BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:  April 14, 2009

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                   AB 974 (Strickland) - As Amended: April 13, 2009
           
          SUBJECT  :   Pupil Rights: Religious Expression 

           KEY ISSUES  : 

          1)Is there sufficient evidence that existing protections of  
            student expression are inadequate to support the approach  
            taken in the bill?

          2)do the "model policies" envisioned by this bill appear to FAIL  
            constitutional muster, especially in light of recent case law?  


           FISCAL EFFECT  :  This bill as currently in print is keyed fiscal.  


                                      SYNOPSIS

          This bill is modeled nearly word-for-word after the "Religious  
          Viewpoints Antidiscrimination Act," enacted in 2007 in Texas and  
          endorsed nationwide as a model bill by the American Family  
          Association.  In order to ensure that school districts treat  
          student expression of a "religious viewpoint" in the same manner  
          that it treats secular viewpoints, this bill would require local  
          school districts and non-religious private secondary schools to  
          create a "limited public forum" for student speakers at  all   
          school events at which a student may speak.  The bill also  
          requires schools to adopt policies that allow religious groups  
          to form clubs and use school facilities in the same manner that  
          is available to other extra-curricular groups.  The bill  
          provides "model policies" which school districts may adopt to  
          ensure conformity with the bill's provision.  As noted in the  
          analysis below, while the measure purportedly is an effort to  
          codify existing case law, the court's most recent and important  
          case on this subject -  Santa Fe Ind. School Dist. v. Doe  (1980)  
          - erects substantial barriers to school-sponsored religious  
          expressions and holds that a school does not create a "limited  
          public forum" merely by declaring it as such.  In addition,  
          existing law already provides substantial protections for  
          student speech and religious expression and delineates  








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          procedures by which religious groups may have access to school  
          facilities.  The Committee may conclude that neither the author  
          nor supporters have presented sufficiently persuasive evidence  
          that students are being disciplined or discriminated against to  
          any large extent for their religious views, or that existing law  
          does not provide adequate remedies for the few cases that arise.  
           Although the bill does not mandate the exact content of a  
          school's required "limited public forum" policy, it apparently  
          seeks to entice schools toward a uniform policy by offering a  
          detailed "model policy."  A school district that adopts the  
          model policy will be deemed to be in compliance with the bill's  
          substantive provisions.  Finally, as most recently amended, any  
          school district that fails to develop and implement the policy  
          in the manner prescribed by the bill will be subject to civil  
          actions for both monetary damages and injunctive relief.   
          Attorney's fees will be available only to the prevailing  
          plaintiff.  Moreover, the bill specifies that civil actions may  
          be brought under this bill without exhausting any administrative  
          remedies required by the district or by the state Tort Claims  
          Act.  In short, while the bill does not require a school  
          district to adopt the model policy, it creates a very strong  
          incentive for them to do so if they want a safe harbor against  
          potential lawsuits. 

           SUMMARY :  Enacts the Religious Viewpoints Discrimination Act to  
          ensure that a student's voluntary expression of a religious  
          viewpoint is treated in the same manner as a student's voluntary  
          expression of a secular viewpoint, and requires schools to adopt  
          a policy establishing a "limited public forum" for student  
          speakers, as specified.  Specifically,  this bill  :  

          1)Requires a school district to treat a student's voluntary  
            expression of a religious viewpoint, if any, on an otherwise  
            permissible subject in the same manner the district treats a  
            student's voluntary expression of a secular or other viewpoint  
            on an otherwise permissible subject and prohibits  
            discrimination against a student based on a religious  
            viewpoint expressed on an otherwise permissible subject. 

          2)Requires, in order to realize the general objective set out  
            above, all school districts to adopt a policy that includes  
            the establishment of a "limited public forum" for student  
            speakers at all school events at which a student may speak  
            publicly.  Specifies that the policy establishing the limited  
            public forum must do all of the following:








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             a)   Provide a forum in a manner that does not discriminate  
               against a student's voluntary expression of a religious  
               viewpoint, if any, on an otherwise permissible subject. 
             b)   Provide a method, based on neutral criteria, for the  
               selection of student speakers at school events and  
               graduation ceremonies.
             c)   Ensure that a student speaker does not engage in  
               obscene, vulgar, offensively lewd, or indecent speech.
             d)   State, in writing, that the student's speech does not  
               reflect the endorsement, sponsorship, position, or  
               expression of the district, and this disclaimer shall be  
               provided at all graduation ceremonies or other events for  
               as long as need exists to dispel confusion over the  
               district's nonsponsorhip of the student's speech. 

