Former Red Hill Elementary teacher Michelle Frilot has filed suit against Albemarle County and the School Board, charging them with discriminating against her because she’s Christian. The Eastern Orthodox Christian had displayed a 5″x7″ painting of Jesus in the corner of her classroom, despite being asked repeatedly by a superior not to do so. When she turned to an assistant superintendent for help, she was told once again that she could not display religious iconography in the school. In February of 2001, after five months on the job, she quit, citing a hostile work environment. Her attorney is John Whitehead of the Rutherford Institute. Adrienne Schwisow has the story in today’s Progress.
News and meta-news about Charlottesville, VA, since 2001.
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Police announced this afternoon that their investigation into what was initially believed to be a fatal fire on Rugby Avenue is now a homicide investigation. #
The Virginia Supreme Court has denied George Huguely’s appeal. His second-degree murder conviction will stand, WRIC reports. #
In a carefully worded story, and not citing specific sources, WTVR reports that forensic evidence belonging to Jesse Matthew Jr., the main suspect in the disappearance of Hannah Graham, matches forensic evidence collected during the investigation of Morgan Harrington’s 2009 murder. #
In the wake of Hannah Graham’s disappearance, and the evidence that came from private security footage, city officials are revisiting the question of installing security cameras on the downtown mall. #
Both Charlottesville Registrar Sheri Iachetta and former Electoral Board member Stephanie Commander have turned themselves in to the police on
foursix and four felony counts of embezzlement, respectively. #Ten years ago, the National Institutes of Health budget doubled and schools like the University of Virginia built massive new research facilities. A decade later, those buildings remain largely underutilized. NPR visits UVA in this story on the effect of federal binge and spurge spending in the sciences. #
In 2012, Council approved a new student housing complex on West Main—now some council members are questioning whether what they were shown matches what was built. #
The Architectural Review Board has approved a bike-themed mural on West Market, below the McGuffey Art Center, although at least one member expressed concerns that it might look like the bicyclists were riding away from Charlottesville’s downtown. #
City Police Chief Tim Longo is meeting with city leaders to work on protocols regarding the use of military surplus police weapons in Charlottesville. #
A 100-year-old Colonnades resident received military honors for her service in the WWII Women’s Army Corps #
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This is the kind of thing that ticks me off. Lawsuits that don’t seem to have a basis in any kind of reality. From the story in the progress it appears that this woman was offered alternatives and wouldn’t accept any of them. For example, she refused to move her desk to the library but moved her class to the library to "escape hostility"?
I don’t see any discrimination here; rather, a public school questioning whether a religious icon should be placed in view of students on a regular basis. Further things that irk me…she quit and is suing, in part, for her job back.
If we allow that she felt there was hostility towards her in her work place perhaps it should be considered that it could be due to co-workers (or space sharers) simply disliking her. And there is certainly no constitutional requirement to like someone. Thank god.
Just another reason to sue and try to get rich quick. This idiot must not realize the position the school is in when it comes to separtation of church and state. If she is too stubborn to accept the administration’s ruling on this, then she has no business teaching our children in public schools and should just settle for a private teaching position. What if I was a teacher and had a picture of the almighty SATAN hanging up? How would she feel? Just wait, this will turn into one of those "freedom of speech/expression" things.
(And no, I don’t worship satan. I was using it as an example)
I think Michelle Frilot should have been allowed to display her icon, though I can understand the concerns of the other teacher and the administration. It’s difficult to make a decision in a situation where the rights of one person are in conflict with the rights of another.
As for the lawsuit, the conflict with the other teacher doesn’t really seem to rise to the level of harassment. The icon was removed and placed face-down "more than once" (since no more precise figure was given, I assume it didn’t happen often), a tissue box was once placed in front of it, and she was asked to take it down. She was never verbally or physically assaulted, and her icon was never stolen or damaged. Furthermore, the actions that did take place seem to be a result of concern over the church/state separation, and not a personal feeling about her religion.
