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California State Appellate Court Upholds Public School Yoga Program

A California school district's use of yoga in its physical education classes does not impermissibly advance religion, despite yoga's roots in Hinduism, a state appellate court has ruled.

A three-judge panel of California's 4th District Court of Appeal, based in San Diego, ruled unanimously on April 3 that the yoga program of the 6,500-student Encinitas Union School District does not violate the state constitution's prohibition against government establishment of religion.

"The record in this case contains abundant evidence that contemporary yoga is commonly practiced in the United States for reasons that are entirely distinct from religious ideology," the court said.

The all-elementary Encinitas district began its yoga program in 2011-12 at one school and expanded it to all nine of its schools within two years, court documents say. The district received a grant from the Jois Foundation, an Encinitas-based organization that promotes "Ashtanga" yoga. That form covers eight "limbs," including postures, breathing, and concentration exercises, as well as more-religious concepts such as "union with the divine."

The district hired its own expert to write a curriculum that conformed to California's physical education standards. The district's program focused on yoga poses, breathing, and relaxation, as well as helping instill such character traits as empathy and respect.

After some initial parent complaints that the program was religious, the district made changes, such as removing Sanskrit and images of India, and renaming some positions (such as changing the "lotus" position to "criss-cross applesauce.")

Nevertheless, in 2013, Stephen and Jennifer Sedlock, the parents of two children in the district, sued over the yoga program, alleging that it violated the California Constitution's establishment clause.

A state trial court upheld the program, and in its decision last week in Sedlock v. Baird, the mid-level state appellate court affirmed.

The court said that in deciding state establishment clause challenges, California's courts are guided by federal establishment clause rulings. So the court analyzed the yoga program under the so-called Lemon test, from the 1971 U.S. Supreme Court's decision in Lemon v. Kurtzman. Under that test, a challenged government program must have a secular purpose, the program's primary purpose must not advance or inhibit religion, and it must not be excessively entangled with religion.

The court assumed Ashtanga yoga was affiliated with the Hindu religion, but it said the district's program passed all three prongs of the Lemon test. Under the critical advancement prong, the district's yoga program did not advance Hinduism because it was "devoid of any religious, mystical, or spiritual trappings."

"We see nothing in the content of the district's yoga program that would cause a reasonable observer to conclude that the program had the primary effect of either advancing or inhibiting religion," the state appellate court said. 

"To be sure, if the district's program instructed children that through yoga they would become one with God and that yoga could help end the karmic cycle of reincarnation, ... we have little doubt that the program would violate the establishment clause," the court said. "However, nowhere in the district's curriculum is there mention of any of the eight limbs of Ashtanga, and there is certainly no mention of the final limb (union with the divine)."

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