Federal Appeals Court Rejects Challenge to District's Lessons on 'the Muslim World'
A federal appeals court has rejected a family's First Amendment challenge to a Maryland school district's lessons on the Islamic faith as part of a high school world history course.
The family argues that the unit on "the Muslim World" endorsed and advanced Islam in violation of the First Amendment's bar against government establishment of religion. The parents also argued that the school district violated their daughter's free-speech rights by requiring her to complete a fill-in-the-blank assignment about the so-called Five Pillars of Islam.
John and Melissa Wood, and their daughter Caleigh Wood, are represented by the Thomas More Law Center, an Ann Arbor, Mich.-based legal organization that has brought a number of similar challenges to lessons on Islam and Muslim history in public school districts.
The lawsuit alleges that the Charles County school district in Maryland and various officials "concealed that their high school World History class promoted Islam" and that the parents and student "were harshly punished for voicing concerns about the desecration of their Christian beliefs and heritage and the promotion of the Islamic faith" in the class.
Wood took the required World History class as an 11th grader at La Plata High School in La Plata, Md., during the 2014-15 school year, court papers say. The unit entitled the Muslim World was five days of a yearlong course that covered the Renaissance and Reformation, the Enlightenment period, the Industrial Revolution, and World Wars I and II.
One element that the Woods strongly objected to was a PowerPoint presentation by the teacher comparing "peaceful Islam" with "radical fundamental Islam," which contained the statement that "Most Muslim's [sic] faith is stronger than the average Christian."
The family also objected to a worksheet in which students had to fill in blanks of certain statements, including one that said, "There is no god but Allah and Muhammad is the messenger of Allah." That comes from a Muslim declaration known as the shahada. For that worksheet, students had to fill in the first "Allah" and the word "messenger."
School officials declined to excuse Wood from the unit, and John Wood directed his daughter not to complete the assignment, which resulted in lower percentage grade for the course, but did not affect her letter grade.
The Woods sued under the First Amendment, and lost in a federal district court. In its Feb. 11 decision in Wood v. Arnold, a three-judge panel of the U.S. Court of Appeals for the 4th Circuit, based in Richmond, Va., also ruled for the Charles County district and its officials.
The appeals court said it was important to view the lessons in the Muslim world in context, because focusing on isolated statements would turn the courts into a "defacto curriculum review committee."
The court said the "comparative faith statement" (from the PowerPoint slide suggesting that Muslims' faith was stronger than Christians') was not offered to advance Islam over Christianity. The court noted that a content specialist in the school district later testified that the slide was inappropriate, and he would have advised the teacher not to use it.
Meanwhile, the "shahada" worksheet was meant to assess students' understanding of the lesson, not to advance the Islamic faith, the court said.
"The use of both the comparative faith statement and the shahada assignment in Wood's world history class involved no more than having the class read, discuss, and think about Islam," the 4th Circuit court said. "These types of educational materials, which identify the views of a particular religion, do not amount to an endorsement of religion."
The court also rejected Wood's free-speech challenge, saying that public school students often must be compelled to speak as part of classroom assignments.
"Although a student's right against compelled speech in a public school may be asserted under various circumstances, that right has limited application in a classroom setting in which a student is asked to study and discuss materials with which she disagrees," the court said.