She was allowed to display it–in another area than the one she had originally chosen. That’s different from being told that she couldn’t display it at all. What I took away from the story is that the school made an effort to accomodate her wishes but tried to balance those wishes against their desire to keep it from being displayed where students could see it.
I also believe she should be allowed to display it, even where children could see it. As far as I know, there is no civil right that guarantees that you don’t have to see someone else’s religious practices. Even in school. The idea that the icon could violate the establishment clause, or disrupted the work-place in any way is one that I find rediculous.
I don’t agree with her lawsuit, though. She was told that she wouldn’t be fired over it, with some mention that her life with her (intolerant) co-workers might be more difficult. If she chose to live with that, then it was her decision.
It’s a shame that intolerance towards Christianity is accepted, though. If this had been a case of intolerance towards another religion (say, Islam), would it have made a difference in the eyes of the administration? I wonder what would happen if the controversial article in question was an ankh? How about an athame?
Can we stop saying "I believe she should have been allowed to display it" when it’s not true that she was not allowed to display it? I quote from the DP article:
"Instead, the school principal suggested a compromise and offered Frilot a space in the library for her desk."
Lafe and Cat, it would be more accurate for you to say "I believe that she should have been allowed to display WHEREVER SHE WANTED TO DISPLAY IT," because THAT’S what she was not allowed to do. She could have displayed it, apparently, at her desk if she would have taken the offer to move into the library. As I understand the DP article.
I wasn’t trying to say that she wasn’t allowed to display it, merely agreeing that she should be allowed to do so. I then added on the opinion that I believe she should be allowed to do so, even where the children could see it.
Sorry if I was being confusing.
Indeed, the article explicitly said the she was allowed to display it in spite of the direction of some administrator, and wouldn’t be (officially) penalized for doing so.
That’s why I disagree with her lawsuit. Her perceived persecution was carried out by others than her bosses. If she wants to sue someone, find whoever the heck it was that kept moving or hiding her icon, and sue them for harassment. Though even that, I think, would be a bad move. At least it’d be more appropriately targeted.
“It’s difficult to make a decision in a situation where the rights of one person are in conflict with the rights of another.”
“Rights of another?” What right, specifically, are you referring to? Is there a right for school administrators to make arbitrary judgements about who may display what where? I’m not saying that there isn’t, but that appears to be the only thing causing conflict with Frilot’s desire to display her picture at her own desk.
“What if I was a teacher and had a picture of the almighty SATAN hanging up?”
That’s a silly strawman. Everyone knows that Satan worshippers don’t teach children — they EAT them.
The right of a teacher to practice his/her religion vs. the right of a student in a public school to be educated without the influence of any particular religion.
Yes, the principal offered her a workspace in the library. However, the Progress article also says that an assistant superintendent "suggested she take the icon down" and "she deliberately ignored a directive from the assistant superintendent to remove the icon if there was any possibility that the children could see it (which they could)".
I don’t see much difference between a private study carrel in the corner of a classroom and one in the library. They’re both areas that are open to students. My impression was that the library move was offered as a way to ease tensions between Ms. Frilot and Ms. Horwitz, and not as a permanent solution.
Is there a right to be educated without "the influence of any particular religion?"
If there is such a beast, I haven’t seen it. There is a guarantee that the state will not make a law repecting the establishment of religion, which I take to mean that the school (or any other government institution) won’t teach religion.
As far as I know, there is no guarantee whatsoever that the kids will never come into contact with other peoples’ religion. Even that of teachers.
This case is really very interesting. It’s one of the more mind-expanding cases that I’ve seen recently. Every time that I think that I’ve made my mind up regarding right and wrong here, somebody goes and changes it. (Most recently, Lafe.) The fact is that there’s not a single legal reason (that I’m aware of) of why she can’t display that picture. On the other hand, I feel as if there should be.