          3)Requires that students be permitted to express beliefs about  
            religion in homework, artwork, and other written or oral  
            assignments free from discrimination based on the religious  
            content of their submissions, and that such submissions shall  
            be judged by ordinary academic standards of substance and  
            relevance and against legitimate pedagogical concerns. 

          4)Provides that students may organize prayer groups, religious  
            clubs, "see you at the pole" gatherings, and other religious  
            gatherings before, during, and after school to the same extent  
            that students are permitted to organize other noncurricular  
            groups.  Provides further that if student noncurricular groups  
            are permitted to advertise or announce group meetings and  
            events, then students that meet for prayer or other religious  
            speech shall be entitled to this same privilege. 

          5)Sets forth a detailed "model policy" governing religious  
            expression and provides that a school district that adopts the  
            model policy shall be deemed to have complied with the  
            requirements set out in this bill.

          6)Provides that the above provisions may be enforced through a  
            civil action, brought by or on behalf of a student enrolled in  
            the school at the time any of the above provisions have been  
            violated.  Such action may seek damages and injunctive relief.  
             Provides that, upon motion of the court, the prevailing  
            plaintiff (but not a prevailing defendant) may be awarded  
            attorney's fees.  Provides that any person who violates, or  
            aids in the violation of, the rights protected under this bill  








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            shall be liable for not less than $4000 and not more than  
            $25,000 for each occurrence.  Provides further that a  
            plaintiff bringing an action under this bill need not exhaust  
            any administrative remedies required by the school district or  
            by the state Tort Claims Act. 

          7)Specifies that the above provisions apply to public schools  
            and private secondary schools, but not to a private secondary  
            school that is controlled by a religious organization. 

           EXISTING LAW  : 

          1)Prohibits school districts, including private secondary  
            schools, from making or enforcing a rule subjecting a high  
            school student to discipline based solely on speech or  
            expressive conduct that, if engaged in outside of the school,  
            would be protected by the First Amendment of the U.S.  
            Constitution and parallel provisions in the California  
            Constitution.  (Education Code Section 48950.)

          2)Protects a student's right to freedom of speech and press in  
            public schools, including the use of bulletin boards, the  
            distribution of printed materials or petitions, and the right  
            of expression in official publications, so long as the  
            expression is not obscene, libelous, or slanderous.   
            (Education Code Section 48907(a).)  

          3)Requires each governing board of a school district and each  
            county board of education to adopt rules and regulations, in  
            the form of a written publications code that shall include  
            reasonable provisions for the time, place, and manner of  
            student expression.  (Education Code Section 48907 (b).) 

          4)Provides that every public school facility within the state is  
            a "civic center" where specified groups may hold meetings and  
            conduct activities for specified purposes, subject to terms  
            and conditions that the governing board of the school district  
            deems proper.  Expressly permits religious and church  
            organizations to use facilities for temporary periods on a  
            renewable basis, so long as a fee is charged at least equal to  
            the school district's direct costs.  (Education Code Sections  
            38131 and 38134.) 

          5)Provides, at a minimum, that the Establishment Clause of the  
            U.S. Constitution prevents public schools from students to  








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            support or participate in religion or its exercise, even when  
            a student that does not want to participate has a theoretical,  
            but not practical, ability to excuse him- or herself from the  
            activity.  (Santa Fe Independent School Dist. v. Doe (2000)  
            530 U.S. 290.)

          6)Provides that school sponsorship of an invocation - which by  
            common definition is a prayer invoking an appeal for divine  
            assistance - at a sporting event is unconstitutional, because  
            it sends the message to members of the audience who are not  
            adherents that they are outsiders, not full members of the  
            political community, and a message to adherents that they are  
            insiders, favored members of the political community.  (Id. at  
            309-310).

          7)Delivery of an invocation, or other religious message, over  
            the school's public address system, by a speaker representing  
            the student body, under school supervision, and pursuant to  
            school policy, is not properly characterized as private speech  
            and is therefore constitutionally impermissible.  (Id. at  
            310.)    

