Archives for category: Elections

Dana Milbank is my favorite columnist at the Washington Post. In this column, he responds to the Texas GOP platform, which proposes that the state secede from the US and become a sovereign nation. Milbank says. “Good riddance!” As a native Texan, I’m ashamed for my state, ashamed that it’s been taken over by theocrats and dumbbells.

The Lone Star State does not have the best track record as a sovereign power. The Republic of Texas survived only 10 years from independence to annexation by the United States in 1845. Texas seceded during the Civil War — and, with the rest of the Confederacy, was crushed.


But, as the saying goes: If at first you don’t secede, try, try again. The Texas GOP now wants the state to vote on declaring independence.


And the United States should let Texas go! Better yet, let’s offer Texas a severance package that includes Oklahoma to sweeten secession — the Sooner the better.

Over the weekend, while many Americans were celebrating the 167th anniversary of Juneteenth (when Union Gen. Gordon Granger, in Galveston, Tex., delivered the order abolishing slavery) the Texas Republican Party voted on a platform declaring that federal laws it dislikes “should be ignored, opposed, refused, and nullified.”


The proposed platform (it’s expected to be approved when votes are tallied) adds: “Texas retains the right to secede from the United States, and the Texas Legislature should be called upon to pass a referendum consistent thereto.” It wants the secession referendum “in the 2023 general election for the people of Texas to determine whether or not the State of Texas should reassert its status as an independent nation.”


Yee-haw!


Of course, protections would have to be negotiated for parts of Texas that wish to remain on Team Normal. Dallas, Houston, Austin, San Antonio and parts of South Texas would remain in the United States, and they will need guaranteed safe passage to New Orleans or Santa Fe, along with regular airlifts of sustainable produce, accurate textbooks and contraceptives.

But consider the benefits to the rest of the country: Two fewer Republican senators, two dozen fewer Republican members of the House, annual savings of $83 billion in defense funds that Texas gets. And the best reason? The Texas GOP has so little regard for the Constitution that it is calling for a “Convention of the States” to effectively rewrite it — and so little regard for the United States that it wishes to leave.


In democracy’s place, the Republican Party, which enjoys one-party rule in Texas, is effectively proposing a church state. If you liked Crusader states and Muslim caliphates, you’ll love the Confederate Theocracy of Texas.


The Texas GOP platform gives us a good idea what such a paradise for Christian nationalists would look like. Texas would officially declare that “homosexuality is an abnormal lifestyle choice.” It would redefine marriage as a “covenant only between one biological man and one biological woman,” and it would “nullify” any court rulings to the contrary. (The gay Log Cabin Republicans were banned from setting up a booth at the convention.) It would fill schools with “prayer, the Bible, and the Ten Commandments” but ban “the teaching of sex education.” It would abolish all abortions and require students to “learn about the Humanity of the Preborn Child.”


The Texas Theocracy, which maintains that President Biden “was not legitimately elected,” would keep only traces of democracy. It wants the Voting Rights Act of 1965 “repealed,” and it would rewrite the state constitution to empower minority rule by small, rural (and White) counties. It would rescind voters’ right to elect senators and the Constitution’s guarantee of birthright citizenship.

The Texas Theocracy would probably be broke; it wants to abolish the federal income tax, “Axe the Property Tax” and do away with the estate tax and various business taxes. Yet it is planning a hawkish foreign policy! The platform argues that Texas is currently “under an active invasion” and should take “any and all appropriate measures the sovereign state defines as necessary to defend” itself. It imagines attacks by a “One World Government, or The Great Reset” — an internet-born conspiracy belief — and proposes “withdrawal from the current United Nations.” The Theocracy would put the “wild” back in the West, abolishing the minimum wage, environmental and banking regulations, and “red-flag” laws or waiting periods to prevent dangerous people from buying guns.

Above all, the Confederate Theocracy of Texas would be defined by thought police. It would penalize “woke corporations” and businesses that disagree with the theocracy over abortion, race, trans rights and the “inalienable right to refuse vaccination.”

Government programs would be stripped of “education involving race.” Evolution and climate change “shall be taught as challengeable scientific theories subject to change.” There would be a “complete repeal of the hate crime laws.” The Texas Revolution “shall not be ‘reimagined’” in a way the theocracy finds “disrespectful.” Confederate monuments “shall be protected,” “plaques honoring the Confederate widows” restored, and lessons on “the tyrannical history of socialism” required.

In their platform, the Texas Republicans invoked “God” or the “Creator” 18 times and “sovereignty” or sovereign power 24 times. And the word “democracy”? Only once — in reference to China.