There is one thing that I’m quite certain of. I think that this woman handled this all very poorly, at least based on the Daily Progress interview. I must admit that I don’t know a great deal about Eastern Orthdox Christianity, but I think she could have gotten through the day having to keep that picture in her drawer, purse, or pocket. Instead, she set up an environment that could very easily be awkward or uncomfortable for her students or co-workers, and, of course, turned out to be just that. Practically-speaking, she should have taken that picture down rather than deliberately construct a poor work environment.
Anyhow, like I said, this seems quite legally murky, and I’ll be really interested to see where it goes. I’m glad that Rutherford took this case on.
I don’t see anything to indicate that this was intolerance specifically towards christianity. It sounds to me like its the public school being concerned about seperation of church and state. In the current climate, Islam is going to be more of a hot-button issue…but i don’t see anything in this case to suggest that this had anything whatsoever to do with a particular religion.
I don’t know the answer to my question, but its interesting nonetheless.
At what point does something like an icon rise to the level of prosthelytizing?
Many of you are going to dismiss this out of hand, but i’m quite serious. I agree students are not going to go through school and never come into contact with the religious beliefs of others…but they should never be prosthelytized in a public school (when being used for school purposes — keep in mind that many schools rent out space during off hours).
I, along with Waldo, don’t know much about this woman’s particular religion but I don’t believe that it was intrinsic to her religion to have an icon in one specific place. When you take a job, you also have to make some compromises…and not every compromise one is asked to make creates a hostile workplace.
At what point does something like an icon rise to the level of prosthelytizing?
Excellent question. I fear, though, that the answer is invariably going to be personal and subjective. My tolerance level for other people’s religion is bound to be different from your tolerance level.
Hmmm, perhaps that may actually be the point. None of us have the “right” not to be offended by what someone else does or says. I think the only acceptable guiding factor is “Does that, in fact, pressure someone else into accepting your religion?”
In this particular case, I think most people are saying, “No.” Up to, and including, her bosses at the school.
Who decides what constitutes “pressure”? Better yet, if a student comes up to the teacher after class and asks to learn about her religion, should she be allowed to share?
The fact is that there’s not a single legal reason (that I’m aware of) of why she can’t display that picture. On the other hand, I feel as if there should be.
Just out of curiosity, why do you feel that she should be legally barred from displaying the picture?
I must admit that I don’t know a great deal about Eastern Orthdox Christianity
Just to fill in, here. She doesn’t have a religious mandate to display this picture. I’m familiar (but not intimately) with the Eastern Orthodox church. To the outsider (including me) it looks an awful lot like Catholicism. There are some (important?) theoretical and theological differences, but the customs and practices are very analogous.
I think that this woman handled this all very poorly, at least based on the Daily Progress interview.
And with that, I must agree. She has taken a mildly uncomfortable situation, and made of it a wildly inappropriate situation. Regardless of the interesting questions she’s raised, one of them is not if she’s done the right thing. I think the answer to that is quite obviously, “No.”
If the students see the picture, why can’t she just tell them it’s a photo of her cousin Martha and her son? It’s not like the picture’s pornographic or otherwise patently dangerous!
Granted, this lady sounds (from her actions, at least) like a true brain donor, but that’s no excuse for this silliness.
I’m sure school employees have SOMETHING better to do than squabble over a bloody picture.
Scott
And Ms. Horwitz does attend church, so don’t think for a minute she was simply offended by a picture of Jesus. It’s the part about being in the school that is irksome. I remember having to work in an office (non-governmental) with a woman who had religious stuff all over her workspace. It was difficult for me because I felt straight off the bat that I had to hide the real me from her since I clearly didn’t operate on the same ultra-pious religious plane that she did. And I think that’s where the problem really is- people can feel threatened by a potential bias from others regarding religion. Like the unwritten rule in the Justice Dept. that you have to go to Ashcroft’s prayer circles or you won’t get anywhere career-wise there. Does that make sense?
