Court’s deci- sion to “express discrimination based on religious identity” (i.e., status), not “religious uses of funding.” Id., at ___, n. 3 (slip op., at 14, n. 3). In other words, a State was barred

——————
* See, e.g., Everson v. Board of Ed. of Ewing, 330 U. S. 1, 16 (1947) (“No

tax in any amount, large or small, can be levied to support any religious activities or institutions . . . ”); Agostini v. Felton, 521 U. S. 203, 222–223 (1997) (observing that government aid that impermissibly “advanc[ed] . . . religion” was constitutionally barred); Mitchell v. Helms, 530 U. S. 793, 840 (2000) (O’Connor, J., concurring in judgment) (“[O]ur decisions provide no precedent for the use of public funds to finance religious ac- tivities” (internal quotation marks omitted)); see also Rosenberger v. Rec- tor and Visitors of Univ. of Va., 515 U. S. 819, 875–876 (1995) (Souter, J., dissenting) (chronicling cases).

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SOTOMAYOR, J., dissenting

from withholding funding from a religious entity “solely be- cause of its religious character,” id., at ___ (opinion of the Court) (slip op., at 14), but retained authority to do so on the basis that the funding would be put to religious uses. Two Terms ago, the Court reprised and extended Trinity Lutheran’s error to hold that a State could not limit a pri- vate-school voucher program to secular schools. Espinoza v. Montana Dept. of Revenue, 591 U. S. ___, ___ (2020) (slip op., at 9). The Court, however, again refrained from extend- ing Trinity Lutheran from funding restrictions based on re- ligious status to those based on religious uses. Espinoza, 591 U. S., at ___–___ (2020) (slip op., at 9–12).

As JUSTICE BREYER explains, see ante, at 8–9, this status- use distinction readily distinguishes this case from Trinity Lutheran and Espinoza. I warned in Trinity Lutheran, however, that the Court’s analysis could “be manipulated to call for a similar fate for lines drawn on the basis of reli- gious use.” 582 U. S., at ___, n. 14 (dissenting opinion) (slip op., at 25, n. 14). That fear has come to fruition: The Court now holds for the first time that “any status-use distinction” is immaterial in both “theory” and “practice.” Ante, at 17. It reaches that conclusion by embracing arguments from prior separate writings and ignoring decades of precedent affording governments flexibility in navigating the tension between the Religion Clauses. As a result, in just a few years, the Court has upended constitutional doctrine, shift- ing from a rule that permits States to decline to fund reli- gious organizations to one that requires States in many cir- cumstances to subsidize religious indoctrination with taxpayer dollars.

Second, the consequences of the Court’s rapid transfor- mation of the Religion Clauses must not be understated. From a doctrinal perspective, the Court’s failure to apply the play-in-the-joints principle here, see ante, at 13–14 (BREYER, J., dissenting), leaves one to wonder what, if any- thing, is left of it. The Court’s increasingly expansive view

4 CARSON v. MAKIN SOTOMAYOR, J., dissenting

of the Free Exercise Clause risks swallowing the space be- tween the Religion Clauses that once “permit religious exercise to exist without sponsorship and without interfer- ence.” Walz, 397 U. S., at 669.

From a practical perspective, today’s decision directs the State of Maine (and, by extension, its taxpaying citizens) to subsidize institutions that undisputedly engage in religious instruction. See ante, at 10–11 (BREYER, J., dissenting). In addition, while purporting to protect against discrimination of one kind, the Court requires Maine to fund what many of its citizens believe to be discrimination of other kinds. See ante, at 16 (BREYER, J., dissenting) (summarizing Bangor Christian Schools’ and Temple Academy’s policies denying enrollment to students based on gender identity, sexual ori- entation, and religion). The upshot is that Maine must choose between giving subsidies to its residents or refrain- ing from financing religious teaching and practices.

Finally, the Court’s decision is especially perverse be- cause the benefit at issue is the public education to which all of Maine’s children are entitled under the State Consti- tution. As this Court has long recognized, the Establish- ment Clause requires that public education be secular and neutral as to religion. See ante, at 2–3, 12 (BREYER, J., dis- senting) (collecting cases). The Court avoids this framing of Maine’s benefit because, it says, “Maine has decided not to operate schools of its own, but instead to offer tuition as- sistance that parents may direct to the public or private schools of their choice.” Ante, at 14. In fact, any such “deci[sion],” ibid., was forced upon Maine by “the realities of remote geography and low population density,” ante, at 2, which render it impracticable for the State to operate its own schools in many communities.