           COMMENTS  :  This bill is modeled nearly word-for-word after the  
          "Religious Viewpoints Antidiscrimination Act," enacted in 2007  
          in Texas and endorsed nationwide as a model bill by the American  
          Family Association, a group which describes its mission as  
          changing American culture to "to reflect Biblical truth and  
          traditional family values."  In order to ensure that school  
          districts treat student expression of a "religious viewpoint" in  
          the same manner that it treats secular viewpoints, this bill  
          would require local school districts and non-religious private  
          secondary schools to create a "limited public forum" for student  
          speakers at  all  school events at which a student may speak.   
          This limited public forum would be required at more than just  
          "events" as that term is usually understood, for this bill would  
          also dictate that public school districts and private secondary  
          schools develop policies that permit students to express beliefs  
          about religion "in homework, artwork, and other written and oral  
          assignments free from discrimination based on the religious  
          content of their submissions.  Finally, this bill would require  
          that students be permitted to organize prayer groups, religious  
          clubs, "see you at the pole" gatherings, or other religious  
          gatherings before, during, and after school hours to the same  
          extent that other students are permitted to form non-curricular  
          secular groups. 








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           Background  :  The Texas statute upon which this bill is based  
          grew, at least in part, out of the United States Supreme Court  
          landmark decision in Santa Fe Independent School District v. Doe  
           (2000) 530 U.S. 290.  In that case, the Court struck down a  
          school district policy that required a student council  
          "chaplain" to deliver a prayer over the public address system  
          before every varsity football game.  (This may explain AB 974's  
          model policy oddly privileges football games and football team  
          captains as favored events and speakers.)  While the Santa Fe  
          case was proceeding at the district court level, the school  
          changed its policy so that the student-elected "chaplain" was  
          permitted rather than required to deliver the prayer that was  
          required to be non-sectarian and non-proselytizing.  A Court of  
          Appeal ruled that the policy, even as modified, was invalid, and  
          the U.S. Supreme Court agreed.  "When a governmental entity  
          professes a secular purpose for an arguably religious policy,"  
          the Court reasoned, "the government's characterization is, of  
          course, entitled to some deference.  But it is nonetheless the  
          duty of the courts to 'distinguish a sham secular purpose from a  
          sincere one.'"  (Santa Fe, supra at 308, quoting Wallace v.  
          Jaffre (1985) 472 U.S. 38, 75.)

          The Court in Santa Fe also rejected the school district's claim  
          that, because the students had elected the speaker, that this  
          somehow avoided an Establishment Clause issue because the  
          students, not the school, were endorsing the religious speech.   
          The Court concluded that delivery of an invocation, or other  
          religious message, over the school's public address system, by a  
          speaker representing the student body, under school supervision  
          and pursuant to school policy, is not properly characterized as  
          private speech and is therefore not permissible under the  
          Establishment Clause.  (Id. at 310.)  

          The Court in Santa Fe also concluded that the school's claim  
          that religious speech was somehow saved from Constitutional  
          scrutiny because the speaker was chosen in a student body  
          election also failed constitutional muster.  First Amendment  
          protections - like the Bill of Rights more generally, the Court  
          reasoned - cannot be diminished by a mere majority vote.   
          Indeed, it is the minority, whose views are most likely to be  
          unpopular, that is the most in need of protection.  As the Court  
          noted in Santa Fe, quoting Justice O'Conner's opinion in Lynch  
          v. Donnelly (1984), the expression of religious messages at  
          school events, even if by a "private" student speaker and with  








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          school disclaimers, is constitutionally impermissible because it  
          sends a message to nonadherents "that they are outsiders, not  
          full members of the political community, and an accompanying  
          message to adherents that they are insiders, favored members of  
          the political community."  (Id. at 309-310, quoting Lynch v.  
          Donnelly, 465 U.S. at 688 (O'Conner, J., concurring.)) 
           