I for one
Just out of curiosity, why do you feel that she should be legally barred from displaying the picture?
I’m not entirely sure that I have a rational line of thought to back that up. :) I think the premise is that a teacher is a major role model in the lives of many children, and that relatively simple acts can have profound effects on their students. The display of a picture of Jesus isn’t substantially different than hanging a crucifix on the wall over the chalkboard, and yet it’s agreed (I believe) that the latter is not permitted in public schools.
Anyhow, the line of thought is something like that.
Would you feel the same if, say, you were legally barred from displaying one of those cute little darwin fishes with feet on your desk if you have been elected to City Council?
Would you feel the same if, say, you were legally barred from displaying one of those cute little darwin fishes with feet on your desk if you have been elected to City Council?
I’m really not sure. It’s easy for me to say “of course — there’s no reason why anybody on Council should be displaying anything,” but I’m not sure that opinion is suffiently grounded in the reality of emotions. I’d like to think that I’d have better sense than to do something like that. OTOH, it sounds like the sort of thing that I’d do. :)
But they are cute, aren’t they? :)
Heh, my own personal feelings are that that government has no business telling us what to display, or not to display regarding religion (or lack thereof).
One of the forces that drove the original Americans over here was the freedom to worship (or not) as they saw fit. With that goes the understanding that everyone else will do the same. Sorta like that quote that says something like, "I don’t like what you’re saying, but I’ll fight to the death for your right to say it." Similarly, I may not agree with your religion, but I’ll fight to the death for your right to practice it.
I think those that get offended by seeing someone else’s religion should grow a thicker skin. ;)
I also believe that the government itself, as an entity, has no business treating anyone any differently because of their religion (or lack thereof), nor promoting any one religion (or lack thereof) over any other. That religion should be totally transparent to the government. Or something like that.
Otherwise, we’re all back to that whole subjective judgement thing. What’s tolerable to you, isn’t tolerable to someone else. What’s tolerable to me, may drive you crazy. ;)
I’m sure you know this, and it’s arguably beside the point, but I feel like it’s worth reminding people: the original Americans (i.e., Calvinist pilgrims and Puritans) came over here looking for space to practice their religion as they saw fit, but they *expressly* did not feel that everyone else had the right to do the same. The Puritans banished numerous people from the original colonies for deviations from orthodoxy. They were the original religious bigots.
The ideas of freedom of religion came from other settlers.
Here’s why (I think) people don’ t want teachers in a public school hanging religious pictures in their workspaces if those are workspaces where students might go:
Schools, particularly elementary schools, are full of kids. Kids, particularly the younger ones, are pretty impressionable–some might say "vulnerable" or "easily influenced." Imagine an 8-year-old student whose family practices Hinduism going to this teacher’s workspace. There’s a huge picture of Christ on the cross there. The student stares at it–maybe even asks "who’s that?" The teacher has to answer, maybe *wants* to answer (given the imperative to proselytize characteristic of some religions). The teacher explains–imagine that the "explanation" comes across as more of an exhortation (that’s Christ, he died on the cross for your sins so that you could go to heaven and be with God…). There is the potential now that this kid is confused, upset, frightened because these statements conflict with what her parents have been telling her. She wonders if this Christ is an official part of the school–after all, she saw his picture at the desk of a Teacher (authority figure). She associates Christ/Christianity with the official stance of the school.
Now, I am NOT saying that we all have a Constitutional right not to be confused, upset, or frightened. That’s life. But I can see why many people argue that schools are a unique institution in that they are the primary holding pens for mass numbers of kids, who by their nature are easily influenced. And that this unique power over children necessitates a higher level of caution regarding the display of religious imagery.
