Religious coercion in a U.S. public school
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30-01-2014, 05:34 PM
Religious coercion in a U.S. public school
When I first came across this story, I said to myself, "Well, it's sad, but what can you expect in a private Christian fundie school?" But then I read further and realized this is a PUBLIC school, funded by U.S. taxpayers.

Here's the legal complaint filed by the boy's parents. You'll get the story in the brief Introduction in the first of couple of pages. Read it and weep.

https://www.laaclu.org/resources/2014/01...plaint.pdf

Religious disputes are like arguments in a madhouse over which inmate really is Napoleon.
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30-01-2014, 05:37 PM
RE: Religious coercion in a U.S. public school
My virus protection won't let me click that link...anybody wanna give me the short story on what it's about?

~Philosophy is questions that may never be answered. Religion is answers that may never be questioned.~
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30-01-2014, 05:49 PM
RE: Religious coercion in a U.S. public school
(30-01-2014 05:37 PM)kellyrm Wrote:  My virus protection won't let me click that link...anybody wanna give me the short story on what it's about?

Cliff Notes:
They are force feeding a Buddhist student, a faintly-Christian student, and an atheist student Bible verses, creationism, etc. within the school system, with the blessing of the Supervisor. All 3 are members of an extended family, and are being subject to all sorts of bad behavior, which seems to be encouraged by the staff. The parents are suing, with the assistance of the ACLU.

We have enough youth. How about looking for the Fountain of Smart?
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30-01-2014, 06:34 PM
RE: Religious coercion in a U.S. public school
(30-01-2014 05:37 PM)kellyrm Wrote:  My virus protection won't let me click that link...anybody wanna give me the short story on what it's about?

Some virus protection software treats PDF files like potentially harmful executables. Don't know why...

The story is actually quite frustrating. Basically an entire public school and district using taxpayer money to run christian schools and really fuck up students with creationism, bible knowledge tests in science class, and false claims about evolution. The superintendent also approved of the teachers ridicule and indoctrination of students of other faiths, and actually suggested that a student either put up with it, change religion, or change school. Kid changed school, to one which is still run by the same ass-hat.
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30-01-2014, 08:14 PM (This post was last modified: 30-01-2014 08:22 PM by Taqiyya Mockingbird.)
RE: Religious coercion in a U.S. public school
(30-01-2014 05:37 PM)kellyrm Wrote:  My virus protection won't let me click that link...anybody wanna give me the short story on what it's about?


I copy/pasted the text from the .pdf here for you:

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DIVISION
SCOTT LANE, on his own behalf and on
behalf of his minor children, S.L. and M.L.;
AND SHARON LANE, on her own and on
behalf of her minor child, C.C.,
Plaintiffs,
– Versus –
SABINE PARISH SCHOOL BOARD;
SARA EBARB, in her official capacity as
Superintendent of the Sabine Parish School
District; GENE WRIGHT, in his official
capacity as Principal of Negreet High School;
and RITA ROARK, in her official capacity as
a teacher at Negreet High School,
Defendants.
NUMBER: 5:14-cv-00100
JUDGE:
MAGISTRATE JUDGE:
VERIFIED COMPLAINT



