Caleigh Wood v. Evelyn Arnold
915 F.3d 308 (2019)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Presenting religious information, including core tenets and comparative statements, as part of a secular world history curriculum does not violate the First Amendment's Establishment Clause or Free Speech Clause, provided the material serves an academic purpose, does not have the primary effect of endorsing religion, and does not compel a student to profess a belief.
Facts:
- During the 2014-2015 school year, Caleigh Wood was an eleventh-grade student in a mandatory world history course at La Plata High School, a public school in Maryland.
- The course included a five-day unit entitled 'The Muslim World,' which explored the history of Middle Eastern empires and the basic concepts of the Islamic faith.
- As part of this unit, a PowerPoint slide presented to the class contained the statement that 'Most Muslim's [sic] faith is stronger than the average Christian.'
- Wood was also required to complete a worksheet on Islam that included a 'fill-in-the-blanks' exercise for the shahada, the Islamic declaration of faith: 'There is no god but Allah and Muhammad is the messenger of Allah.'
- Wood's father objected to the assignments, believing they violated his daughter's Christian beliefs.
- Wood refused to complete the assignments related to Islam and received a lower percentage grade for the course as a result, although her final letter grade was not affected.
Procedural Posture:
- Caleigh Wood sued school officials Evelyn Arnold and Shannon Morris in U.S. District Court.
- Wood alleged that the curriculum violated her First Amendment rights under the Establishment Clause and the Free Speech Clause.
- The district court granted summary judgment in favor of the defendant school officials.
- Wood, as the appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Fourth Circuit.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a public high school's world history curriculum, which includes a statement comparing the faith of Muslims and Christians and a worksheet requiring students to fill in blanks of the Islamic statement of faith (the shahada), violate a student's First Amendment rights under the Establishment Clause or the Free Speech Clause?
Opinions:
Majority - Judge Barbara Milano Keenan
No, the curriculum does not violate the student's First Amendment rights. The coursework, when viewed in the proper academic context, did not impermissibly endorse a religion or compel religious speech. For the Establishment Clause claim, the court applied the Lemon test and found all three prongs were satisfied. First, the school had a genuine secular purpose: teaching world history, including the role of religion in the development of empires. Second, the primary effect of the materials was not to endorse Islam; a reasonable observer would understand the materials were part of a secular academic curriculum and not a devotional exercise. The court stressed the importance of context, noting the materials were a small part of a year-long course. Third, the curriculum did not create an excessive entanglement between government and religion. Regarding the Free Speech Clause claim, the court held that the assignment did not constitute compelled speech because it was a purely academic exercise designed to test a student's knowledge of the curriculum, not to force her to profess or adopt any belief.
Analysis:
This decision reaffirms the principle that public schools can teach about religion without violating the Constitution, distinguishing academic instruction from religious indoctrination. The court's emphasis on analyzing challenged materials within their broader curricular context provides schools with significant deference in designing history and social studies lessons. This precedent makes it more difficult for plaintiffs to succeed by isolating specific statements or assignments they find offensive, requiring instead a showing that the overall purpose or effect of the instruction is to endorse religion. The ruling also clarifies the scope of the compelled speech doctrine in schools, establishing that requiring students to demonstrate knowledge of religious tenets for academic purposes is not the same as forcing them to affirm those beliefs.