And to those who say "but the picture in her workstation is purely her own individual expression of faith, not the school’s," I would say yes, we adults understand that distinction, but that might be asking a bit much of elementary school kids (and Red Hill is an elementary school). I think that kids tend to merge TheTeacher and TheSchool into one lump–it’s all one big official authority figure. If the teacher says it, it must be school policy. That’s how kids tend to think. And that fact too suggests that this particular institution–the school–needs to exercise more caution regarding the display of religious imagery.
So no, I don’t know what *law* is being broken when a teacher puts up a picture of Christ in her cubby, but I do understand why many people argue that her right to display Christ must be balanced against the need to keep this special institution religiously neutral.
You make some good points. And I too understand people’s feelings about the subject. I certainly understand a parent’s fear of influences on my child that I do not agree with (I have three school age children at the moment).
However, I fear that if we were to make laws that would outlaw these personal displays in this one “special circumstance,” that we begin sliding down the slippery slope that eventually bans all forms of religious expression in public places.
Understand that I’m not trying to be alarmist about it, but I believe that would be the far-reaching, eventual result. Civil rights are eroded only slowly, and often for the very best of reasons, and with the very best of intentions.
And almost always with a complete lack of foresight.
Ultimately, it’s my responsibility as a parent to make sure my children are prepared for the influences they will doubtlessly be exposed to. They will be exposed to everything from drugs, to sex, to various religions, to bigotry, to hate, to racism, and to stupidity. I do not count on, nor want, this issue to be left in the government’s hands.
In this kind of a situation i think the teacher was offered a solution…move her desk to the library. it allowed her to put up the picture in a place that was more isolated from students.
while it is your job as a parent to prepare your child for the kinds of things you mentioned…it should also be the job of a teacher to, as much as they possibly can, avoid creating those potential situations for their students themselves. she has other options…private religious schools spring to mind. she even had other options within the public school. accepting a job as a public school teacher brings with it certain realities. one certainly does not give up the freedom of religion but neither is one permitted to erect a shrine to one’s deity of choice. imagine the furor that would take place if this teacher had put wiccan materials in their workspace where students could see it.
Someone tore my linux fish off my car, What? they didn’t even realize it had nothing to do with religon. But clearly I have no right to have an operating system of choice and to proclaim it on my car. They clearly have the right to vandalize my car. Thanks random christian vandal, you’ve ummm really helped the world out.
It DOESNT MATTER if she’s allowed to have a picture of jesus or not. What matters is this woman doesn’t care about children. She cares more about profiting from a lawsuit than she cares about educating our children, she’d rathar quit so she can sue for damages than teach our children.
Someone with so little respect for education should not be working in our schools, period. Regardless of her religon. Who cares if she’s justified in her lawsuit or not. I certainly don’t.
I think we agree that we hope to be the kind of parents who will prepare our kids for the influences they’ll meet. I certainly don’t want to raise a philosophically and morally fragile child who crumbles the first time he encounters something different from our values. And I like to think that if he comes home from school and says that Teacher has this funny picture on her desk of a man on two sticks with nails in his hands, I’m *not* going to freak out and try to get Teacher fired. (But, if Teacher were to tell my son he’s going to hell unless he accepts Jesus as his Personal Saviour, that would be a different matter…).
Sadly, I think many parents draw their line of tolerance much sooner than that, though. And I understand why school administrators feel they have to "act" against someone like Ms. Icon. They’re damned if they do and damned if they don’t. If they don’t act, they get the angry parents suing them. If they do act, they get the angry teacher suing them. It’s a crappy position for them to occupy, and they don’t have any evil anti-Christian agenda. They’re just trying to navigate this insane, hyper-litigated terrain in which every decision you make is somehow Wrong because everyone uses their 20-20 hindsight to figure out what the Better decision would have been (as if it were perfectly obvious at the time). It’s frickin’ nuts, and tho’ I admire John Whitehead in many ways (he’s thoughtful and complex, tho’ often a wingnut), I’m sad that there’s yet another case of litigation like this, because our culture doesn’t need more of this crap.