The Court’s analysis does leave some options open to Maine. For example, under state law, school administra- tive units (SAUs) that cannot feasibly operate their own

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SOTOMAYOR, J., dissenting

schools may contract directly with a public school in an- other SAU, or with an approved private school, to educate their students. See Me. Rev. Stat. Ann., Tit. 20–A, §§2701, 2702 (2008). I do not understand today’s decision to man- date that SAUs contract directly with schools that teach re- ligion, which would go beyond Zelman’s private-choice doc- trine and blatantly violate the Establishment Clause. Nonetheless, it is irrational for this Court to hold that the Free Exercise Clause bars Maine from giving money to par- ents to fund the only type of education the State may pro- vide consistent with the Establishment Clause: a reli- giously neutral one. Nothing in the Constitution requires today’s result.

***

What a difference five years makes. In 2017, I feared that the Court was “lead[ing] us . . . to a place where separation of church and state is a constitutional slogan, not a consti- tutional commitment.” Trinity Lutheran, 582 U. S., at ___ (dissenting opinion) (slip op., at 27). Today, the Court leads us to a place where separation of church and state becomes a constitutional violation. If a State cannot offer subsidies to its citizens without being required to fund religious exer- cise, any State that values its historic antiestablishment in- terests more than this Court does will have to curtail the support it offers to its citizens. With growing concern for where this Court will lead us next, I respectfully dissent.

The United States Supreme Court released a 6-3 decision called Carson v. Makin that reverses many decades of precedent. The decision requires the state of Maine to provide public funding to religious schools because the state funds private schools in areas where population is so sparse that public schools are not available.

The two religious schools at issue are Temple Academy in Waterville, Maine, and Bangor Christian Schools. Temple Academy expects its teachers to “integrate biblical principles with their teaching in every subject” and “to spread the word of Christianity.” Bangor Christian Schools seeks to develop “within each student a Christian worldview and Christian philosophy of life.” Both schools deny admission to students based on their gender, gender identity, sexual orientation, and religion. Both schools require their teachers to be born-again teachers.

Why should the state of Maine or any other state be required to fund schools that practice discrimination and violate federal civil rights laws? Why should people who do not share the religious ideas of these schools be compelled to underwrite them? Why should a Catholic or a Buddhist or a Jew or a Muslim or an atheist pay taxes for schools that will exclude their own children and will refuse to hire them or their children as teachers?

Although the conservative majority likes to claim its loyalty to an “Originalist” interpretation of the Constitution, this decision cannot be called “Originalist.” The founders were very clear about their commitment to separation of religion and the state. They were keenly aware of the centuries of bloodshed in Europe that religious strife caused. They wrote the First Amendment to the Constitution to protect freedom of religion, but also to prevent any establishment of religion by government. These two phrases have often been in tension, and the Court has typically balanced them so that everyone is free to practice their religion but without government subsidy. There is literally nothing in the Constitution that supports this majority decision. It is hard to imagine a Supreme Court decision that departs more radically from the explicit, unambiguous statements of the Founding Fathers.

Some religious groups have fought for many decades to gain government funding for their schools, which are used to indoctrinate children into the tenets of their religion. It is somewhat ironic that at the very time that so many conservatives are criticizing public schools and teachers for “indoctrinating” their children into liberal views about racism and gender, they would nonetheless enthusiastically endorse the idea of public subsidy for religious organizations that explicitly indoctrinate children into their views.

There is a simple solution to the issue at hand: Maine and other states that fund private schools should stop doing so. They should use public funds only to support public schools. Public schools should be subject to all state and federal laws governing civil rights, health, and safety. Any private or religious schools that accept public funding under this ruling should be required to comply with the same state and federal laws that apply to public schools.

Here is the full decision.

I will separately post the dissents by Justice Breyer and another by Justice Sonia Sotomayer, which of course are included in the full decision.

Dean Obeidallah, a regular contributor to CNN, describes the Texas GOP’s defiant rejection of democracy. In an earlier post, I pointed out that the state convention booed Senator Jon Cornyn for daring to negotiate a bipartisan gun control deal (which did not include any of President Biden’s demands). That was the mildest of their actions.

He writes:

CNN) – Disturbing video from the Texas Republican Convention this weekend shows convention-goers mocking GOP Rep. Dan Crenshaw — a Navy SEAL veteran who lost his right eye to a bomb in Afghanistan — with the term “eye patch McCain.”

Fox News’ Tucker Carlson coined the derisive nickname after the Texas lawmaker dared to express support for beleaguered Ukraine following Russia’s barbaric attack on it.