I hope you can read the comments. Readers suggest other states that should secede with Texas.

Arizona Republican candidates are running as die-hard supporters of Trump’s Big Lie that the 2020 election was stolen. They laugh at the 1/6 Conmisssion and ignore the many Republicans who testified that Trump knew he lost the election but decided to destroy democracy rather than admit he lost.

Is stupidity contagious? Or is it gullibility?

Tens of millions of people have watched the first two Congressional hearings probing the insurrection at the U.S. Capitol last year, but several of Arizona’s Republican candidates for governor were not among those viewers.

The GOP candidates largely dismissed the hearings as political theater and wouldn’t answer a question from The Arizona Republic about former President Donald Trump’s role in the riot.

Meanwhile, their Democratic opponents seized on the chance to call out their conservative competitors as complicit in the false claims of election fraud that fueled the violence at the U.S. Capitol on Jan. 6, 2021.

“The hearing is a stark reminder of the lengths at which they will go to attack America.”

“I watched the Jan. 6 hearing because right here in Arizona we face dangerous threats from candidates like Kari Lake who continue to spread conspiracy theories and lies to try to undermine our democracy,” Secretary of State and Democratic candidate for governor Katie Hobbs said.

Lake: ‘I think it’s a waste of time’

Lake, a leading Republican candidate and former Fox 10 news anchor, did not respond to questions for this article. During her campaign, Lake has championed the unproven claims the election was corrupt, and that insurrectionists were held without charges or were welcomed into the Capitol by police.

Lake said in an interview on the conservative channel Newsmax that she would not watch the Jan. 6 hearings, which she dismissed as an effort by Democrats, mainstream Republicans and the media to discredit Trump.

“So this is their effort to try to make Donald Trump and his followers go away forever and it’s not going to work,” Lake said in that interview Friday. “This is theater. They’ve obviously been spinning and splicing and taking different video clips, removing the pertinent parts that would put the truth out there and trying to tell a story that spreads their lies. So I’m not going to be watching it. I think it’s a waste of time.”

Blogger Robert Hubbell brings clarity and reason to the abortion debate. The Court’s decision overturns a precedent that had been in place for 49 years. Both Justices Gorsuch and Kavanaugh pledged to Senators that they would not overturn roe. They lied. What now?

Hubbell writes:

There is much to discuss after the Supreme Court’s brutal ruling in Dobbs v Jackson Women’s Health, but the most important question is, “What are we going to do about it?” We have several effective paths forward and must pursue all simultaneously.

First, Alito claims he is returning the decision of reproductive freedom “to the people and their state representatives.” Let’s ignore (for the moment) Alito’s smoldering bad faith and thinly veiled contempt for the rights of women. We need to flip state legislatures to repeal antiabortion legislation and capture statewide executive offices that can veto legislation abortion bans. While this path is not an answer in every state, it can make a difference in states where the GOP margin of control is thin.

Second, we must demand that Congress pass legislation codifying Roe. That means gaining a 54-seat majority in the Senate, carving out an exception to the filibuster, and retaining control of the House. Will national legislation be challenged? Sure! Will the Supreme Court invalidate it? Possibly, but it is worth the effort.

Will national legislation be challenged? Sure! Will the Supreme Court invalidate it? Possibly, but it is worth the effort.

Third, we must break the Supreme Court. Democrats should expand the Court to thirteen justices. This path also requires holding the House, gaining a 54-seat majority in the Senate, and carving out an exception to the filibuster. Expanding the Court requires only a majority vote in both chambers of Congress and signing of the bill by the president. Will Republicans expand the Court to nineteen? Maybe. But what Republicans might do in the future shouldn’t deter us now. Will tit-for-tat expansions of the Court undermine its legitimacy? It is far too late for that.

Fourth, reproductive choice must be on the ballot in every race. Republicans have finally achieved what they wanted—no right to abortion and no exceptions for rape or incest. We must make every Republican running for every office in the land own the GOP position on abortion in its ugliest manifestation. The outcome in Dobbs is opposed by a strong majority of Americans and should provide a basis for a sweeping Democratic victory in 2022.

Finally, the right to same-sex marriage, same-sex relations, contraception, and other privacy-based rights must be on the ballot in every race. Justice Clarence Thomas’s concurrence declared war on those rights and invited reactionary legislatures to pass laws to serve as test cases. We would be foolish to assume that the other members of the reactionary majority will not follow his lead, given a chance.

