Archives for category: History

Maureen Downey of the Atlanta Journal-Constitution posted a guest column by two university scholars in Georgia, warning about the dangerous legislation now under consideration.

T. Jameson Brewer is an assistant professor of social foundations of education at the University of North Georgia. Brandon Haas is an associate professor of social foundations and leadership education at the University of North Georgia.

Brewer and Haas write:

At present, several bills in the state Legislature — including House Bill 1084 and Senate Bill 377 — weaponize grievance politics in the culture wars during a Georgia election year. These bills are our state’s iteration of “anti-critical race theory” proposals across the nation.

In Florida, lawmakers are seeking to make it illegal for white students to feel discomfort. In Oklahoma, a recent proposed bill would allow parents to sue teachers for $10,000 per day if they discuss any topic that does not perfectly align with a student’s closely held religious belief.

The House and Senate bills here in Georgia do not mention critical race theory by name. But they are part of this growing ideological trendto manufacture and capitalize on outrage as it relates to what students are taught or not taught in schools — the front line, as it were, of the nation’s culture war.

While there have long been efforts from the political right to censor curriculum and ban books in U.S. schools, these efforts have reached a fever pitch over the past two years. First, parents shouted at local school boards to ignore medical science and reopen schools as well as remove mask mandates during the height of the pandemic. Then, concerns over the teaching of CRT began to spring up across the country.

The simmering perception that K-12 schools and universities are engaged in teaching students to hate the United States or themselves was captured in the Trump administration’s 1776 Report. That report, not penned by historians, is full of inaccuracies in its attempt to promote fascist-like indoctrination that the United States is without historical or contemporary issues. Among many concerns, the 1776 Report attempts to suggest that George Washington freed his slaves and, thus, the United States does not have a legacy of racial oppression. Those with an accurate understanding of history know Martha Washington freed one of approximately 123 slaves.

Recently, the Heritage Action group tweeted about “uncovering” the teaching of CRT in Gwinnett County Public Schools despite K-12 districts suggesting that they do not teach CRT. Yet, this tweet was not the “gotcha” that Heritage may think it was for a few reasons: (1) The course in question was an Advanced Placement language and research course (that is, a college-level course), (2) students learn myriad frameworks for examining and critiquing issues, and (3) this type of critical thinking is precisely what we should want education to teach our students. All of that said, Superintendent Calvin Watts, noted that the syllabus in question was never used in classes. A district spokeswoman said it was a sample syllabus submitted to the organization that provides AP curriculum.

Georgia’s proposed bills seek to establish that racial injustice is an artifact of the past that no longer exists. They state that educators cannot suggest that the United States or Georgia is fundamentally biased based on race. Yet, any examination will clearly show that racial bias was a fundamental component of our legal, social, and educational system — from slavery to Jim Crow to mass incarcerations. The question, then, is whether or not these inequalities still persist. For this, students need to develop the ability to examine, evaluate and critique myriad forms of data and generate their own fact-based conclusion.

While part of any learning process is extending beyond our comfort zones, that discomfort is not what is at stake with these bills in Georgia, Florida and a dozen other states. It is uncomfortable to admit that white schools receive so much more in funding than nonwhite schools. Admitting this reality begs action. If we claim that the U.S. affords all children with a level playing field, the receipts showing that the field is structurally uneven suggests that we either forfeit the claim of equality or seek to remedy the inequality…

The larger problem created by SB 226 is that it creates a slippery slope of giving power to those who lack training in curriculum, instruction, and library media. This trend should alarm anyone who does not fancy a Nazi Germany-style authoritarian government over a democratic republic. In fact, one of the initial steps taken in Nazi Germany was banning of books, control of school curriculum and requirements of “loyalty oaths” and coerced patriotism as we are seeing in a variety of proposed laws across the country.

The United States has a checkered past that is troubling for all citizens. This is known as difficult history and provides students with an opportunity to understand how the past shapes the present so that they can be thoughtful and effective citizens. As novelist and essayist James Baldwin said, “I love America more than any other country in the world and, exactly for this reason, I insist on the right to criticize her perpetually.”