INTRODUCTION
1. Students of all faiths should feel safe and wel
come in our public schools. At
Negreet High School (“Negreet” or “NHS”) in Sabine
Parish, Louisiana, however, school
officials have a longstanding custom, policy, and p
ractice of promoting and inculcating Christian
beliefs by sponsoring religious activities, as well
as conveying religious messages to students. For
example, at Negreet, which serves students in kinde
rgarten through twelfth grade, teachers ask
students for professions of faith in class. At lea
st one science teacher treats the Bible as scientif
ic
fact, telling students that the Big Bang never happ
ened and that evolution is a “stupid” theory that
“stupid people made up because they don’t want to b
elieve in God.” Paintings of Jesus Christ,
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 1 of 20 PageID #: 1
2
Bible verses, and Christian devotional phrases ador
n the walls of many classrooms and hallways,
including the main hallway leading out to the bus p
ick-up area. A lighted, electronic marquee
placed just outside the building scrolls Bible vers
es every day. And staff members routinely lead
students in Christian prayer. The school district’
s administration – all the way up to the
Superintendent of Schools – not only knows about th
ese activities, but endorses and encourages
all of this.
2. So engrained is official promotion of religion
at Negreet that when Plaintiff C.C.,
1
a Buddhist of Thai descent, enrolled in the sixth g
rade this past August, he quickly became the
target of proselytizing and harassment by one of hi
s teachers, Defendant Rita Roark, who even
ridiculed C.C. in class for his non-Christian belie
fs and has told her students that his faith,
Buddhism, is “stupid.”
3. After learning of Negreet’s unlawful practices
and treatment of their son, C.C.’s
parents, Scott and Sharon Lane, rose to his defense
, taking their concerns to Defendant Sara
Ebarb, the Sabine Parish Superintendent of Schools.
But she took no corrective action. On the
contrary, she told the Lanes that “[t]his is the Bi
ble Belt” and that they would simply have to
accept that teachers would proselytize students. S
he also asked whether C.C. had to be raised as a
Buddhist and whether he could “change” his faith, a
nd she suggested that C.C. transfer to another
district school – more than 25 miles away where, in
her words, “there are more Asians.” The day
after meeting with the Lanes, the Superintendent se
nt a letter to Negreet Principal Gene Wright
stating that she approved of Negreet’s official rel
igious practices. Wright read the letter to the
entire Negreet student body over the school’s publi
c-address system.
4. Plaintiffs believe that their children should b
e able to attend public school without
1
Per L.R. 5.7.12(b), Plaintiffs who are minors are
identified only by their initials in this
document and in all other public filings.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 2 of 20 PageID #: 2
3
unwelcome exposure to government-sponsored religiou
s practices and messages and without
harassment for their religious beliefs. Indeed, the
Establishment Clause of the First Amendment to
the U.S. Constitution guarantees that public-school
students have an unequivocal right to attend
school free from official imposition or promotion o
f religion. Defendants’ custom, policy and
practice of promoting and inculcating Christian rel
igious beliefs, while denigrating students of
non-Christian faiths, plainly violates this right.
Matters of faith are deeply personal and the
decision regarding which religious beliefs, if any,
to follow belongs to students and their families,
not school officials.
5. Accordingly, Plaintiffs seek a declaratory judg
ment that the Defendants’ policies
and practices are unconstitutional because they are
religiously coercive, endorse and promote
religion, and have the purpose and effect of advanc
ing religion. Plaintiffs further seek preliminary
and permanent injunctive relief enjoining Defendant
s from continuing their unlawful practices;
nominal and compensatory damages; and other relief
as set forth below.
JURISDICTION AND VENUE
6. Plaintiffs bring this matter under 42 U.S.C. §19
83 (2014), for violations of civil
rights under the First and Fourteenth Amendments to
the U.S. Constitution.
7. This Court has jurisdiction over this action pu
rsuant to 28 U.S.C. § 1331 (2014)
(federal question); Section 1343 (civil rights); an
d Sections 2201 and 2202 (Declaratory Judgment
Act).
8. Venue is proper in this district under 28 U.S.C
. § 1391(b)(1) and (2) (2014), and
the Local Civil Rules for the Western District of L
ouisiana. Plaintiffs and Defendants reside in
this district and division, and the unlawful practi
ces that give rise to the claims herein occurred
within this district and division.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 3 of 20 PageID #: 3
4
PARTIES
9. Plaintiffs Scott and Sharon Lane are married an
d reside within the Sabine Parish
School District. Scott Lane is the natural parent
of minor Plaintiffs S.L. and M.L. and step-parent
to C.C. Sharon Lane is the legal parent of minor P
laintiff C.C. and step-parent to S.L. and M.L.
10. Plaintiff C.C. is a student currently enrolled
in the Sabine Parish School District.
His mother, Plaintiff Sharon Lane, sues on his beha
lf, as well as on her own behalf. From August