And P.S.: You fear the slip-sliding away of our civil liberties through little PC laws to protect feelings etc. I can respect that. I come at this from the other perspective, though, which is that I think the greater threat in this country is not the triumph of Tolerance (a.k.a. PC) but of the Christian right. I think it’s much more realistic to fear a future in which Christ’s picture *will* indeed appear, courtesy of the government, in every classrooom than it is to fear a future in which all forms of public expression of religion are banned. I mean, look how hard our elected politicians are fighting for the "under God" part of the pledge! We’re much more likely to become an officially Christian nation than an officially non-religious nation. The former is my nightmare scenario.
Your error (I think) lies in thinking that "offering alternatives" such as moving her desk to the library constitutes a show of non-discrimination. There was no legal basis for requiring her to take such a step and so it was equivalent to saying, "if you must display that offensive Christian symbol do it out of sight." The reason there was no legal basis is that the law as currently interpreted by the Supreme Court does not consider every expression of religious belief in a public school or facility to constitute a violation of the "establishment clause". As one justice put it in the Rosenberger case, where the right of a religious student publication to funding was affirmed, "religious speech is not a free speech orphan" (the quote is approximate.) I would suppose that, analogously, the Constitution would be construed to allow a public high school to fund a Christian, or Jewish or Muslim newsletter so long as the funding decisions were not selective. In short, religious believers have the same advocacy rights as political believers; what is forbidden — of both — is to use their position to compel conformity. And such humble expressions as keeping a picture, even by a teacher, may not be taken as tantamount to requiring conformity. If the Constitution allows a teacher to display a picture of Martin Luther King or King George or Maharishi Mahesh Yogi, Marx or Darwin, it equally allows a picture of Jesus. Certainly one can construct borderline cases — but in this case it appears that the pressure for conformity was applied to the teacher by the administrators, rathr than by the teacher to her students.
Militant secularists, who seem to dominate public school power-structures in every nook and hamlet outside of Mississippi, have long taken as a finished matter, chiseled in stone as it were, that any scrap of religious expression in a public school constitutes a state endorsement of a particular religion and is hence forbidden. They also react to what they see as violations by Christians with an odd ferocity and dogmatism, as if they were expressing a hatred of same. One can not imagine them reacting similarly to a portrait of the Buddha. In any case, their legal presumption is no longer held valid, and in the future they should do a better job of keeping up with events. Personally, I am pleased by the shift in legal climate, since I have always regarded politics as generally more evil than religion, and object to the pressure to conform politically that is common in public education. We ought to consider at some point that public schools were created so that all children would have the chance of an education, not so that children would be spared from exposure to religion. Since religion is a cornerstone of culture and morals, it would be a a defect rather than a virtue of public schooling if it proceded without reference to religion. And of course in practice there has always been a great deal of reference to religion, as when one discusses the Crusades, the Papacy, the Reformation, the persecutions of the Holocaust or the Inquisition, and the Constitution itself with its guarantee of religious freedom. However, these subjects are normally treated with a neutral or hostile attitude toward Christianity. What is tabooed — for it is taboo rather than law — is any suggestion that Christianity might be a good thing. While much evil has been done in the name of Christianity, it has been arguably in contradiction of Jesus’ teaching, unlike, by contrast, the genocides carried out in the name of Marxism by Stalin, Mao and Pol Pot. For Marxism, unlike Christianity, does not recognize an individual right not to be murdered, only the right of the proletariat to accomplish its victory by any means necessary. And even democracy has its little genocides to explain away, such as the immolation of Hiroshima and Dresden during WWII. Such considerations are of course not relevant to the legal question, but in my mind they have everything to do with the sociological question as to why putting up a picture of Jesus provokes such a tempest of righteous wrath, and so are hopefully not outside the appropriate scope of the discussion.
In response to two (related) claims you make: first, "[The militant secularists] also react to what they see as violations by Christians with an odd ferocity and dogmatism, as if they were expressing a hatred of same," and "putting up a picture of Jesus provokes… a tempest of righteous wrath."