Will Georgia codify lying to students? Will we ban or burn books? While the next political outrage may find another arena to target and destroy for political gain, there are real harmful implications of the one currently targeting schools and books in an effort to satiate the public’s broad ignorance about buzzwords such as critical race theory. These bills are not anti-CRT, whatever that may mean. They are explicitly anti-education.

Historian Adam Laats warns that the Supreme Court failed to understand the wisdom behind the Founding Fathers’ efforts to separate public schools, public funding, and religion. And in their failure, they have opened controversies that will rock American society and schools for years to come.

Laats writes:

Religious conservatives have been fighting for years to get prayer back into America’s schools, and this year, the Supreme Court gave them what they wanted. In Kennedy v. Bremerton, the six conservative justices affirmed a coach’s right to offer a prayer after a football game.

But what is really astonishing is that this decision will over time prove to be less monumental than the Court’s other big religion decision this term. In Maine’s Carson v. Makin, the Court ruled 6–3 that a state could not exclude private religious schools from receiving public funding only because of their religion. In prospect, it opens up a vast new world of publicly funded religious schools—using tax money, potentially—to teach kids that dinosaurs walked with humans, that girls primarily come into this world to grow up and bear children, or that only heterosexuals deserve rights. Maine quickly passed a law to keep public money away from avowedly anti-LGBTQ schools, but legislators will only be able to play anti-discrimination whack-a-mole for so long. Carson, not Kennedy, is the decision that could reshape the relationship of Church and school in America—even though prayer in school has long been the symbolic victory conservatives were intent on winning.

The reasons that prayer in school became the hallmark fight of this movement go back to the middle and late 20th century, when the Supreme Court decided a series of cases that conservatives thought “kicked God out of the schools.” In 1962, in Engel v. Vitale, the Supreme Court ruled that public schools could not require students to recite a state-written prayer. Politicians rushed to condemn the decision. Representative Frank Becker of New York called the decision “the most tragic in the history of the United States.” Ex-President Herbert Hoover joined ex-President Dwight Eisenhower in protesting the decision, declaring it the end of the country’s public-school system.

To Americans who cared a lot about religion, however, the decision seemed like a good one. Conservative evangelical Protestants looked askance at the bland wording of the prayer—it left out any specific mention of Jesus—and they did not approve of government-written prayers in the first place. From the fundamentalist citadel of the Moody Bible Institute, in Chicago, President William Culbertson wrote, “Christians who sense the necessity for safeguarding freedom of worship in the future are always indebted to the Court for protection in this important area.”

That all changed the next year, with the Court’s decision in School District of Abington Township, Pennsylvania v. Schempp. In Schempp, the Court ruled that some of the religious staples of American public schooling veered too far into controversial territory. It ruled against teachers leading students in prayer, and against students reading the Bible in class as part of a prayerful practice.

For America’s conservative Christians, even evangelicals who had supported the Engeldecision, that was too much. Evangelical editors ranked the Schempp decision as the most devastating, world-changing event of 1963, more important to America and to Christianity even than the bombing of Birmingham’s 16th Street Baptist Church, with its murder of Christian children. Madalyn Murray O’Hair, the outspoken atheist who helped bring the Schempp cases to court, was attacked relentlessly, labeled by Life as “The Most Hated Woman in America.”

Ambitious politicians scrambled to pass a constitutional amendment to bring prayer back to public schools. New York’s Becker persuaded his colleagues to unite behind a single, simple change to the Constitution. The amendment explicitly stated that the Constitution never prohibited prayer or Bible reading in public schools or other government functions. The Republican Party added a plank to its party platform in favor of the amendment. By 1965, however, the amendment drive had lost steam.

Conservatives despaired. As one conservative Christian wrote in 1965, the end of school prayer meant the end of American Christianity itself. The Schempp decision, he warned, was only the start of “repression, restriction, harassment, and then outright persecution.” From the conservative evangelical Biola University, near Los Angeles, President Samuel Sutherland concluded that the decision and the failure of a constitutional amendment signaled America’s transformation into “an atheistic nation, no whit better than God-denying, God-defying Russia herself.”

