Malnak v. Yogi
1977 U.S. Dist. LEXIS 13367, 440 F. Supp. 1284 (1977)
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Rule of Law:
A government-sponsored program taught in public schools violates the Establishment Clause of the First Amendment if its core teachings posit the existence of an ultimate reality, supreme being, or creative force, and its practices include mandatory, devotional ceremonies, regardless of whether the program is presented as a secular science or philosophy.
Facts:
- During the 1975-76 academic year, five New Jersey public high schools offered an elective course titled 'Science of Creative Intelligence/Transcendental Meditation' (SCI/TM).
- The course was developed by Maharishi Mahesh Yogi and taught by instructors who were trained and paid by the World Plan Executive Council-United States (WPEC-US), a private organization, not by the school districts.
- The course textbook described an unmanifest, eternal, omnipresent, and all-powerful field of 'pure creative intelligence' as the ultimate reality and source of everything in the universe.
- The textbook taught that through the practice of Transcendental Meditation, an individual could directly contact this field of pure creative intelligence.
- As a mandatory prerequisite for learning the meditation technique, every student had to attend a private ceremony known as a 'puja.'
- During the puja, the teacher sang a chant in Sanskrit before a table holding offerings such as fruit, flowers, and incense, and a picture of Maharishi Mahesh Yogi's deceased teacher, Guru Dev.
- An English translation of the chant revealed it to be an invocation that repeatedly bows down to 'the Lord,' deifies Guru Dev, and references Hindu deities.
- At the conclusion of the puja, each student was privately given a secret 'mantra,' a sound aid considered essential for practicing Transcendental Meditation.
Procedural Posture:
- Taxpayers, parents, and organizations (plaintiffs) sued Maharishi Mahesh Yogi, the World Plan Executive Council, five New Jersey school boards, and various state and federal education agencies (defendants) in the U.S. District Court for the District of New Jersey.
- The plaintiffs sought an injunction to prohibit the teaching of the SCI/TM course in public schools, claiming it violated the Establishment Clause.
- The plaintiffs moved for partial summary judgment to decide the constitutional issue as a matter of law.
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Issue:
Does the teaching of the "Science of Creative Intelligence/Transcendental Meditation" (SCI/TM) course, which includes a textbook describing a concept of ultimate reality and a mandatory initiation ceremony, in New Jersey public schools violate the Establishment Clause of the First Amendment?
Opinions:
Majority - Meanor, District Judge.
Yes. The teaching of the SCI/TM course in public schools is a religious activity that violates the Establishment Clause of the First Amendment. The court determined that both the course's content and its required ceremony are religious in nature, making their inclusion in the public school curriculum unconstitutional. The court reasoned that the concept of 'creative intelligence' as described in the textbook—an eternal, infinite, all-pervasive source of life and knowledge—is functionally equivalent to the concept of God or a supreme being in recognized religions. Labeling these concepts as 'science' or 'philosophy' does not strip them of their inherently religious character. Furthermore, the mandatory 'puja' ceremony is not a secular act of gratitude but a religious ritual involving invocation, offerings, and worship of a deified figure, which is a form of prayer. Applying the three-pronged Lemon test, the court found the course unconstitutional because (1) its secular purpose of stress reduction was pursued through religious means, (2) its primary effect was to advance religious concepts, and (3) it resulted in excessive government entanglement with religion through its funding and integration into the school curriculum.
Analysis:
This decision established a significant precedent that the determination of whether a belief system or practice is 'religious' under the Establishment Clause depends on its objective substance, not the subjective characterizations of its proponents. By looking past the 'scientific' label of SCI/TM, the court affirmed that the First Amendment prohibits the promotion of belief systems that deal with ultimate realities and involve devotional practices in public schools. This ruling provides a crucial analytical framework for evaluating other ostensibly secular programs, such as certain forms of yoga or mindfulness, to ensure they do not cross the constitutional line into religious instruction. It solidifies the principle that government neutrality requires schools to avoid teaching concepts that are the functional equivalent of religious dogma, even if they are part of a 'new' or unconventional system of thought.