But apparently even more heinous in the eyes of some attendees is that Crenshaw rejected former President Donald Trump’s claims that the 2020 election was stolen. One man wearing a red “Make America Great Again” hat can be seen yelling in an online video, “Dan Crenshaw is a traitor!” and “He needs to be hung for treason!”

As despicable as the behavior toward Crenshaw was, even more alarming were the actions taken by the Texas GOP and the convention’s 5,000-plus delegates.

The gathering rejected the outcome of a democratic election, supported bigotry toward the LGBTQ community and imposed far-right religious beliefs on others by seeking to have them enshrined into law. And that wasn’t half of it.

In fact, the convention showed us one thing: Texas Republicans are no longer hiding their extremism. Instead, they are openly embracing it.

Even before the opening gavel, they gave us a glimpse of the party’s extremism in the Lone Star State by banning the Log Cabin Republicans from setting up a booth at the convention.

Texas Republican Party Chairman Matt Rinaldi cast the deciding vote on the move to bar the group that has advocated for LGBTQ Republicans for decades. “I think it’s inappropriate given the state of our nation right now for us to play sexual identity politics,” Rinaldi told the Fort Worth Star-Telegram.

Once it formally got underway, the convention took a number of appalling and un-American actions. First, delegates approved a measure declaring that President Joe Biden “was not legitimately elected.” In short, the Texas GOP — like Trump himself — is embracing a lie because it’s unhappy with the election results. Put more bluntly, the Texas GOP voted to reject American democracy.

Republican delegates also booed John Cornyn, the senior US senator from Texas, at the convention Friday because of the Republican lawmaker’s role leading negotiations to reach a Senate deal on a bill to stem gun violence. Those legislative efforts follow last month’s horrific shooting that claimed the lives of 19 schoolchildren and two teachers in Uvalde, Texas.

The platform approved at the convention called for repealing or nullifying gun laws already in place, such as the Gun Control Act of 1968, which prevents felons and other dangerous people from being able to purchase a gun legally. Apparently, the Texas GOP believes that even dangerous people should have a constitutionally protected right to buy a gun.

The Texas GOP platform also embraced ramping up anti-abortion rhetoric in public schools. For example, the platform states that “Texas students should learn about the Humanity of the Preborn Child, including … that life begins at fertilization.” It even seeks to force students to watch “a live ultrasound” and for high-schoolers to read an anti-abortion booklet that critics say “includes scientifically unsupported claims and shames women seeking abortion care,” according to The Texas Tribune.

It sounds like the curriculum that you might find in a theocratic government such as the Taliban — not one in the United States funded by taxpayer dollars. But the GOP in large swaths of this country is no longer hesitant to support laws to impose its religious beliefs — as we see with measures some Republicans champion that would totally ban abortion. The GOP convention’s document additionally urges officials “not to infringe on Texas school students’ and staffs’ rights to pray and engage in religious speech.”

The Texas GOP platform also does its best to demonize those in the transgender community. It describes transgender people as suffering from “a genuine and extremely rare mental health condition.” And it sees sexual reassignment surgery as a form of medical malpractice.

The platform takes aim at gay Americans as well with the statement that homosexuality is “an abnormal lifestyle choice.” Instructively, the Texas GOP platform did not include such language in 2018 and 2020.

This platform gives us a glimpse into the views of the Republican base on key issues that in turn will pressure GOP elected officials in Texas — and possibly beyond the state — to adopt similarly extreme positions or run the risk of a primary challenge from an even more extreme Republican.

What caused this move to the far right? Brandon Rottinghaus, a political scientist at the University of Houston, told The Texas Tribune about the state GOP’s new extreme platform, “Donald Trump radicalized the party and accelerated the demands from the base.” He added alarmingly, “There simply aren’t limits now on what the base might ask for.”

I agree — in part. I don’t think Trump radicalized the base — rather he simply gave people permission to be who they always wanted to be.

But I agree with Rottinghaus that there are now no limits for what the GOP base might seek — be it rejecting election results it doesn’t agree with to enacting more laws based on extreme religious beliefs. And that should deeply alarm every American who wants to live in a democratic republic.

The convention also issued a call to repeal the 1965 Voting Rights Act, which guaranteed the right to vote for every citizen of voting age.

The only thing the Texas GOP neglected to do was pass a resolution congratulating the shooter at Uvalde for exercising his “God-given right” to use his AR15 as he saw fit.