Bob Shepherd, polymath and educator, predicts the truly extraordinary goal of the far-right extremist Supreme Court. It mainly consists of dismantling the federal government’s powers. This was proclaimed by Steve Bannon in 2016 before the Trump election. In this rightwing dream, all federal laws protecting civil rights, women’s rights, climate change, etc. would disappear.

Shepherd writes:

Let me be as clear about this as I can be. My reading of what the Extreme Court has been up to is NOT that it means to do away with the doctrine of stare decisis. No. It means to establish, with Dobbs v Jackson Women’s Health and West Virginia v. EPA, in this term, and with Moore v. Harper in the next term a new set of precedents designed to fulfil the conservative goals of a) shrinking the federal government down to a size at which it can be drowned in a bathtub and b) turning over power to state governments, many of which will be de facto theocracies under the new legal order. Dobbs provides a template or boilerplate for eliminating whole bodies of federal law and regulation related to unenumerated rights and with these these agencies and departments that do that regulation and enforcement. WV v. EPA is a template or boilerplate for eliminating government agencies or departments (or parts of these) that promulgate regulations pursuant to Congressional legislation on the basis of an argument that Congress can’t turn such decision-making over to Executive Branch agencies or departments because the Constitution insists that these are legislative matters. The idea, again, is to shrink the power and authority of the federal administrative state in full knowledge the fact that Congress,being divided, will not step into these various roles (will not, for example, agree on real climate change). And again, the effect of that will be, with the federal executive and legislature and courts all out of the picture, to turn all this power back to the states. And, finally, Moore will enable the court to rule that the feds cannot pass legislation to protect voting rights because determination of how voting is to be conducted is entirely up to state legislatures under this extremist reading of the Constitution. Again, the effect will be to eliminate federal power and agencies/departments and turn this all over to the states.

All this is revolutionary and is meant to be. It’s the fulfillment of a dream that conservatives in America have had for a long, long time. They have long believed in state’s rights, in the federal government being a monster not envisioned by the founders. This Extreme Court is simply making good on that.

And, btw, as with the various coup methods undertaken by Trump and his team, this has all been discussed on Steve Bannon’s War Room podcast (or whatever he wants to call it). He recently devoted much of a program to this very topic: the ways in which work is underway to completely “dismantle the administrative state.”

Ohio Republican legislators have drafted a bill to require teachers to teach “both sides” of controversial issues. The sponsor wants teachers to teach the Holocaust from the perspective of German soldiers. Concentration camp guards?

COLUMBUS— Today, State Reps. Brigid Kelly (D-Cincinnati) and Casey Weinstein (D-Hudson), demanded House Bill (HB) 327, the ‘Both Sides’ bill, be barred from any further consideration by the Ohio House after the Republican bill sponsor said in a recent interview that educators should teach “German soldiers’” perspective of the Holocaust. The bill sponsor then proceeded to make several inaccurate and anti-Semitic claims about the Holocaust during the interview.

“Claiming there are two neutral and legitimate sides to the Holocaust is nothing short of denial,” said Rep. Weinstein, a Jewish member of the Ohio House. “Trying to wipe out and ignore our history while imposing big government on school districts to limit First Amendment rights in an unconstitutionally broad and vague way is chilling and reminiscent of the ‘thought police.’”

The ‘Both Sides’ bill would make “failing to fairly present both sides of a political or ideological belief or position” conduct unbecoming of an Ohio educator, which prompted widespread alarm from teachers and concerned parents. Educators and potentially-impacted organizations across the state have asked how teachers would be expected to confront difficult subjects. How do you teach both sides of the Holocaust? Of 9/11? Of slavery? Of Ukraine?

“These comments are absolutely reprehensible, and reveal HB 327’s true intent: to force our educators to teach ‘both sides’ of topics like the Holocaust, slavery or 9/11 that unequivocally have only a right side and a wrong side. This is exactly why we must trust well informed educators, not partisan politicians, to determine what is taught in our classrooms so our children are best prepared for the future,” said Rep. Kelly.