None of these approaches will be easy or provide a complete answer. Readers have already sent emails that preemptively identify the problems with some of these approaches and dismiss their chances of success. But these are the paths available to us. We can choose to pursue them or do nothing. We must pursue them relentlessly until we have regained control of every branch of government, including the Supreme Court. Only then can we reverse the ruling in Dobbs and preserve other liberties grounded in the same right to privacy that supported reproductive rights for a half-century.

We are the majority, and American democracy presumes majority rule while protecting the rights of the minority. Republicans are attempting to reverse that presumption by seeking to impose permanent minority rule with no protection for the rights of the majority. That cannot stand. It will not stand. But it is up to us to restore the natural balance to democracy. It is not enough that we vote with greater passion or conviction. We must motivate those who did not believe this day would not come or who were not paying attention. We can do that—if we act with greater passion, conviction, and urgency.

The ruling.

Alito’s final decision is a judicial insult. In a single blow, he has demoted American women to second-class citizens. It is filled with venom and contempt in addressing a contentious issue on which people of good faith can disagree. He refers to physicians as abortionists when they seek to save a woman’s life or terminate a pregnancy forced on a teenager by a rapist. He misrepresents, minimizes, and dismisses the burdens and risks of pregnancy. He substitutes his Catholic dogma for judicial analysis.

Alito’s final version of his opinion changed little from the draft leaked last month. As such, it retains the dishonesty and intellectual sophistry of the “deeply rooted tradition” analysis contained in the draft—an analysis that deliberately misrepresents the American tradition relating to abortion. See Aaron Tang in The Los Angeles Times, Op-Ed: The Supreme Court flunks abortion history.

But most ominously, Alito’s “deeply rooted” analysis signals Alito’s intent to attack other privacy-based rights, such as same-sex marriage. Alito dissented in the Court’s decision recognizing same-sex marriage, Obergefell v. Hodges. Alito wrote in Obergefell, as follows:

          To prevent five unelected Justices from imposing their personal vision of liberty upon the American people, the Court has held that “liberty” under the Due Process Clause should be understood to protect only those rights that are ‘deeply rooted in this Nation’ s history and tradition.’ And it is beyond dispute that the right to same-sex marriage is not among those rights.

There it is: Alito’s analysis in overruling Roe v. Wade does not stop with reproductive rights. It reaches to same-sex marriage. He said so in his dissent in Obergefell. And Justice Thomas made that explicit in his concurrence in Dobbs:

          In future cases, we should reconsider all of this Court’s substantive due process precedents, including Griswold, Lawrence, and Obergefell.

Griswold recognized the right to use contraceptives of choice; Lawrence recognized the right to enter into a same-sex relationships; and Obergefell recognized the right of same-sex couples to marry. Justice Thomas notably omitted a right based on “substantive due process precedents”—the right of members of different “races” to marry, a right first granted in Loving v. Virginia in 1967. If the Court reverses Loving v. Virginia, Thomas’s marriage to Ginny Thomas would be illegal in some states.

For a longer discussion of the threat to other rights, see Mark Joseph Stern in Slate, The Supreme Court decision overruling Roe v. Wade puts marriage equality in immediate jeopardy.

It will take weeks to understand the implications of Justice Alito’s decision, but a good place to start is with Ian Millhiser’s analysis in Vox, The Roe v. Wade abortion decision, explained.

Finally, for a discussion of self-inflicted damage to the Court’s legitimacy, see Dahlia Lithwick, in Slate, Roe v. Wade overturned: The Supreme Court will pay for abortion decision.

The corruption and illegitimacy of the Supreme Court.

As currently constituted, the Supreme Court is illegitimate and corrupt. It is illegitimate because two justices appointed by Trump resulted from norm-busting “rules” made up by Mitch McConnell on the fly. Gorsuch sits in a seat stolen from an Obama appointee, and Barrett sits in a seat that belonged to the incoming president.

The Court is corrupt because Gorsuch, Kavanaugh, and Barrett lied to the Senate about their pre-determined intent to overrule Roe v. Wade. And it is corrupt because Justice Thomas has refused to recuse himself from cases in which his wife assisted in an attempted coup.

The trust of the American public in the Court has plummeted to an all-time low of 25%. It will decline further if the January 6th Committee proves that Ginny Thomas funneled information about Court deliberations to John Eastman. It will fall further if the Committee demonstrates that Justice Thomas knew of and condoned his wife’s insurrectionist activities.