           Complex Interaction of Establishment and Free Exercise Clauses  :   
          There are actually two provisions concerning government and  
          religion in the First Amendment: "Congress [and the states as  
          incorporated by the 14th Amendment] shall make no law respecting  
          an establishment of religion, or prohibiting the free exercise  
          thereof."  The "establishment clause" has been held to mean that  
          government may not do anything to endorse religion or a  
          religious viewpoint, while the "free exercise" clause prohibits  
          the government from interfering with persons in the private  
          practice of their chosen religion.  Sometimes these clauses  
          exist in tension with each other.  For example, a state program  
          that provides aid to public and private schools alike might be  
          accused of violating the Establishment Clause if the aid is used  
          to support a religious private school.  On the other hand, if  
          the state decides to deny the aid to avoid violating the  
          Establishment Clause, it may be accused of violating the "Free  
          Exercise" clause if it discriminates against a religious school  
          by denying a form of aid that is otherwise available to all  
          other private schools.  (See e.g. Everson v. Board of Education  
          (1947) 330 U.S. 1, upholding a law permitting a Catholic  
          parochial school to receive a transportation subsidy that was  
          otherwise available to all private schools.)  However, the two  
          clauses can reinforce each other as well, as in the Santa Fe  
          case.  That is, the Court found that school-sponsored prayer,  
          even given by an elected student speaker, violated both the  
          Establishment Clause, in that it amounted to state support of  
          religion, and the Free Exercise Clause, in that it discriminated  
          against students with different religious viewpoints who were  
          effectively coerced to listen. 

          As the U.S. Supreme Court noted as early Engle v. Vitale in  
          1962, interpreting the Establishment Clause to ensure at least a  
          degree, if not a wall, of separation between church and state  
          does  not  reflect hostility to religion; to the contrary, it is  
          necessary "to secure religious liberty" in a religiously  
          pluralistic society.  (370 U.S. 421, 430.)  It is not  
          surprising, therefore, that in the Santa Fe the case was brought  
          not by atheists or agnostics, but by the parents of Catholic and  








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          Mormon students.  These parents and students complained that  
          allowing a majority to determine the speaker and the content of  
          the invocation invariably favored not only a Christian message,  
          but the Baptist revivalism apparently favored by the majority.   
          Separating church and state reflects deep respect for religious  
          viewpoints, not opposition to religious viewpoints.   
          Accordingly, in its letter of opposition, the Anti-Defamation  
          League "emphatically rejects the notion that the separation  
          principle is inimical to religion.  To the contrary, we hold  
          that a high wall of separation is essential to the continued  
          flourishing of religious practices and beliefs in America."  

           Do the Policies Envisioned by this Bill Meet the Santa Fe  
          Requirements?    Supporters of the Texas statue and many of the  
          letters in support of this measure claim that the model bills  
          conform with, and indeed codify, the U.S. Supreme Court's ruling  
          in Santa Fe.  Apparently, supporters believe that the model  
          policies meet the Santa Fe requirements by replacing the invalid  
          student election approach with a policy by which school district  
          officials select students based on supposedly "neutral criteria"  
          and provide written statements that the school does not sponsor  
          or endorse the student speech.  However, while it is true that  
          the Court in Santa Fe disapproved of the student election  
          because it simply permitted the majority to impose its religious  
          viewpoints on a captive minority, it was not merely the choosing  
          of speakers by election that met with the Court's objections.   
          The Court noted that any speech at a school sponsored event over  
          school sponsored media could reasonably be seen as indicia of  
          endorsement.  AB 974 has done away with the elections, but  
          school involvement is not diminished - indeed it may be  
          intensified - by having the school district determine the  
          criteria for selection.

          Proponents of the model legislation also appear to believe that  
          the "neutral criteria" upon which selection is based addresses  
          concerns raised in Santa Fe.  But it is not clear in what sense  
          the "neutral criteria" in the model policy is in fact neutral.   
          For example, in selecting student speakers the school is  
          directed to select students who have achieved "positions of  
          honor," including student council officers, class officers,  
          homecoming kings and queens, prom king and queens, and captains  
          of the football team.  In short, the "neutral criteria" appears  
          to be that the most popular students will be selected.  Whatever  
          religious viewpoints these popular students may wish to express,  
          it is not clear how imposing their views on students with other  








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          views addresses the problem identified in Santa Fe.  The  
          "neutral criteria" simply appear to risk replacing the student  
          election with a popularity contest by other means.  And  
          opponents question why students lacking in the requisite good  
          looks, athletic skill, and social graces - as measured by  
          adolescent tastes - should have less of an opportunity to  
          express their viewpoints, religious or otherwise. 