8, 2013, through approximately September 3, 2013, C
.C. was a student at Negreet, where he was
subject to the customs, policies, and practices of
all Defendants.
11. C.C. is of Thai descent and is a Buddhist. Shar
on Lane became a practicing
Tibetan Buddhist approximately fourteen years ago.
Both C.C. and Sharon deeply value their
Buddhist religious beliefs. They object to and are
offended by Defendants’ conduct because it
denigrates their faith and promotes religious belie
fs to which they do not subscribe. Defendants’
unlawful practices have made C.C. and Sharon feel m
arginalized and unwelcome within the
School District simply because they do not share th
e same religious beliefs as many school
officials.
12. Specifically, as a sixth-grade student at Negre
et, C.C. felt extremely uncomfortable
because he was routinely subjected to unwelcome rel
igious messages by school officials. He felt
coerced, both directly and indirectly, into partici
pating in religious activities and expression that
did not comport with his personal religious beliefs
. C.C. was distraught when schools officials
mocked and disparaged his Buddhist faith. Defendan
ts’ unyielding imposition of Christian
beliefs and shocking treatment of C.C. caused him t
o become physically ill and to dread attending
school.
13. Instead of ceasing these unlawful practices, D
efendants vowed to continue them.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 4 of 20 PageID #: 4
5
Defendant Ebarb told C.C.’s parents that he could e
ither continue suffering the official
proselytizing and harassment at Negreet or transfer
to another District school where “there are
more Asians.” She also asked if C.C. “has to be ra
ised a Buddhist,” or whether he could
“change” his faith. C.C.’s parents were incredulou
s and dismayed by Ebarb’s suggestion.
However, unwilling to subject C.C. to further emoti
onal and physical distress, the Lanes agreed to
transfer him to another school.
14. C.C. is currently enrolled as a sixth-grader at
Many Junior High School (“Many”
or “MJHS”), where he remains subject to the customs
, policies, and practices of Defendants
Sabine Parish School Board and Superintendent Ebarb
. To attend MJHS, C.C. must be driven to
school by a parent every day, more than 30 minutes
each way from his home. During the day, he
is separated from his siblings, who remain at Negre
et. And, even at MJHS, District officials
continue to promote Christianity and impose religio
us exercise on students.
15. Like C.C., his mother Sharon Lane is also extre
mely uncomfortable with and
offended by Defendants’ disparagement of Buddhism a
nd pervasive promotion of Christianity, to
which both she and her son have been exposed. Lane
is committed to raising C.C. as a Buddhist
and believes that Defendants are interfering with h
er right to direct her son’s religious education.
Defendants’ refusal to cease this unlawful conduct
has not only caused C.C. to suffer substantial
anguish, but also has caused the family to take on
additional financial and administrative burdens
in order to transport C.C. each day more than 25 mi
les to a different school than his siblings.
16. Plaintiffs S.L. and M.L. are minor children and
brothers to C.C. They are both
enrolled at Negreet High School, where they are sub
ject to the customs, policies, and practices of
Defendants Sabine Parish School Board, Superintende
nt Ebarb, and Principal Wright. Although
M.L. attends church, he believes that faith is a pe
rsonal matter. He believes that he should be able
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 5 of 20 PageID #: 5
6
to decide, with the guidance of his parents and rel
igious leaders, which beliefs he will follow and
when, as well as how to express those beliefs, with
out pressure from his teachers and school
officials. S.L. is a non-believer who does not sub
scribe to the religious beliefs promoted by
schools officials.
17. S.L. and M.L. feel very uncomfortable and coerc
ed, both directly and indirectly,
by school officials’ repeated efforts to impose the
ir religious beliefs on students in the form of
official prayer, displays of religious iconography,
and other religious activities. They are also
upset and offended by school officials’ disparageme
nt of their brother, C.C., and his faith. S.L.
and M.L. feel like outsiders in their school becaus
e of Defendants’ conduct.
18. Plaintiff Scott Lane sues on behalf of his mino
r children, S.L. and M.L., and on his
own behalf. Lane objects to and is offended by Def
endants’ policies and practices alleged herein
because they promote religious beliefs to which he
does not subscribe and impede his right to
control his children’s religious education and upbr
inging free from governmental intrusion or
interference.
19. Plaintiffs have been rendered outsiders at Neg
reet and within the School District
because of Defendants’ longstanding custom, policy,
and practice of promoting and inculcating
Christian beliefs by sponsoring and encouraging pra
yer, proselytizing students, and imposing
other religious messages and iconography on them.
If this custom, policy, and practice remains
in place, Plaintiffs will continue to suffer these
harms through this school year and beyond.
20. Defendant Sabine Parish School Board is a Sabi
ne Parish governmental
organization with the power to sue and be sued. Th