Jennifer Rubin succinctly summarizes the death blow to the Court’s legitimacy in her column in WaPo, The Supreme Court eviscerates abortion rights and its own legitimacy. Per Rubin,

The hypocrisy and intellectual dishonesty of the court’s right-wing justices lead to the conclusion that they have simply appointed themselves super-legislators free to impose a view of the United States as a White, Christian and male-dominated society despite the values, beliefs and choices of a majority of 330 million modern Americans.

The court’s decision may result in women’s deaths. But it has certainly killed off what is left of the court’s credibility. And for that, there is no solution in sight.

Concluding Thoughts.

On a day like today, it does not feel right to end on an optimistic note. Rather, we should acknowledge the anger, frustration, fear, and grief that tens of millions of women in America are feeling after the ruling. There will be a time to rally and rejoin the fight for the dignity and equality of women—a fight we will win.

But today, we should acknowledge what women have lost and give them the time and space to absorb and recover from a once-in-a-generation shock. As they do, everyone in their lives should let them know we are at their side every step of the way. Walk along in silence and listen. Nothing can be “fixed” today, but we can begin the long journey back in the coming days.

Charles P. Pierce is a super writer who is smart and insightful, especially when he writes about education. He writes regularly for Esquire. In this post, he slices and dices the absurdity of the Carson vs. Makin ruling that compels Maine to pay tuition for students at evangelical Christian schools that openly discriminate against students, families, and teachers who do not share their religious views. The six justices in the majority are certainly not Originalists. Their decision overturns a key principle embedded in the Constitution, which prohibits the state from sponsoring or “establishing” religion.

He writes:

It’s been a big week for Christian nationalism in our politics. In the case of Carson v. Makin, which involved a Maine law that forbade public money to go to religious schools, the Supreme Court ruled that the Establishment Clause of the United States Constitution is…unconstitutional. The Court’s carefully engineered conservative majority has been heading in this direction, finding anti-religious—primarily anti-Christian—discrimination in laws deliberately written to be religiously neutral. This was a pole-vault over that line, and one that conceivably could threaten public education as a whole. Writing for the majority, Chief Justice John Roberts said:

This case concerns two families that live in SAUs that neither maintain their own secondary schools nor contract with any nearby secondary school. Petitioners David and Amy Carson reside in Glenburn, Maine. When this litigation commenced, the Carsons’ daughter attended high school at Bangor Christian Schools (BCS), which was founded in 1970 as a ministry of Bangor Baptist Church. The Carsons sent their daughter to BCS because of the school’s high academic standards and because the school’s Christian worldview aligns with their sincerely held religious beliefs.

Translation: the school discriminates against LGBTQ citizens. Here, from a brief filed in this case, is what Bangor Christian Schools are up to.

BCS believes that a student who is homosexual or identifies as a gender other than on his or her original birth certificate would not be able to sign the agreement governing codes of conduct that BCS requires as a condition of admission.

If a student was openly gay and regularly communicated that fact to his or her classmates, “that would fall under an immoral activity” under BCS’ Statement of Faith and if “there was no change in the student’s position” after counseling, the student would not be allowed to continue attending BCS.

BCS does not believe there is any way to separate the religious instruction from the academic instruction – religious instruction is “completely intertwined and there is no way for a student to succeed if he or she is resistant to the sectarian instruction.”

One of the objectives in the ninth-grade social studies class is to “[r]efute the teachings of the Islamic religion with the truth of God’s Word.”

Shrug, says John Roberts. Pay up, suckers.Me? I am planning to open a taxpayer-funded madrassa out in the woods somewhere. I’ll keep you advised.

Open the link. The post has an interesting take on Herschel Walker and on Arizona official Rusty Bower’s view that the Constitution was divinely inspired.

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.

Cite as: 596 U. S. ____ (2022) 1 BREYER, 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 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 Columbia, Inc. 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

2 CARSON v. MAKIN BREYER, J., dissenting

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 Aye, Inc. 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. 71, Champaign Cty., 333 U. S. 203, 211 (1948). Nor may a State “adopt programs or practices in its

Cite as: 596 U. S. ____ (2022) 3 BREYER, J., dissenting

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

4 CARSON v. MAKIN BREYER, J., dissenting

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.

Cite as: 596 U. S. ____ (2022) 5

BREYER, J., dissenting

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

6 CARSON v. MAKIN BREYER, J., dissenting

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

8 CARSON v. MAKIN BREYER, J., dissenting

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.

10 CARSON v. MAKIN BREYER, J., dissenting

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

12 CARSON v. MAKIN BREYER, J., dissenting

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

14 CARSON v. MAKIN BREYER, J., dissenting

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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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.

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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 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

Cite as: 596 U. S. ____ (2022) 5

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.