Though this level of wrath, ferocity, and dogmatism might characterize some clashes over expressions of religion in the public schools, it really doesn’t seem to characterize our Red Hill Elementary tempest.
What I see, based on the DP story, is teachers and administrators muddling through, not sure exactly what to do (or even if to do) but certain that they’re damned if they do and damned if they don’t, trying to make the best decision possible. It sounds like the teacher whose room the icon-woman was sharing was the most aggressive of the bunch. And then icon-woman seems to have gotten a little aggressive herself, or maybe just passive-aggressive.
But I don’t see any militancy on the part of the administrators in the school system. I just see confused people trying to do their best.
And I would wager that it is that state–confusion and good intentions–that characterizes far more of these clashes than the fanaticism you describe. Again, I’m not saying that militancy doesn’t exist when it comes to these questions–surely it does, on all sides of the controversy. But I think you’re caricaturing the debate.
in this case, the students are too young to be expected to place the kind of "pressure for conformity" you’re looking for. its incumbent upon the administrators to make certain the environment is as its supposed to be in public schools.
in this case, by the way, this was an endorsement of a particular religion. clearly.
having a degree in religious studies and having taught, i feel very strongly that the history of religion should be taught (in public schools as well as elsewhere). i think that the views of different religions should be taught. i do not think that teachers should advocate. i’m not sure that in this situation the teacher in question was advocating. but i can see what the administrators thought. and it wasn’t descrimination. it had nothing to do with christianity and to make it about the specific religion in this case helps nothing. i can easily imagine these same people reacting the same way to a photo of the buddha, mohomad, vishnu or any other figure you’d care to name.
… vishnu or any other figure you’d care to name.
Waldo? ;)
exactly, if i had a picture of waldo on my desk as an icon i fully expect i’d be asked to move as well. :)
Two points:
1) You say " this was an endorsement of a particular religion. clearly" It was arguably an endorsement of a religion by the teacher, but not by the school system. It is the school, not the teacher, that is forbidden to "establish a religion." It could break that rule by hiring only Christian teachers or insisting that all teachers teach the truth of Christian doctrine. I will accept that no teacher should be allowed to teach the truth of a particular religious doctrine, but don’t see why displaying a picture or wearing a crucifix, yarmulke, Muslim head-covering or whatever should be seen as more than an expression of a personal affiliation. (Amusingly, it is considered constitutional to teach the FALSITY of fundamentalist Christian doctrine e.g. to teach the theory of evolution.)
2) You say it was not discrimination and had nothing to do with Christianity, yet you give not one reason for this opinion, as if it were obvious. But consider: Nearly all such church/state cases involve an attempt to suppress a Christian expression. This is in part a statistical effect of the prevalence of Christianity but I think there is more to it. Because Christianity is demographically the dominant religion in western culture, its hegemony is more threatening to those who reject it. Also, the ideas of Christianity are in sharper conflict with modernity than, say, Buddhism, at least the American style (it’s true the Dalai Lama condemns sex outside of marriage.) The great battles between religion and secularism in Western history have all involved Christianity. The execution of nuns and priests by the Jacobins during the Reign of Terror in France, the imprisonment of the Pope by Napoleon, the framing of Orthodox priests by Stalin, the murder of 12-14% of the Spanish clergy by the Republicans (as the American left averted its gaze or was indifferent): all these testify to the strong feelings that animate the struggle between Christianity and the secular ideologies that oppose it. Christian churches are also the primary source of pro-life advocacy, surely a hot-button (which is not to say that all Christians are pro-life.) I don’t regard the Holocaust as a counter-example to my claim because it was not motivated by secularism but by anti-semitism. Hitler was not a Christian but neither was he a secularist — he cooked up a kind of Teutonic neo-paganism inspired by Wagnerian operas. While he did not tolerate opposition from Christian leaders, he hated Communists far more.