e Board controls, operates, and supervises all
District schools, including Negreet High School and
Many Junior High School. The Board is
responsible for prescribing and enforcing rules and
regulations at all District schools.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 6 of 20 PageID #: 6
7
21. Defendant Sara Ebarb is a resident of Sabine P
arish and Superintendent of the
Sabine Parish School Board. She is responsible for
, among other things, implementing and
enforcing Board rules, regulations, and policies.
She is sued in her official capacity.
22. Defendant Gene Wright is a resident of Sabine
Parish and the Principal of Negreet
High School. He is the decision-maker on day-to-da
y operational issues at Negreet and is
responsible for enforcing school rules, regulations
, and policies. He is sued in his official
capacity.
23. Defendant Rita Roark is a resident of Sabine P
arish and a sixth-grade teacher at
Negreet. She is in charge of the education of chil
dren in her classroom. She is sued in her
official capacity.
24. At all relevant times, Defendants were acting
and continue to act under color of
law.
ADDITIONAL FACTUAL ALLEGATIONS
25. Plaintiffs re-allege and incorporate by refere
nce all of the preceding paragraphs of
this Complaint as if fully set out herein.
26. Defendants have a longstanding custom, policy,
and practice of promoting and
inculcating Christian beliefs by coercing and encou
raging prayer and religious exercise,
proselytizing students, and subjecting students to
religious iconography and other religious
messages. Among other unlawful activities, Defenda
nts routinely incorporate official prayer and
proselytization into class and school events, teach
Biblical doctrine as fact, display religious
messages and iconography in classrooms and hallways
, and degrade minority faiths.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 7 of 20 PageID #: 7
8
A.
Defendant Roark’s Unlawful Promotion of Religion an
d Denigration of
Minority Faiths During Science Class
27. Defendant Roark regularly promotes creationism
and other Christian beliefs in her
sixth-grade science class.
28. For example, during science class, Roark has re
peatedly taught students that the
Big Bang never happened and that the Universe was c
reated by God approximately 6,000 years
ago.
29. Roark has also told her students that evolutio
n is “impossible” and a “stupid”
theory that “stupid people made up because they don
’t want to believe in God.” She has informed
her students that, “if evolution was real, it would
still be happening: Apes would be turning into
humans today.” And she simply skipped over the evol
ution chapter in the students’ science
textbook.
30. In addition, Roark regularly administers scienc
e tests that include fill-in-the-blank
Biblical verses and other religious affirmations as
test questions.
31. On one occasion, the final question of an exam
required students to fill in the blank
to this question: “ISN’T IT AMAZING WHAT THE ______
_______ HAS
MADE!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!”
See
Ex. A
, a copy of the exam.
32. Having been raised a Buddhist, C.C. was uncert
ain about the expected answer and
left the question blank. When the test was returne
d to him, Roark had marked the question wrong
and written “LORD” in red ink as the correct answer
.
See
Ex. A
. She also scolded C.C., with the
entire class listening, for not writing in the corr
ect answer. C.C.’s sister, who is also in Roark’s
class, explained that her brother is a Buddhist and
does not believe in God. After Roark returned
to her desk, a student remarked, “you’re stupid if
you don’t believe in God.” Roark looked up
and shook her head yes in affirmation of the studen
t’s remark.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 8 of 20 PageID #: 8
9
33. C.C. felt sick and humiliated after the incide
nt.
34. When C.C. later showed the exam to his mother,
she instructed him that he need
not answer such inappropriate questions. However,
when C.C. expressed his concerned that he
would lose points on his tests, Sharon told her son
he could write “Buddha,” consistent with their
religious beliefs, if the question were posed again
.
35. C.C. did just that on a subsequent science tes
t featuring the same question. In the
blank, he wrote “Lord Boda [sic].” Roark marked the
answer incorrect by placing a large, red
question mark near it.
See
Ex. B
, a copy of the test. As Roark was returning the t
ests to students,
one student declared again, for the whole class to
hear, that “people are stupid if they think God is
not real.” Roark agreed, responding, “Yes! That is
right! I had a student miss that on his test.”
Most of the students, who were present when Roark h
ad previously ridiculed C.C. for failing to
write “Lord” as the correct answer, broke out in la
ughter.
36. As a result of Roark’s conduct, C.C. became an
xious and nauseated every morning
before school. When his mother asked why he was si
ck, he told her in more detail what Roark
had been doing in science class.
B. Defendants’ Refusal to Stop Roark’s Unlawful Act
ivities
37. Outraged over Roark’s treatment of C.C., Scott
and Sharon Lane contacted
Superintendent Ebarb and explained what had happene
d. Although Ebarb indicated that she
would look into the matter, she also told them that
“this is the Bible Belt,” and recommended that