Donald Trump, a man without any religious faith or moral principle, addressed an evangelical religious convocation called “Faith and Freedom” in Tennessee. He used the occasion to ridicule the Republicans who did not support his attempt to demolish the rule of law and the Constitution so he could have a second term in office. He is a very sore loser.

NASHVILLE — Former president Donald Trump used an evangelical conference here to ridicule former vice president Mike Pence for upholding the Constitution on Jan. 6, 2021, choosing an audience that represents Pence’s political base as a venue to attempt to undermine him.


“Mike Pence had a chance to be great. He had a chance to be historic,” Trump said in his first remarks about his onetime governing partner amid Jan. 6 committee hearings revealing the intense pressure Pence withstood in deciding to go forward with his constitutional role certifying the election.

“Mike did not have the courage to act.” He added: “Mike was afraid of whatever he was afraid of.”
Trump also referred to Pence, who did not attend the conference, as a “human conveyor belt” for his role in moving the election process forward, saying that he had considered labeling him as a “robot.”

Trump’s own aides have testified they told the president it would not be constitutional for Pence to move to overturn the election.

Trump also attacked Adam Kinzinger, calling him a crybaby. Kinzinger responded far too generously on Twitter.

As we watched the January 6 Commission and its interviews, we have seen the connecting of the dots in the most audacious effort in our history to overturn the results of a free and fair election. We have seen overwhelming evidence of a conspiracy to destroy our democracy and our Constitution. 2020 was not a close election. Trump could not bear the thought, the reality that he lost. He lost. He is a loser.

Among the many devious, dishonest plots to stop the certification of Joe Biden’s election, the following story may be the worst, in my judgment, although there are surely other contenders.

Michael Kranish of The Washington Post told the story of Trump’s attempt to appoint a new Attorney General in early January 2021 who would send letters to several states informing them that their electors should be withdrawn due to serious concerns about election fraud. Trump met with an official, Jeffrey Clark, in the Justice Department who wanted to be appointed Attorney General and stop the certification of Biden. Clark’s superiors said he was totally unqualified and threatened to resign en masse if Trump elevated him. Faced with the threat of a mass resignation of the top officials at the Justice Department, his own appointees, Trump backed down.

Three days before Congress was slated to certify the 2020 presidential election, a little-known Justice Department official named Jeffrey Clark rushed to meet President Donald Trump in the Oval Office to discuss a last-ditch attempt to reverse the results.


Clark, an environmental lawyer by trade, had outlined a plan in a letter he wanted to send to the leaders of key states Joe Biden won. It said that the Justice Department had “identified significant concerns” about the vote and that the states should consider sending “a separate slate of electors supporting Donald J. Trump” for Congress to approve.


In fact, Clark’s bosses had warned there was not evidence to overturn the election and had rejected his letter days earlier. Now they learned Clark was about to meet with Trump. Acting attorney general Jeffrey Rosen tracked down his deputy, Richard Donoghue, who had been walking on the Mall in muddy jeans and an Army T-shirt. There was no time to change. They raced to the Oval Office.

As Rosen and Donoghue listened, Clark told Trump that he would send the letter if the president named him attorney general.


“History is calling,” Clark told the president, according to a deposition from Donoghue excerpted in a recent court filing. “This is our opportunity. We can get this done.”

Donoghue urged Trump not to put Clark in charge, calling him “not competent” and warning of “mass resignations” by Justice Department officials if he became the nation’s top law enforcement official, according to Donoghue’s account.

“What happens if, within 48 hours, we have hundreds of resignations from your Justice Department because of your actions?” Donoghue said he asked Trump. “What does that say about your leadership?”


Clark’s letter and his Oval Office meeting set off one of the tensest chapters during Trump’s effort to overturn the election, which culminated three days later with rioters storming the U.S. Capitol. His plan could have decapitated the Justice Department leadership and could have overturned the election.


Clark’s actions have been the focus of a Senate Judiciary Committee investigation and an ongoing probe by the Justice Department’s inspector general, and now are expected to be closely examined during June hearings by the House committee investigating the insurrection of Jan. 6, 2021.


After the New York Times reported in January 2021 about Clark’s actions, he said he engaged in a “candid discussion of options and pros and cons with the president,” denied that he had a plan to oust Rosen, and criticized others in the meeting for talking publicly and “distorting” the discussion.
Now, however, key witnesses have provided Congress with a fuller account of Clark’s actions, including new details about the confrontation that took place in the Jan. 3 Oval Office meeting, which lasted nearly three hours.


A reconstruction of the events by The Washington Post, based on the court filings, depositions, Senate and House reports, previously undisclosed emails, and interviews with knowledgeable government officials, shows how close the country came to crisis three days before the insurrection.