           Will written disclaimers meet constitutional objection  ?  In  
          addition to the fact the school selection process is no less  
          objectionable than the process struck down in Santa Fe, the fact  
          that the school issues a statement disclaiming endorsement or  
          sponsorship of the speech does not appear to meet the criteria  
          of Santa Fe either.  Indeed, the Court expressly rejected the  
          school district's argument that, by eliminating the requirement  
          of a prayer before a football game with a two-stage election  
          that allowed students to select a speaker and approve an  
          invocation, the once school-sponsored speech was transformed  
          into "private" speech.  As the Court noted in Santa Fe, the  
          delivery of the student's message "over the school's public  
          address system, by a speaker representing the student body,  
          under the supervision of school faculty, and pursuant to school  
          policy . . . is not property characterized as 'private' speech."  
           (Santa Fe, supra at 310.)  It is the manner and medium by which  
          the speech is expressed that necessarily suggests school  
          sponsorship, and a mere disclaimer does not end the Court's  
          inquiry.  (See e.g. Freiler v. Tangipahoa Parish Bd. of Educ.  
          (2005) 201 F. 3d 602) (holding that disclaimer before teaching  
          of creationism is not enough to prevent a violation of the  
          Establishment Clause.)   
           
           Does existing law in California already provide adequate  
          protection  ?  Finally, neither the author nor the supporters have  
          provided evidence to the Committee that appears to show that  
                                   existing protections both in statute and in the state  
          Constitution do not already provide adequate protection for  
          student expression.  The California Education Code already  
          provides that no school district shall make or enforce any rule  
          that disciplines a student solely on the basis of speech or  
          expression that, if engaged in outside of school property, would  
          be protected by the First Amendment to the U.S. Constitution or  
          Article I, Section 2 of the California Constitution.  (Education  
          Code Section 48950.)  

          In addition to the general protection of First Amendment rights,  








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          California law also protects a student's right to freedom of  
          speech and press in public schools, including the use of  
          bulletin boards, the distribution of printed materials and  
          petitions, and the right to expression in official school  
          publications.  Of course, schools may prohibit obscene speech or  
          speech that might incite violence or unlawful conduct, and the  
          school district can develop reasonable provisions regarding the  
          time, place, and manner of such expression.  (Education Code  
          Section 48907 (a)-(b).)  But overall, California generally  
          accepts the rule laid down by the U.S. Supreme Court in Tinker  
          v. Des Moines (1969) 393 U.S 503: students do not shed their  
          First Amendment rights at the schoolhouse gate, while at the  
          same time recognizing that the requirements of maintaining an  
          orderly learning environment may require limitations in time,  
          place, and manner that might go beyond restrictions that would  
          be tolerated outside of a school among adults. 

           How will this bill conform with the existing Civic Center Act?     
          AB 974 would require school districts to give religious groups  
          the same access to school facilities - before, during, and after  
          school hours - that is afforded to other noncurricular groups.   
          Education Code Section 38131 makes every school facility a  
          "civic center" that should be open to community groups,  
          including church and religious groups.  However, to ensure that  
          taxpayer funds are not used to support a particular religious  
          group, existing law requires local school districts to charge  
          religious groups a fee that is equal to any actual costs  
          associated with allowing the group to use the facilities (e.g.  
          utility costs, etc.).  While such fees are also charged to other  
          groups, such as entertainment groups, they are not charged to  
          all community groups, such as Boy Scouts or Girl Scouts.  Would  
          this bill require the elimination of those fees so that  
          religious groups would not be treated any differently than  
          secular groups?  Would this bill apply to community religious  
          groups who want to use the facilities before or after school  
          hours, or would it only apply to groups that are formed by  
          enrolled students on the campus?  At the very least, the  
          relationship of this bill to other statutes governing the use of  
          school facilities would need to be clarified, should the  
          Committee support the bill's broad provisions.