they simply tolerate Roark’s proselytization and ha
rassment.
38. Unsatisfied, the Lanes met with Ebarb to follo
w up. They discussed Roark’s
treatment of C.C., as well as the general promotion
of Christianity by faculty and administrators
at Negreet. During the meeting, Ebarb was unrecept
ive to Plaintiffs’ concerns and repeated her
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 9 of 20 PageID #: 9
10
earlier admonition that they were “in the Bible Bel
t” and should simply accept the pervasiveness
of official Christianity in Sabine Parish public sc
hools.
39. Ebarb defended Roark specifically, declaring t
hat “[t]eachers have religious
freedom.” She further stated that “if they were in
a different country,” Plaintiffs would see “that
country’s religion everywhere,” and that, therefore
, they “shouldn’t be offended” to “see God
here.” Purporting to illustrate her point further,
she noted that, because she did not find it
offensive that “the lady who cuts [her] toenails ha
s a statue of Buddha,” Plaintiffs should not be
bothered by Roark’s in-class proselytization. She
then wondered whether C.C. “has to be raised
Buddhist” and even asked whether he could “change”
his faith. The Lanes were floored by
Ebarb’s implication that C.C. should change his fai
th to fit in.
40. In the end, the only recourse Ebarb offered Pl
aintiffs was to transfer C.C. to a
different school 25 miles away where, in her words,
“there are more Asians.” She did not,
however, offer to provide school bus transportation
or, alternatively, funds to cover Plaintiffs’
private expense of transporting C.C. to the new sch
ool.
41. Ebarb’s dismissive and offensive response to P
laintiffs’ concerns did not end there.
The day after her meeting with Ebarb, Principal Wri
ght read a letter from Ebarb over Negreet’s
public-address system. The letter stated that Ebar
b approved of Wright’s practices in general and
that she approved of the fact that the teachers at
Negreet acted consistent with their strong
religious beliefs.
42. Concerned about the increasingly hostile envir
onment Defendants were creating
for C.C., and hoping to save him from suffering add
itional psychological harm, his parents
decided to remove him from Negreet and enroll him a
t Many Junior High School. At great
personal expense of both cost and time, the Lanes n
ow drive C.C. daily 25 miles each way to
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 10 of 20 PageID #: 10
11
school.
C. Roark’s Continued Promotion of Religious Belief
s
43. Despite Plaintiffs’ objections, Defendant Roar
k continues to promote religious
beliefs to students during science class and at oth
er times.
44. In recent months, she has repeatedly instructe
d students that evolution is not valid
as a scientific theory and that God made the world
6,000 years ago.
45. She demands that students write a Bible verse
or “Isn’t it amazing what the Lord
has made” at the bottom of exams and assignments if
they want extra credit. Roark writes “Yes!”
next to the verse or religious affirmation and awar
ds students five additional points when they
comply with this mandate.
46. In social studies class, which Roark also te
aches, she presents Biblical accounts of
persons, places, and events as fact. For example,
on a handout asking, “What mountain did
Moses supposedly get the Ten Commandments from,” Ro
ark crossed out the word “supposedly.”
She also has told students that the Bible is “100%
true” and that “scientists are slowly finding out
that everything in the Bible is accurate.”
47. Further, she continues to ridicule non-Chris
tians for their beliefs. Last month,
during a social studies lesson about Hinduism and B
uddhism, after asking a student to read aloud
from the textbook, Roark would make derogatory comm
ents about the discussed minority faith.
For instance, she told the class during a discussio
n of Siddhartha that Buddhism is “stupid,” and
that “no one can stay alive that long without eatin
g.”
D. Displays of Religious Iconography and Messages a
t Negreet
48. Roark’s conduct is part of a pervasive custom,
policy, and practice of official
promotion and inculcation of religion generally, an
d Christianity, specifically, by District
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 11 of 20 PageID #: 11
12
officials.
49. For example, the District’s belief statement, p
osted on its website until this school
year, declares first that, “We believe that: God ex
ists.”
See
Ex. C
, a screenshot of the page.
50. A large painting of Jesus Christ hangs in the m
ain hallway and other depictions of
Christ have been displayed in classrooms and hallwa
ys at other times during the year.
See
Ex. D
,
a photograph of the painting that hangs in the main
hall.
51. A large, outdoor, variable-message electronic m
arquee on Negreet premises
regularly displays Bible verses. By way of example
,
see
Exhibit E
, a video of the marquee
displaying the message, “In all ways acknowledge Go
d, and he will direct thy path. Prov. 3, v6.”
52. Bible verses are also prominently displayed in
many school hallways and
classrooms. For example, posters displayed in the h
allways of the junior-high wing of Negreet
present the following Bible verses to students:
● 2 SAMUEL 22:31: AS FOR GOD, HIS WAY IS PERFECT
. . .
HE SHIELDS ALL WHO TAKE REFUGE IN HIM;
● PHILLIPIANS 4:6-7: DON’T WORRY ABOUT ANYTHING:
INSTEAD, PRAY ABOUT EVERYTHING;
● PSALM 137:8: THOUGH I WALK IN THE MIDST OF
TROUBLE, YOU PRESERVE MY LIFE;
● PSALM 51:10: CREATE IN ME A PURE HEART, O GOD,
AND
RENEW A STEADFAST SPIRIT WITHIN ME; and
● JEREMIAH 29:13: YOU WILL SEEK ME AND FIND ME
WHEN YOU SEEK ME WITH ALL YOUR HEART . . .
DECLARES THE LORD.
See
Ex. F
, a set of photographs of the above posters.
53. Another display in the main foyer of the schoo
l informs students that “ACTIONS
SPEAK LOUDER THAN WORDS.” It features several post
ers, including one of a child praying
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 12 of 20 PageID #: 12
13
that instructs students to “Pray,” another that urg
es them to “Worship,” and another that
encourages them to “Believe.”
See
Ex. F
.
54. Meanwhile, a poster displayed in the waiting a
rea of the main office announces
that “[i]t’s okay to pray.”
55. Principal Wright approved, or at least is awar
e of, these items. Superintendent
Ebarb is also aware of their presence, and neither
she nor Wright has made any effort to have
them removed.
E. School-Sponsored Prayer & Distribution of Relig
ious Literature
in Class and at School Events.
56. School officials also routinely incorporate Ch
ristian prayer into school functions or
class. Principal Wright encourages, condones, and
tolerates such prayers. Superintendent Ebarb
is also aware of and approves the practice and has
made no effort to curtail it.
57. For example, C.C.’s fifth grade math teacher,
Stacy Bray, asked her students to
bow their heads and pray aloud before lunch every d
ay. Bray selected a different student each
time to lead the class in prayer and participated i
n the prayers herself. Another teacher, Angela
Knight, leads her class in daily lunchtime prayer.
58. Nearly all student assemblies begin with praye
r. For example, this past spring,
Negreet held a mandatory Drug Abuse Resistance Educ
ation (D.A.R.E.) assembly at which
Principal Wright led the entire faculty and student
body in prayer. Wright frequently leads the
faculty and student body in prayer at other assembl
ies as well, including the school’s annual Class
Ring Ceremony, held in the springtime.
See
Ex. G
, a photo of students being led in prayer at the
Class Ring Ceremony. Student attendance at the Cla
ss Ring Ceremony is compulsory.
59. Mandatory pep rallies held before LEAP standar
dized testing also feature official
prayer led by a student over the public-address sys
tem.
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 13 of 20 PageID #: 13
14
60. Every Veterans Day, including the most recent,
school officials invite a local
Christian preacher to hold a group prayer at a mand
atory faculty/student assembly honoring the
Nation’s veterans.
See
Ex. H
, a video of this year’s clergy-led prayer at the V
eterans Day
assembly. This assembly also features video present
ations set to Christian pop music.
61. Once a year, Negreet administrators and facult
y organize a “See You at the Pole”
event, at which students and faculty gather at the
school’s flagpole before class to pray.
Attendance is compulsory for all students.
62. Almost every athletic event at Negreet opens wi
th an official prayer. The prayers
are often led by faculty, administration, or local
religious leaders.
63. The day Negreet was dismissed for the most rec
ent holiday break, Principal Wright
prayed to all of the students over the public-addre
ss system.
64. Negreet faculty members also sometimes distrib
ute religious literature to students.
For example, on one occasion earlier this school ye
ar, a faculty member gave M.L. and the rest of
his class copies of a book from the “Truth for Yout
h” program. Published by Revival Fires
International ministry of West Monroe, Louisiana, t
he “Truth for Youth” Bibles consist of the
entire New Testament, along with cartoon tracts tha
t promote Christian beliefs, denounce
evolution, spread scientifically inaccurate informa
tion about birth control and sex, and warn
students about the evils of rock music, drunkenness
, pornography, premarital sex, homosexuality,
sorcery, witchcraft, and other subjects.
2
F. Official Promotion of Religion at Many Junior H
igh School
65. At Many Junior High School, which C.C. current
ly attends, school officials also
2
A detailed summary of the Truth for Youth program
can be found at Truth for Youth
Bible, Revival Fires International, http://timtodd.
org/truthforyouth.html (last visited Jan. 18,
2014).
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 14 of 20 PageID #: 14
15
incorporate official prayer into school events. For
example, most, if not every, football game
begins with an official student-led prayer over the
public-address system. Prior to each prayer, an
announcer asks the entire audience to stand and bow
their heads.
See
Ex. I
, a video portraying
such prayer at a recent Many football game.
66. School-day assemblies, including the Veterans
Day celebration, also include
official prayer.
67. This past Christmas, Many Junior High School o
rganized and held on school
premises a “living nativity” scene depicting the bi
rth of Jesus Christ.
68. And before the holiday, C.C.’s teacher read hi
s class a story about the birth of
Christ. The story stated that candy canes are shap
ed like a “J” to symbolize Jesus.
CLAIM FOR RELIEF: ESTABLISHMENT CLAUSE VIOLATION
69. Plaintiffs re-allege and incorporate by referen