The evidence, which fills in crucial details about Clark’s efforts, includes an email showing he was sent a draft of a letter outlining a plan to try to overturn the election by a just-arrived Justice Department official who had once written a book claiming President Barack Obama planned to “subvert the Constitution.”

But larger mysteries could still be solved at an upcoming Jan. 6 committee hearing slated to examine Clark’s actions, including the crucial question of whether Clark and his allies were acting on their own initiative — or whether they were one piece of a larger, well-planned effort to keep Trump in power. That question gets to the heart of the committee’s professed mission: proving there was a “coordinated, multi-step effort to overturn the 2020 presidential election.”
Clark, 55, and his lawyer, Harry MacDougald, declined to comment.


The House committee unanimously voted to hold Clark in contempt of Congress after he declined in December to answer most questions on grounds that his interactions with Trump were privileged. But Clark later appeared before the committee and asserted his Fifth Amendment right against self-incrimination, CNN reported; his testimony from that appearance has not been released.


Sen. Sheldon Whitehouse (D-R.I.), who participated in the Judiciary Committee’s investigation, said investigators should key in on whether Clark was working on behalf of others not yet identified.
“It certainly could be a symptom of a much larger and more coherent plan than has currently been disclosed,” Whitehouse said. Clark “does not appear to have elections expertise or experience, which raises the question, did he really sit down at his computer and type it out or does somebody produce it for him?
…”

Trump met in the White House with Clark and the top officials in the Justice Department, including Jeffrey Rosen and Richard Donoghue. Trump told them of his plan to make Clark the Attorney General. They were outraged.

Trump repeatedly went after Rosen and Donoghue, saying they hadn’t pursued voter fraud allegations.


“You two,” Trump said, pointing to the two top Justice Department officials. “You two haven’t done anything. You two don’t care. You haven’t taken appropriate actions. Everyone tells me I should fire you.”


Trump continually circled back to the idea of replacing Rosen with Clark.


“What do I have to lose?” the president asked, according to Donoghue.


“Mr. President, you have a great deal to lose,” Donoghue said he responded. “Is this really how you want your administration to end? You’re going to hurt the country, you’re going to hurt the department, you’re going to hurt yourself, with people grasping at straws on these desperate theories about election fraud, and is this really in anyone’s best interest?”


Donoghue warned Trump that putting Clark in charge would be likely to lead to mass resignations at the Justice Department.


“Well, suppose I do this,” Trump said to Donoghue. “Suppose I replace [Rosen] with [Clark], what would you do?”


“Sir, I would resign immediately,” Donoghue said he responded. “There’s no way I’m serving under this guy [Clark].”


Trump then turned to Steve Engel, the Justice Department’s assistant attorney general for the Office of Legal Counsel, whom Trump reportedly had considered for a seat on the Supreme Court.
“Steve, you wouldn’t resign, would you?” Trump asked.

“Absolutely I would, Mr. President. You’d leave me no choice,” Engel responded, according to Donoghue’s account. Engel declined to comment.

“And we’re not the only ones,” Donoghue said he told Trump. “You should understand that your entire department leadership will resign. Every [assistant attorney general] will resign. … Mr. President, these aren’t bureaucratic leftovers from another administration. You picked them. This is your leadership team. You sent every one of them to the Senate; you got them confirmed. What is that going to say about you, when we all walk out at the same time?”

Donoghue then told Trump that Clark had no qualification to be attorney general: “He’s never been a criminal attorney. He’s never conducted a criminal investigation in his life. He’s never been in front of a grand jury, much less a trial jury.”
Clark objected.

“Well, I’ve done a lot of very complicated appeals and civil litigation, environmental litigation, and things like that,” Clark said, according to Donoghue’s deposition.

“That’s right,” Donoghue said he responded. “You’re an environmental lawyer. How about you go back to your office, and we’ll call you when there’s an oil spill.”

Pat Cipollone, the White House counsel, told Trump that Clark’s proposed letter was “a murder-suicide pact,” according to Donoghue’s deposition. “It’s going to damage everyone who touches it. And we should have nothing to do with that letter. I don’t ever want to see that letter again.” Cipollone declined to comment.

Read the rest of the story if it is not behind a paywall.

The account goes on, filling in details about Clark’s effort to be named Attorney General of the United States and overturn the election. It is a shocking story. Had Trump appointed Clark, some Republican-led states might have recalled their electors. The Constitutional process, the orderly transition of power, would have been halted. The nation would have endured an unprecedented crisis. Trump would have been in control of the military and the levers of government.