          In light of the protections listed above and the opportunity  
          that existing law already appears to provide for religious  
          groups to use school facilities in a manner deemed proper by  
          school districts, the Committee is not aware of evidence that  








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          existing laws and policies are preventing students from  
          presenting their religious viewpoints when it is an appropriate  
          time, place, and manner.  The background sheet provided by the  
          author does not appear to cite a single instance in which a  
          student has been denied the opportunity to express his or her  
          religious viewpoint in an appropriate forum.  Although the  
          background sheet includes an assertion by the Pacific Justice  
          Institute that it has handled "hundreds of cases" where students  
          have been penalized or discriminated against, not a single  
          example is actually provided.  Committee staff could not locate  
          any list of cases on the Pacific Justice Institute website, but  
          the site did contain two items on religion in the classroom.   
          The first item is about a school that  reversed  a teacher's  
          decision to prevent an eight year old student from distributing  
          Bible literature to her classmates.  The other item, entitled  
          "Islam Takes over Middle School Curriculum," is about a parent  
          who claimed that her child was made "uncomfortable" because a  
          7th grade teacher in San Luis Obispo taught the students about  
          Islam and allegedly gave students extra credit for memorizing  
          passages from the Quran.  The discomfort of the student in this  
          particular case, opponents might note, illustrate why schools  
          find it best to limit professions of religious faith in a  
          religiously diverse student body.  
          (  www.pacificjustice.org/resources/articles/focus.cfm?ID=ART434511 
          306  )  
           
          ARGUMENTS IN SUPPORT  :  Concerned Women for America (CWA) of  
          California claims that this bill will protect students "who wish  
          to invoke their faith in writing assignments, clothing, and  
          artwork" from being discriminated against.  "Unfortunately," CWA  
          claims, "too often they are [discriminated against and] teachers  
          either do not accept or penalize students for assignments that  
          include religious themes and expressions."  The CWA does not,  
          however, cite any specific examples. 

          The Capitol Resource Family Impact also supports AB 974 because  
          it will protect a student's right to express his or her  
          "religious beliefs about religion in homework, artwork, and  
          other written and oral assignments free from discrimination" and  
          would also allow students "to organize prayer groups or  
          religious clubs or gatherings before, during, and after school  
          and use school facilities just as other secular groups are  
          permitted." 

          The Traditional Values Coalition supports this bill for  








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          substantially similar reasons, and it does include a list of  
          nine instances that occurred between 2007 and 2008.  However, of  
          these nine items, none actually involved students being formally  
          disciplined.  Six of the nine cases in which students were asked  
          not to engage in certain activities (such as distributing or  
          displaying Bibles) were resolved in the students' favor after a  
          phone call or other communication to school officials.  One of  
          the cases involved a parent who complained to the Pacific  
          Justice Institute that a school official told her that even  
          mentioning the word "Christmas" in school was "illegal," but the  
          PJI assured the parent that this was not the case.  Another case  
          did not even involve an action taken by a school, but reports an  
          allegation that "someone in the community" threatened to sue the  
          school because a local church bulletin announced that a  
          Christian high school group would be holding a "See You at the  
          Pole" event.  It is not clear if this "someone" ever followed  
          through on the threat or what the legal basis of such a suit  
          might be.  Another case involved a San Diego-area school that  
          set aside a room an hour a day for Muslim students to pray, but  
          the school apparently reversed this policy when PJI urged the  
          school to make similar accommodations for Christian and Jewish  
          children. 

          A number of form letters from individuals assert that AB 974  
          would "clarify what the courts have already held, but some  
          schools and special interests continually attempt to deny."   
          There are no examples offered in support of this assertion. 

           ARGUMENTS IN OPPOSITION  :  The Anti-Defamation League (ADL)  
          argues that, although the measure is ostensibly an attempt to  
          codify the Santa Fe ruling, it falls short in many respects.   
          First, ADL argues that a school cannot create a "limited public  
          forum" just by naming it as such. ADL contends that the Court in  
          Santa Fe held that the district's policy did not meet the test  
          of a limited public forum because it limited who could access  
          the forum and regulated the content of the speech in the forum.   
          AB 974 also restricts both who can speak and the content of the  
          speech, and would likely suffer the same fate as the school  
          district in Santa Fe.  Second, ADL contends that model policies  
          recommended by this bill will not protect schools from  
          Establishment Clause violations, for the Court in Santa Fe held  
          that the mere creation of a public forum does not shield a  
          government entity from scrutiny under the Establishment Clause.   
          Moreover, a mere disclaimer of school sponsorship is not enough  
          to pass constitutional muster.  The court looks at the specific  