ce all of the preceding paragraphs in
this Complaint.
70. The conduct alleged above constitutes the offic
ial policy and practice of
Defendants, or is so persistent, widespread, and pe
rvasive as to constitute an official custom
regarding which Defendants have actual or construct
ive knowledge.
71. By Defendants’ conduct alleged above, they have
violated, and continue to violate,
Plaintiffs’ rights under the Establishment Clause o
f the First Amendment to the U.S. Constitution
and the Fourteenth Amendment to the U.S. Constituti
on. Defendants’ custom, policy, and
practice of promoting and inculcating Christian bel
iefs by sponsoring and encouraging prayer,
proselytizing students, and imposing other religiou
s messages and iconography on them is the
cause-in-fact of the constitutional violations.
72. Defendants’ conduct coercively exposes Plaintif
fs to unwanted religious exercises,
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 15 of 20 PageID #: 15
16
instruction, and messages.
73. Defendants’ conduct also improperly endorses re
ligion. A reasonable, objective
student, parent, or other observer aware of the con
duct alleged above would conclude that the
Defendants have endorsed, and continue to endorse,
religion by sending the message that
Christians are officially favored, and non-Christia
ns disfavored, by school officials.
74. Defendants’ conduct, in addition, has the prima
ry purpose and effect of promoting
and advancing religion and excessively entangles th
e School Board with religion.
75. Unless restrained by this Court, Defendants wil
l continue to subject Plaintiffs to
this unlawful conduct, causing Plaintiffs irreparab
le harm by denying their fundamental
constitutional rights to be free from governmental
promotion of religious beliefs and messages,
governmental coercion of religious practices, and g
overnmental denigration of their faith.
76. Plaintiffs have no adequate remedy at law for t
he denial of their fundamental
constitutional rights.
RELIEF REQUESTED
77. Plaintiffs respectfully request the following
relief in the form of a judgment against
the Defendants Sabine Parish School Board, Sara Eba
rb, Gene Wright, and Rita Roark, jointly
and severally:
A. An order declaring Defendants’ customs, policies
, and practices alleged
above to be in violation of the Establishment Claus
e of the First
Amendment to the U.S. Constitution;
B. An order preliminarily, and thereafter permanent
ly, enjoining Defendants
and their officers, agents, affiliates, subsidiarie
s, servants, employees,
successors, and all other persons or entities in ac
tive concert or privity or
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 16 of 20 PageID #: 16
17
participation with them, from continuing their unla
wful conduct at Negreet
High School, Many Junior High School, and all schoo
ls within the Sabine
Parish School District, and specifically prohibitin
g Defendants from:
1. Participating in, organizing, promoting, advanci
ng, aiding,
endorsing, or causing prayer, religious devotionals
, or proselytizing
during class and school-sponsored events;
2. Teaching Biblical doctrine as fact or otherwise
endorsing,
promoting, or seeking to bolster as true creationis
m or other
religious beliefs about the origin of life;
3. Encouraging students to participate in religious
events and
activities, or otherwise promoting religious events
and activities;
4. Displaying religious iconography or messages in
a manner that (a)
does not have a non-religious, educational, curricu
lum-related
purpose or (b) conveys official approval of its re
ligious message or
content;
5. Permitting the unlawful distribution of religio
us literature on
campus during the school day;
6. Conveying messages endorsing religion or denigr
ating any
individual faiths;
7. Retaliating against Plaintiffs or their family
members for objecting
to Defendants’ unlawful practices and bringing this
action; and
8. Otherwise unconstitutionally endorsing religion
or religiously
Case 5:14-cv-00100 Document 1 Filed 01/22/14 Page 17 of 20 PageID #: 17
18
coercing students.
C. An order directing Defendants to provide a copy
of the written injunction
to all School Board officials, employees, and agent
s;
D. Entry of judgment for Plaintiffs against named
Defendants for nominal
damages; and for compensatory damages to recover mo
ney Plaintiffs have
spent on (1) transporting C.C. to a different schoo
l, and (2) any other
necessary activities related to this matter;
E. An award, from Defendants to Plaintiffs, of reas
onable attorneys’ fees and
costs incurred in connection with this action, purs
uant to 42 U.S.C. § 1988;
F. An order permitting this Court to retain jurisdi
ction over this matter to
enforce the terms of the Court’s orders; and
G. Such further and different relief as is just an
d proper or that is necessary to
make Plaintiffs whole.
Respectfully submitted,
/s/ Justin Harrison
Justin P. Harrison, La No. 33575
ACLU Foundation of Louisiana
P.O. Box 56157
New Orleans, Louisiana 70156
Telephone: (504) 522-0628
Facsimile: (888) 534-2996
Email: jharrison@laaclu.org
Daniel Mach (D.C. Bar No. 461652)
Motion for Pro Hac Vice Admission to be Filed
Heather L. Weaver (D.C. Bar No. 495582)
Motion for Pro Hac Vice Admission to be Filed
ACLU Program on Freedom of Religion and Belief
915 15th Street, NW
Washington, DC 2000