No one knows what would have happened next.

My favorite part of the story:

“That’s right,” Donoghue said he responded. “You’re an environmental lawyer. How about you go back to your office, and we’ll call you when there’s an oil spill.”

Heather Cox Richardson, historian, summarizes some of the fallout from the first public meeting of the 1/6 Commissuon:

Today in the New York Times, columnist Maureen Dowd reacted to Thursday’s revelations that Trump was “deadly serious about overthrowing the government,” by laying out the main points: Trump knew he had lost the election, and he was willing to see his vice president hanged in order to avoid being labeled a loser. Dowd called former president Trump an “American monster” and compared him unfavorably to Frankenstein’s monster, who at least “has self-awareness, and a reason to wreak havoc…[and] knows how to feel guilty and when to leave the stage.” Our monster, in contrast, is driven only by “pure narcissistic psychopathy—and he refuses to leave the stage or cease his vile mendacity.”

Yesterday, Politico’s Betsy Woodruff Swan and Kyle Cheney reported that on January 5, 2021, then–vice president Pence’s attorney Greg Jacob wrote a three-page memo concluding that what the president and his supporters were demanding Pence do the next day would break the 1887 Electoral College Act—that is, the law—in four different ways. The memo responded to John Eastman’s memo laying out the plan for Pence to hand the election to Trump by refusing to count a number of Biden electors. Jacob noted that Eastman himself “acknowledges that his proposal violates several provisions of statutory law.” In addition, both historical court decisions and one as recent as the day before contradicted Eastman’s plan.

Another fine piece by Jan Resseger about the sorry state of politics in Ohio, where the Legislature ignores pressing problems, but passes bills for spite and political gain.

She begins:

In its legislative update last Friday, Honesty for Ohio Education reported: “It was an appalling and heartbreaking week in the Statehouse as Ohio legislators passed two bills to arm school personnel and ban transgender girls in female sports, and held hearings for bills censoring education about race, sexuality, and gender and banning gender-affirming healthcare for minors.”

The Plain Dealer’s Laura Hancock explains how, without a hearing, the House banned transgender girls from female sports when legislators added the amendment to another bill: “The Ohio House passed a bill shortly before midnight Wednesday, the first day of Pride Month, with an amendment to ban transgender girls and women from playing high school and college women’s sports… As originally introduced, HB 151 would change the Ohio Resident Educator Program, which assists new teachers with mentoring and professional development as they begin their careers… But on the Ohio House floor late Wednesday night, Rep. Jena Powell, a Darke County Republican, offered an amendment to the bill, which a majority of the house accepted…. House Bill 151 passed 56 to 28 with Democrats voting in opposition. It now heads to the Ohio Senate, which is in summer recess and won’t return until the fall.”

A big part of our problem in Ohio is a long run of gerrymandering—leaving both chambers of our state legislature with huge Republican supermajorities. A committee of legislators from House and Senate were charged to create fair and balanced legislative district maps. The Ohio Redistricting Commission spent the winter and spring redrawing the maps, which were rejected five times by the Ohio Supreme Courtbecause a Court majority found the new maps gerrymandered to favor the election of Republicans. At the end of May, however, a federal district court ruled that the state must end the battle over gerrymandering by using maps—for this year’s August primary and the November general election—which were rejected twice in the spring by the state’s supreme court because they favor Republican candidates.

Citizens in a democracy are not supposed to be utterly powerless, but that is how it feels right now in Ohio.

The legislature also passed bills to increase school privatization, despite the woeful performance of charter schools and vouchers. The 90% of students in public schools will suffer so that the failing charter schools and vouchers may thrive, at least financially.

Florida Governor Ron DeSantis is a bully. He uses his power as Governor to force others to comply with his political ideology. Most recently, he forced the Special Olympics, which had chosen Florida for its competitions, to drop its vaccine requirement. This comes on the heels of an audit of Florida health data which found that the state had undercounted the numbers of COVID cases and deaths. Intentionally? DeSantis is probably the most likely Republican to run in 2024, if the aging Trump steps aside.

Rolling Stone and other publications reported the story:

Florida Gov. Ron Desantis and his administration have used their authority to essentially punish organizations he deems to be insufficiently conservative. One of their latest targets is the Special Olympics. Jay O’Brien of ABC News reported on Friday that the governor threatened to levy an eight-figure fine against the Special Olympics if it didn’t drop its Covid-19 vaccine requirement for its games in Orlando this weekend.