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          facts and total environment in which even "private" speech  
          occurs in order to determine if the speech could reasonably be  
          seen as constituting government endorsement.  Third, the model  
          policy suggested in AB 974, ADL believes, will potentially  
          permit religious proselytizing that will leave students subject  
          to the coercion of peers, the kind of coercion Santa Fe and  
          other cases have found impermissible.  Finally, ADL contends  
          that AB 974 will subject California schools to more litigation.   
          Indeed the most recent amendments to the bill expressly provide  
          for civil actions to be brought without the usual requirement  
          that administrative remedies be exhausted. 

          The American Civil Liberties Union (ACLU) opposes this bill for  
          many of the reasons already cited, but stresses that students  
          are inherently "captive" audiences, and no matter how student  
          speakers are selected "students who are not religious or whose  
          beliefs are different must listen" to the speech during  
          school-sponsored and school-controlled events, such as  
          graduation ceremonies, sporting events, daily morning  
          announcements, school assemblies, and pep rallies.  ACLU cites  
          case law supporting the proposition that mere "disclaimers" that  
          student speech does reflect endorsement is not sufficient to  
          withstand an Establishment Clause challenge, because Courts must  
          consider the "whole context" to determine if "a reasonable,  
          objective observer should be able to conclude that the  
          government does not endorse the religious exercise."  (Citing  
          Freiler v. Tangipahoa Parish Bd. of Educ. (2005) 201 F. 3d 602.)  
           Finally, ACLU claims that the provisions relating to forming  
          religious clubs and using school facilities are unnecessary  
          because the federal Equal Access Act (20 USC Section 4071)  
          "already delineates the rights and responsibilities of public  
          schools regarding student meetings on campus." 

          Americans United for Separation of Church and State, in addition  
          to reiterating the above points, stress that existing law  
          already provides adequate protection.  However, this law merely  
          "tries to transform every classroom, assignment, and school  
          function into a place for [students] to proselytize to  
          classmates, but does so in a way that will violate both the  
          Establishment Clause and Free Speech Clause of the First  
          Amendment." 

          Some religious groups also oppose this bill.  The Religious  
          Society of Friends views the "free, un-coerced exercise of  
          religions as the most basic of human rights. Therefore we view  








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          any imposition of participation in religious observance in a  
          public setting (such as public schools) to be the abridgement of  
          the freedom to choose one's own religion."  [Emphasis in  
          original.]  Whenever and however religious viewpoints are  
          expressed in the school context, the Friends believe, the  
          students are always a "captive audience" and students of  
          minority faith traditions are improperly subjected to the  
          religious viewpoints of the majority. 
           
           Finally, California Church IMPACT, which represents 21  
          mainstream, progressive Protestant denominations, "believe  
          utterly in the freedom of religion, but we seriously oppose AB  
          974."  "Religion in American," IMPACT contends, "is not under  
          assault," as the supporters of the measure claim.  For 200  
          years, IMPACT argues, the First Amendment has wisely prohibited  
          government from trying "to meddle in these intensely personal  
          and profound issues."  Prayer is not banned in public schools,  
          but organized prayer, IMPACT claim, is and should be banned.  AB  
          974, IMPACT believes, diminishes "sanctity of faith" by  
          suggesting that it is the "mere equivalent of secular speech."   
          Moreover the bill "creates mandates on government to open up  
          forums to those with the most clout in the community."  The bill  
          "oversteps the bounds" of government intrusion by allowing a  
          school district to decide "who gets speak, how it must be  
          organized, [and] what kinds of assemblies are legitimized."   
          IMPACT concludes that "this measure is a thinly-disguised effort  
          to promote one type of faith expression" and, as such, "does  
          many of us in the faith community grievous harm."   

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Capitol Resource Family Impact
          Concerned Women for American (CWA) of California
          Traditional Values Coalition 
          Several Individual Letters 

           

          Opposition 
           
          American Civil Liberties Union 
          Americans United for Separation of Church and State
          Anti-Defamation League








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          California Church IMPACT 
          Religious Society of Friends, Friends Committee on Legislation  
          in California 

           
          Analysis Prepared by  :    Thomas Clark / JUD. / (916) 319-2334