As they’ve worked through four public versions and at least 12 unofficial drafts of the legislation, Republican lawmakers have been forced to grapple with what a requirement to teach both sides of topics like Communism, Christian values, and even American traditions like standing for the National Anthem might look like in the classroom. Putting restrictions on what people can and can’t say, as it turns out, is a difficult task.

That said, the impossible choice the bill would present to teachers – false equivocacy or firing, is one of the most straightforward provisions in the far-reaching and ambiguous censorship bill.

The bill is intentionally broad, making it nearly impossible for schools, universities, police stations, libraries, and local governments to predict when they cross the line into legal liability. Even business-minded organizations have expressed concerns behind closed doors about the legal uncertainty it would impose.

After a consistent flow of decisions tearing down the wall of separation between church and state, readers have proposed that the U.S. Supreme Court should henceforth be known as the Supreme Christian Court of the United States. Others call it the Supreme Christian Taliban Court.

In every decision involving religion, the Christian Court makes no effort to balance freedom of religion and the Constitutional prohibition against establishment of religion.

This Court agreed that a baker open to the public may refuse to bake a cake for a gay couple because gay marriage violates his religious beliefs.

This Court requires Maine to fund two evangelical schools in Maine that openly discriminates against those who do not share their beliefs. The state is thus compelled to subsidize discrimination that federal and state law forbid.

This Court supports a school coach’s right to pray in public while he is working and influencing students to follow his lead. Will they next support teachers who are moved to pray in their classrooms?

What next, a revival of school prayer?

This Court, in true Taliban style, allows states to revoke women’s reproductive rights, the decision to control their own bodies.

The Court is drunk with its unchecked power. With a certain majority of 5 hard-core extremists, and the likely vote of a powerless Chief Justice, this Court is set to remake American society, to roll back the rights and freedoms that most Americans take for granted.

Do they want to take us back to 1868, as Justice Thomas wrote, when people of color and women could not vote?

Or do they want to transport us to an imaginary world where father knows best, women know their place, Black people quietly acquiesce to indignities, and everyone is forced to pray the same prayers?

Dana Milbank is a wonderful columnist for the Washington Post. He writes here about the death of state decisis, the legal principal of respecting precedent. The six-person majority on the Supreme Court have thrown away precedent. They are drunk with power. They are free to do whatever they want with no restraint, and they are rolling back decades of social progress. They are not conservatives. They are radicals.

Milbank writes:

Now begins the era of stare indecisis.
Respect for precedent — known by the Latin stare decisis, “to stand by things decided” — had been a centuries-old cornerstone of the rule of law, necessary so “the scale of justice” doesn’t “waver with every new judge’s opinion,” as the 18th-century legal philosopher William Blackstone wrote.


But — et tu, Alito? — the Supreme Court’s radical right put the knife in stare decisis in its decision overturning Roe v. Wade and destroying 50 years of precedent upon precedent.

The dissenting justices wrote that “the majority abandons stare decisis,” an act that “threatens to upend bedrock legal doctrines,” “creates profound legal instability” and “calls into question this Court’s commitment to legal principle.”


The majority protested that it didn’t abandon stare decisis — then explained why it did: “Stare decisis is not an inexorable command. … Stare decisis is not a straitjacket.”


The burial of stare decisis leaves us, ipso facto, with a void: Which Latin phrase best describes the legal doctrine of this new era, in which judges rule by whim, not precedent? Well, thank your lucky stares, because my classics consultant, Vanessa (she asked that her surname not be used in order to speak Latin frankly), has many options.


Labels such as “judicial modesty,” “judicial restraint” and “originalism” were trashed along with stare decisis. For this radical majority to claim “restraint” now would be the very definition of stare mendaciis — to stand by lies. Other better labels for the court majority’s new philosophy are stare deviis (to stand by inconsistent things), or perhaps stare fetore (to stand by a foul odor), in honor of the question Justice Sonia Sotomayor posed during oral arguments: “Will this institution survive the stench that this creates?”