The Special Olympics backed off its vaccine requirement hours later, saying in a statement, “We don’t want to fight. We want to play.”

A letter from the Florida Department of Health dated June 2 threatened to assess the Special Olympics a $27.5 million fine due to “5,500 violations” of state law prohibiting business entities (including charitable organizations) from requiring individuals to show proof of vaccination. The applicable fine per person under this law is $5,000.

DeSantis is a dangerous ideologue who disregards science and the lives of his constituents.

The latest news from Florida is that there is an outbreak of a new strain of omicron COVID virus. Governor DeSantis doesn’t care if anyone is vaccinated. He believes that “public health” is a private, individual decision and that government should do nothing to protect the public.

Dana Milbank tells the sad story of Elise Stefanik, a promising moderate who was elected to Congress from Upstate New York. But when power beckoned, she threw aside character, ethics, and principle to join the Trump brigade. For this once-moderate member of Congress, there are no bounds to her willingness to go full MAGA. She echoes the Great Donald, walking in lockstep with him and his Big Lie, even endorsing the “great replacement theory” that terrifies MAGA-Carlson voters but inspired a massacre of ten innocent Black people in Buffalo. A week after the massacre of children and teachers in Uvalde, Texas, Stefanik said she opposes gun control, but favors more funding for mental health. Anything for the base. Anything for power. Sad.

When John Bridgeland left a senior position in George W. Bush’s White House and joined Harvard’s Kennedy School of Government in the fall of 2004, an eager undergraduate got assigned to him as a student fellow and facilitator of his seminar.

“She was so excited because I was one of the few Republicans” then at the school’s Institute of Politics (IOP), Bridgeland told me this week. He remembered her as “extremely bright” and “through-and-through public-service-oriented.” She was so impressive in the seminar that he chose her to do a project with him selling Harvard students on the Peace Corps, AmeriCorps and other service opportunities. “I thought the world of her,” Bridgeland said.


The young woman’s name was Elise Stefanik.

Bridgeland secured her a job in the White House when she graduated in 2006, personally appealing to Chief of Staff Josh Bolten and other former colleagues to hire her. Bridgeland later encouraged her to run for Congress, which she did, successfully, in 2014 — and the New York Republican quickly established herself as a leading moderate. “I was so incredibly happy and proud,” Bridgeland said. “I viewed her as the bright light of her generation of leaders. She was crossing the aisle. She was focused on problem-solving. She had the highest character.”


And then, he said, “this switch went off.”
Today, the world sees a much different Stefanik. This past week, after the racist massacre in Buffalo, attention turned to her articulation of “great replacement” theory, the white-supremacist conspiracy beliefs said to have propelled the alleged killer. Before that, she had been a prominent election denier, voting to overturn the 2020 results after the Jan. 6 insurrection, and then using the issue to oust and replace House Republican Conference Chairwoman Liz Cheney (Wyo.) because she refused to embrace President Donald Trump’s election lies.

Now, Stefanik has thrown her support, as the No. 3 House GOP leader, behind a proposal to “expunge” Trump’s impeachment for his role in the insurrection. She has joined a small group of extreme backbenchers as co-sponsors of the resolution, which casts doubt again on Joe Biden’s “seeming” win, citing “voting anomalies.” The resolution has no purpose (there’s no constitutional way to expunge impeachment) other than to sow further distrust of democracy.


It’s a story told a thousand times: Ambitious Republican official abandons principle to advance in Trump’s GOP. But perhaps nobody’s fall from promise, and integrity, has been as spectacular as the 37-year-old Stefanik’s. “I was just so shocked she would go down such a dark path,” said her former champion, Bridgeland. “No power, no position is worth the complete loss of your integrity. It was just completely alarming to me to watch this transformation. I got a lot of notes saying, ‘What happened to her?’ ”
The answer is simple: “Quest for power,” Bridgeland said. “But power without principle is a pretty dark place to go. She wanted to climb the Republican ranks and she has, but … she’s climbed the ladder on the back of lies about the election that are undermining trust in elections, putting people’s lives at risk.”


As a candidate in 2014, Stefanik refused to sign Grover Norquist’s no-tax pledge, a Republican purity test. Then the youngest woman ever elected to Congress, she became a co-chair of the Tuesday Group of Republican moderates. She boasted about being among the most bipartisan lawmakers. She criticized Trump’s “insulting” treatment of women, his “untruthful statements,” and his proposed Muslim ban and border wall.


But Trump’s huge popularity in her upstate New York district changed all that. She became one of Trump’s most caustic defenders during his first impeachment. After Trump’s 2020 loss, she embraced the “big lie,” making a stream of false claims about voter fraud, court actions and voting machines, and urging the Supreme Court to reject the results.