) 675-2330
Fax: (202) 546-0738
Email: dmach@aclu.org
hweaver@aclu.org
/s/ Nelson Cameron
Nelson Cameron, La Bar No. 01283
Cooperating Attorney
ACLU Foundation of Louisiana
675 Jordan Street
Shreveport, Louisiana 71101
Tel: (318) 226-0111
Fax: (318) 226-0760
Email: eganspk@bellsouth.net
Attorneys for Plaintiffs
Dated: January 22, 2014





It's Special Pleadings all the way down!


Magic Talking Snakes STFU -- revenantx77


You can't have your special pleading and eat it too. -- WillHop
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30-01-2014, 08:34 PM
RE: Religious coercion in a U.S. public school
That is literally unbelievable, I feel like there should be an Onion news logo some where.
In fact I'm going to call bullshit until I see more evidence.

Theism is to believe what other people claim, Atheism is to ask "why should I".
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30-01-2014, 08:53 PM
RE: Religious coercion in a U.S. public school
(30-01-2014 08:34 PM)sporehux Wrote:  That is literally unbelievable, I feel like there should be an Onion news logo some where.
In fact I'm going to call bullshit until I see more evidence.

https://www.aclu.org/religion-belief/lan...hool-board

But now I have come to believe that the whole world is an enigma, a harmless enigma that is made terrible by our own mad attempt to interpret it as though it had an underlying truth.

~ Umberto Eco
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[+] 1 user Likes evenheathen's post
30-01-2014, 09:30 PM
RE: Religious coercion in a U.S. public school
(30-01-2014 08:34 PM)sporehux Wrote:  That is literally unbelievable, I feel like there should be an Onion news logo some where.
In fact I'm going to call bullshit until I see more evidence.

The ACLU's website confirms the case and their involvement in it. It might be reasonable to reserve some judgement about whether that the facts of the case are exactly as the plaintiffs claim, but it's reasonable enough to trust the ACLU as to the fact that the case has been filed. This seems like a real court case. (Also, this thread's original link was to the document, as stored on the ACLU's Louisiana chapter's website.)

... also, confirmed in 2 minutes of Googling. LAAAAAAZY! Laughat

EDIT: And someone else beat me to it. Damn, I'm redundant.
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[+] 1 user Likes Reltzik's post
30-01-2014, 09:38 PM
RE: Religious coercion in a U.S. public school
(30-01-2014 08:34 PM)sporehux Wrote:  That is literally unbelievable, I feel like there should be an Onion news logo some where.
In fact I'm going to call bullshit until I see more evidence.

LOOOZIANA.



'Nuff Said.


I'm FROM Looziana. You wouldn't beLIEVE some of the bullshit that goes on there. Really.




Please note that .pdf came from the official Louisiana ACLU website.


This ain't no joke, my friend.



http://www.shreveporttimes.com/viewart/2...harassment

It's Special Pleadings all the way down!


Magic Talking Snakes STFU -- revenantx77


You can't have your special pleading and eat it too. -- WillHop
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30-01-2014, 09:42 PM
RE: Religious coercion in a U.S. public school
After seeing where it's from, it's not that unbelievable...still bullshit, but not unbelievable. Thanks yall for getting it to where I could see it! Insane....

~Philosophy is questions that may never be answered. Religion is answers that may never be questioned.~
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