But maybe most accurate is stare sodalitate — to stand by your political party. To the Romans, this meant either “electioneering gang” or “religious fraternity,” apt descriptions both of this court’s right wing.


There are other potential principles being thrown about. This week’s Jan. 6 committee hearing revealed that President Donald Trump, upon receiving displeasing information (such as his attorney general’s refusal to bless his election lies), would hurl his meal at the wall. This would be stare cibo iacto — to stand by thrown food (although other scholars use stare vasis fractis — to stand by broken dishes).


The Republican Party, even now, remains steadfastly loyal to Trump, adhering to something called the Wynette Doctrine, stare homine tuo — stand by your man.


Sen. Susan Collins (R-Maine) is claiming she was deceived by Justices Brett Kavanaugh and Neil Gorsuch into thinking they wouldn’t overturn Roe — an instance of stare credulitate, to stand by gullibility.


At a Trump rally, Rep. Mary Miller (R-Ill.) practiced stare hominibus albis — to stand by White people — when she called the abortion decision a “victory for White life.” (She said she misspoke, although the crowd cheered.)


Congressional candidate Yesli Vega, the GOP nominee to replace Rep. Abigail Spanberger (D-Va.) said “it wouldn’t surprise me” if it were difficult for a woman to get pregnant from rape, “because it’s not something that’s happening organically,” according to an Axios recording. That’s called stare rapina legitima — to stand by legitimate rape — affirming the precedent set by Senate candidate Todd Akin (R-Mo.), who said in 2012: “If it’s a legitimate rape, the female body has ways to try to shut that whole thing down.”

Texas Attorney General Ken Paxton is reviving the doctrine of stare contra pedicandum (to stand against sodomy) by saying he would defend a 1973 anti-sodomy law struck down two decades ago. Justice Clarence Thomas has invited challenges to that decision, as well as others protecting same-sex marriage and contraception.


Texts show that Thomas’s wife, Ginni, meanwhile, urged the Trump White House to “release the Kraken” of false election-fraud allegations — a philosophy known as stare monstris, to stand by sea monsters.


The court’s right-wing majority might also share the belief of Rep. Lauren Boebert (R-Colo.) who said she’s “tired of this separation of church and state junk,” which she said came from a “stinking letter” by Thomas Jefferson, not the Constitution. Demonstrating stare templo — to stand by the church — Boebert decreed that “the church is supposed to direct the government.”


Another creed comes from Sen. Ted Cruz (R-Tex.) who attacked Elmo because Sesame Street encouraged coronavirus vaccination. That’s stare contra pupas — stand against Muppets.


The court’s recent rulings invite many other Latin descriptors: stare atrocitate (to stand by cruelty), stare decuriatione (to stand by intimidation), stare deminutione capitis (to stand by the loss of liberties). But ultimately a court that has abandoned precedent stands for nothing (stare nullis) except for the raw exercise of power — stare imperio. And that leads to one place: stare ruina, to stand by destruction.

Ron DeSantis has ranted about “indoctrination” in the classroom, meaning instruction about the brutal facts of racism in American history. He promoted legislation to stop anti-racist teaching, which he calls WOKE.

Florida teachers are now subject to state-sponsored indoctrination. This is thought control.

Several South Florida high school educators are alarmed that a new state civics initiative designed to prepare students to be “virtuous citizens” is infused with a Christian and conservative ideology after a three-day training session in Broward County last week. Teachers who spoke to the Herald/Times said they don’t object to the state’s new standards for civics, but they do take issue with how the state wants them to be taught. “It was very skewed,” said Barbara Segal, a 12th-grade government teacher at Fort Lauderdale High School. “There was a very strong Christian fundamentalist way toward analyzing different quotes and different documents. That was concerning.”

The civics training, which is part of Gov. Ron DeSantis’ Civics Literacy Excellence Initiative, underscores the tension that has been building around education and how classrooms have become battlegrounds for politically-contentious issues.