When Bridgeland saw his former protegee’s lies about the election, “I was shattered. I was really heartbroken,” he told me. Alumni of Harvard’s IOP petitioned to remove Stefanik from its advisory committee, and Bridgeland signed it. “I had to,” he said, “because Constitution first.” Stefanik called her removal a “badge of honor” and a decision on the school’s part “to cower and cave to the woke left.”


Bridgeland, a career-long policy innovator who still considers himself a Republican, retains a flicker of hope that his former student might return to her early promise, recant the lies, and prove true Ralph Waldo Emerson’s belief that if a “single man plant himself indomitably on his instincts, and there abide, the huge world will come round to him.”


“People become totally ruined by their failure to stand up for the good and the true, but I do think she has the spark still and could awaken to it,” Bridgeland said. “It’s not too late.”

For our country’s sake, I wish I could believe that.

Why do people run for school board in their local community?

It has never been a more perilous time to be a school board member. When the pandemic began, local school boards bore responsibility for whether to open or close schools, whether or not to require masks. Whichever decision they made, a sizable number of parents were sure to be angry.

School board meetings in some communities became scenes of outrage and heated exchanges. Then came the manufactured claims that schools were rife with “critical race theory” and inappropriate sex education, and school boards were again under fire. Extremists set a goal of seizing control of local school boards, but have been largely unsuccessful. Here and there, a local school board capitulated to or even led the cries for censorship and book banning.

But most local boards have remained steady as a bedrock of grassroots democracy. Ninety-five percent of school districts are governed by an elected school board. Privatizers and disrupters would love to abolish them all and turn the nation’s schools over to corporate management organizations. But as long as there are local school boards, they must stand for re-election and face the voters in their district.

Given the intemperate attacks on public schools, on school boards, and on our democracy, we owe them our thanks for their service to our communities.

Lawrence A. Feinberg wrote the following tribute to local school board members. He is a passionate advocate for public schools, who has served on his local school board in Pennsylvania for 22 years.

He writes:

“The short answer on why people want to run (for school board) these days is because we are out of our . . . minds.” That was my answer back in May of 2011, long before COVID, when the Philadelphia Inquirer’s Anthony Wood asked me why folks would consider seeking school board seats.

I first ran for the school board in 1999, and then five times more because I believe that public education is the foundation of our democracy and that our mission is to create informed American/Global citizens.

Asked a similar question on a League of Women Voters Zoom panel last month, my colleague, friend and former William Penn School District Board President Jennifer Hoff had a clear, concise answer: “the kids.”

Why would anyone want such a thankless, unpaid role? Here area few reasons:

• To get to shake hands with hundreds of graduating seniors who were in kindergarten when I was first elected.

• To hear elementary students speak eloquently and effusively at a public meeting about the character development initiative in their school.

• To read to elementary school students on Read Across America Day.

• To see and hear, year in and year out, innumerable opportunities and accomplishments for and by students in the arts, music, theatre, robotics, culinary arts, industrial arts, medical trades, community service, athletics, countless clubs and activities, student publications and academics.

• To listen to teams of students demonstrate and describe their science experiments.

• To watch our Best Buddies Unified Bocce team (that includes students with and without special needs) in action and to see them get statewide recognition.

• To see students learn to respect and value their similarities and their differences.

• To see our students register their peers to vote.

• To see our graduates move on successfully to college and careers.

• To marvel at the professionalism, dedication, patience and competency of administrators, teachers and support staff and their clear, constant focus on what is best for kids.

There is no denying that the past two years have not been easy for our school communities. For myself and most of my school director peers throughout the state, our attitude has been to assume that everyone has good intentions and wants what is best for their kids, and to treat others with the same level of respect, civility and dignity that we would like to be treated with.

A profound thank you to all Pennsylvania school directors for their dedicated volunteer public service to their students, communities, taxpayers and school districts.

Special thanks to all our superintendents, administrators, and principals, many of whom worked 24/7 throughout the pandemic in the face of immense challenges.

And thanks to all our teachers, aides and all staff – nurses, counselors, social workers, mechanics, bus drivers, custodians, office personnel, food service workers and librarians. Thank you!

Lawrence A. Feinberg is serving his 22nd year as a school director in Haverford Township, Delaware County. Currently board vice president, he served as board president from 2017 through 2021. He has been an active advocate for public education at the local, regional, state and federal levels.

This commentary was first published by the Pennsylvania Capital-Star.