In Florida, DeSantis and the Republican-led Legislature have pushed policies that limit what schools can teach about race, gender identity and certain aspects of history. Those dynamics came into full view last week, when trainers told Broward teachers the nation’s founders did not desire a strict separation of state and church, downplayed the role the colonies and later the United States had in the history of slavery in America, and pushed a judicial theory, favored by legal conservatives like DeSantis, that requires people to interpret the Constitution as the framers intended it, not as a living, evolving document, according to three educators who attended the training.

“It is disturbing, really, that through these workshops and through legislation, there is this attempt to both censor and to drive or propagandize particular points of view,” said Richard Judd, 50, a Nova High School social studies teacher with 22 years of experience who attended the state-led training session last week.

A review of more than 200 pages of the state’s presentations show the founding fathers’ intent and the “misconceptions” about their thinking were a main theme of the training. One slide underscored that the “Founders expected religion to be promoted because they believed it to be essential to civic virtue.”

Without virtue, another slide noted, citizens become “licentious” and become subject to tyranny. Another slide highlights three U.S. Supreme Court cases to show when the “Founders’ original intent began to change.”

That included the 1962 landmark case that found school-sponsored prayer violated the establishment clause of the First Amendment, which Judd said trainers viewed as unjust. At one point, the trainers equated it to the 1892 U.S. Supreme Court decision that upheld the constitutionality of racial segregation under the “separate but equal” doctrine. [Editor’s note: I think they mean Plessy v. Ferguson of 1896, which upheld separate-but-equal segregation by race.]

“Ending school prayer was compared to upholding segregation,” Judd said. In other words, he said, trainers called both those rulings unjust. On slavery, the state said that two-thirds of the founding fathers were slave owners but emphasized that “even those that held slaves did not defend the institution.”

This is one of the slides shown during the Florida Department of Education’s training series for civics and government teachers. DeSantis’ administration has spent nearly $6 million to train public school teachers across the state on how to teach civics as part of the governor’s initiative. The first training sessions were June 20-22, at Broward College in Davie. Teachers are in Hillsborough County are training this week. The civics training is the latest effort in a long line of education policies that aims to fight what DeSantis and conservative education reformers say are “woke ideologies” in public schools. It also provides a snapshot of how national groups, including Hillsdale College, a politically influential private Christian college in southern Michigan, are working with the DeSantis administration to reshape education in the state.

The goal is to put a greater emphasis on civics than on socially divisive issues such as race and gender identity, which DeSantis has said is an effort to reorient teaching away from “indoctrination and back towards education.” But to several educators who went through the state’s training it felt like a broader effort to impose a conservative view on historical events. “We are constantly under attack, and there is this false narrative that we’re indoctrinating children, but that is nothing compared to what the state just threw in new civic educators’ faces. That’s straight-up indoctrination,” said Segal, a 46-year-old teacher with 19 years of experience.

Read more at: https://www.miamiherald.com/news/local/education/article262941378.html#storylink=cpy

What is happening to the America that we swore allegiance to every day in public school? what happened to the America that was “indivisible, with liberty and justice for all”? How did we get a rogue Supreme Court that recklessly demolishes women’s rights, the separation of church and state, gun control, public safety, and efforts by government to prevent climate disasters? Who kidnapped the conservative Republican Party that believed in stability and tradition? From whence came the people who scorn the commonweal and ridicule Constitutional norms?

Former state legislator Jeanne Dietsch has an answer. Connect the dots by looking at what has happened to New Hampshire. The coup failed in Washington, D.C. on January 6, she writes. But it is moving forward in New Hampshire, with many of the same characters and all of the same goals.

If you read one post today, read this.

She writes:

During the last few weeks, US House leaders documented the nearly successful January 6 coup piece by piece, before our eyes. That personal power grab failed. Meanwhile, the steps clinching takeover of our government by radical reactionaries have nearly triumphed. A plan decades in the making. A plan nearly invisible to the ordinary public.


I can barely believe myself how this story weaves from Kansas to Concord to DC to the fields of southern Michigan over the course of six decades. It starts in Witchita. Koch Industries is the largest privately held company in the US, with over $115 billion in revenues, mostly fossil-fuel related. For many years, two of the founders’ sons, Charles and David Koch, each owned 42% of the company.


The younger, David, studied in the engineering department of MIT for 5 years, simultaneous with young John H. Sununu. Both finished their Master’s degrees in 1963.

1980: THE KOCHS SET THEIR GOALS


Seventeen years later, David Koch ran for Vice President of the US on the Libertarian ticket. The campaign was largely funded by Koch interests. The Libertarian platform of 1980, shown below, may look disturbingly familiar to those following news today.

Open her post to read the Koch Libertarian platform of 1980.

Libertarians demanded the abolition of Medicare, Medicaid, Social Security, public schools, aid to children, the Post Office, the Environmental Protection Agency, the Department of Energy, and more.

The infrastructure for achieving that platform was founded two years later. It was called the Federalist Society. It was a plan by a “small but influential group of law professors, lawyers, and judges.” Its goal?

To train members of their professions to believe in “originalism.” Originalists “strictly construe” the Constitution as they believed the Framers designed it way back in 1787. This matched David Koch’s 1980 platform. It would leave corporations free to do whatever profited them most without regard for social costs or regulations. Older Federalist Society members used their influence to advance their followers to higher judgeships.

SUNUNU FAMILY ROLES


Meanwhile, John Sununu became governor of New Hampshire, then Chief of Staff for President George W. Bush. In that role, John thwarted a plan for the US to join the international conference to address climate change in 1989. Actions like this, that benefitted Koch and the rest of the fossil-fuel industry, would become a hallmark of the Sununu family.


In 1993, an executive of Charles and David’s Koch Industries Michigan subsidiary, Guardian Industries, became a founding trustee of the Josiah Bartlett Center for Public Policy [JBC] in NH. Its mission was to advance many of the policies listed on David Koch’s platform of 1980. John Sununu, and later his son James, would chair the JBC board through today. Another of Sununu’s sons, Michael, would become a vocal climate denier and industry consultant. Still another, Senator John E. Sununu, would oppose the Climate Stewardship Act of 2003. But the Sununus were not coup leaders, just complicit.

BUILDING INFRASTRUCTURE FOR THE COUP


But let’s jump back to the Federalist Society. Its mission was succeeding. They were stacking the lower courts.?..Those justices hired young lawyers as clerks. From 1996-97, Thomas employed a Federalist Society clerk named John Eastman.


Twenty-three years later, Eastman would meet secretly with President Donald Trump. He would convince him that Vice President Pence could refuse to accept electoral college ballots on January 6. But back in 1999, Eastman became a senior fellow at the Claremont Institute. “The mission of the Claremont Institute is to restore the principles of the American Founding to their rightful, preeminent authority in our national life.”


Now we’re almost at the secret clubhouse of the coup. The Claremont Institute was run by a fellow regressive named Larry Arnn.(Photo below) In late 1999, Arnn was in the process of replacing the president of Hillsdale College because of a scandal that made national news. Hillsdale promotes conservative family values. Yet its leader was having an affair with his daughter-in-law. She committed suicide. Hillsdale was the central hub for Libertarian radicals so they needed a strong leader to pull them out of the mud.

Please read the rest of this fascinating post. There is one blatant error: she refers to “Clarence Thomas and Stephen Breyer” as Koch justices, but Breyer was a liberal justice appointed by Clinton. She must have meant the crackpot Alito.

As expected, the US Supreme Court overturned Roe v. Wade, which stood for half a century as a guarantee of women’s reproductive rights. About half or more states have already passed or are about to pass laws banning abortions, even for women who were victims of rape or incest, even for women whose life is in danger. The “right to life” so prized by anti-abortion activists does not include the life of the woman.

As was not quite so expected, the Supreme Court gutted the Miranda rights of people who are arrested. Police may fail to tell prisoners of their legal rights, including their right to remain silent.

The Trump Court is remaking and redefining the law in a radical way. There is nothing “conservative” about their willingness to toss out precedent. There is something very radical about the jackhammer they are using to change social and legal norms.

Women will die because of the Court’s decision to throw out Roe, which several of them pledged in public not to do. The old coat hanger routine and the unlicensed abortionists will return. Women who can afford to flee to a state where abortion is available will do so. Those who can self-medicate with Internet anti-abortion drugs will do so, although some states are trying to ban Internet abortion drugs (will they open every package to every woman of child-bearing age?).

The Court’s decision on New York’s gun law is terrifying. Be prepared to see armed men (and women, don’t forget Congresswoman Lauren Bobert) strolling through your neighborhood or shopping malls. If the six justices actually think that open carry is a fine idea, why won’t they permit it in their own courtroom?

Make no mistake: the current majority on the Supreme Court is not conservative; it is radical, in its reckless disregard for precedent and the safety of citizens.

The Court is not libertarian; its decisions require millions of people to abide by their cramped view of the way things ought to be. The state must fund religious schools, no matter how bigoted and discriminatory they are, if the state funds any private schools. States and cities must not protect their public by enacting laws that prevent them from openly carrying a deadly weapon.

We can expect even more intrusive decisions, valuing property rights over human rights, corporate rights over workers’ rights.

We will be living with this narrow-minded, bossy, intrusive Court for many years. My generation has failed. I look to the enlightened young people, the product of America’s much-maligned public schools, to reverse course in the future and preserve this fragile experiment in democracy from the ideologues who seek to destroy it.

For an insightful assessment of how the Supreme Court’s decision on abortion will affect women in Texas, read this article in The Texas Monthly.

An excerpt:

An excerpt: As trigger laws go into effect around the country, Texans seeking surgical abortions will likely find themselves in either Kansas or New Mexico, the two nearest states where the procedure will remain legal—though both have a limited number of clinics, which is likely to make scheduling an appointment difficult. Kansas has four clinics, which currently serve 530,000 potential patients of reproductive age. Now the state’s clinics will be the nearest alternative for 7.7 million such patients, according to theGuttmacher Institute, a nonprofit group that researches reproductive health. New Mexico, which has seven clinics, will be the nearest option for 1.9 million potential patients, the vast majority of whom will be Texans.

What about abortion pills?

Medication abortions, which are nonsurgical and administered by taking a two-dose regimen of pills that terminate a pregnancy, are currently illegal in Texas after the seventh week of pregnancy; after HB 1280 goes into effect on July 24, medication abortions, which are currently the most common type of abortions in Texas, are included in the total ban on the procedure in the state.

As of last December, Texas law also forbids the shipment of pills that induce an abortion “by courier, delivery, or mail service.” It’s unclear how Texas officials plan to enforce this law, as many U.S. and international organizations offer the pills by mail, or whether those who seek care after a self-administered abortion could face criminal charges under HB 1280, depending on how the law is applied.

Legislators see the Supreme Court ruling as a green light to outlaw abortion and criminalize anyone who performs one. The penalties are as stiff as murder.

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

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

Breyer writes:

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

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

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

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

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

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

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SUPREME COURT OF THE UNITED STATES

_________________

No. 20–1088 _________________

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

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

[June 21, 2022]

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

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

I A

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

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 AyeInc. v. Hialeah, 508 U. S. 520, 542 (1993); alteration in original). We have said that, in the education context, this means that States generally cannot “ba[r] religious schools from public benefits solely because of the religious character of the schools.” Espinoza v. Mon- tana Dept. of Revenue, 591 U. S. ___, ___ (2020) (slip op., at 9); see Trinity Lutheran, 582 U. S., at ___–___ (slip op., at 9–10).

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

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

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

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

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.

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B

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

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

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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BREYER, J., dissenting

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

B

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

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

16 CARSON v. MAKIN BREYER, J., dissenting

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

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

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

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

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

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

18 CARSON v. MAKIN BREYER, J., dissenting

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

***

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

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

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

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

4 CARSON v. MAKIN SOTOMAYOR, J., dissenting

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

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

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

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

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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.