Sechler v. State College Area School District (2000)
Court Decisions on Religious Liberty
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Background Information
On March 17, 2000, Jarrod Sechler and David Warren Saxe filed a complaint against State College Area High School. Sechler's complaint was based upon the allegation that he was prevented from participating in a volunteer lunchroom program because of his status as a "youth pastor" at a local Christian church. Saxe's complaint was based upon the allegation that there no Christian symbols displayed at a winter holiday program at the Corl Street Elementary School, even though symbols from other religions were displayed.
Sechler's case was withdrawn after just one witness testified and Saxe's were retained, even though the case continued to retain the name of the former plaintiff. According to Saxe, the "Winter Holiday" program included a table with a Menorah, a Kwanzaa candelabra, and three books: one about Chanukah, or the "Festival of Lights"; one about Kwanzaa; and one entitled "Celebrations" which was a comparative study of holiday expressions. There were no books or symbols of Christianity. During the program itself, the students sung a variety of secular, seasonal songs - but again, nothing dealing with Christian history or doctrine.
According to Saxe, this extensive inclusion of religious symbols and ideas from Chanukah and Kwanzaa and the simultaneous exclusion of anything and everything Christian was an expression of hostility towards Christianity on the part of school officials.
Court Decision
On November 17, 2000, the U.S. District Court ruled against Saxe's complaint. Relying on past precedent, the Judge McClure found that the mere existence of symbols from non-Christian religions did not constitute an endorsement of those religious beliefs and the absence of Christian symbols did not constitute either express or implied hostility towards religion. On the contrary, McClure pointed out that:
...there is plainly an intent to convey an inclusive message of celebration, hardly a surprising message for the Winter Holiday program.
McClure also disagreed with Saxe's argument that there were no symbols of Christmas and Christianity involved, noting that the "Giving Tree" might be renamed, but it is certainly a traditional symbol of the Christian holiday and the presence of doves as tree decorations. The absence of any overtly Christian symbols, like a crucifix, simply did not make his case. McClure concluded that:
...such a display sends a message of inclusion and celebrates freedom to choose one's own beliefs. Since this message does not offend the Establishment Clause, either as favoring one religion over others or as favoring religion over non-religion, the governmental entity is conveying a legitimate, secular message.
Significance
This decision is one of many which have been part of a general trend in deciding that the mere existence of religious symbols in the context of a general school holiday program does not constitute any automatic endorsement of the faiths to which those symbols belong. Thus, schools are free to include them so long as they are in the context of general educational mission.
What makes this case unique is the fact that these suits are usually brought against the use of some or too many Christian symbols; here, however, we had a Christian complaining about a perceived lack of Christianity - it was, in the words of the court, interpreted as "not Christian enough." According to the court, however, minimal amounts of Christian symbolism which can also be interpreted in a secular manner is not a problem.
This difference is made more interesting by the fact that the case is sometimes cited by conservative Christian groups as supportive of their position. In principle, they are right - the decision does support the inclusion of religious symbols in holiday celebrations. However, the decision also supports the general exclusion of overtly Christian content from those programs. It is a bit of a stretch to conclude, as does the American Center for Law and Justice (the litigation arm of Pat Robertson's media and religious empire) that this case supports schools which want to "teach about the biblical origins of holidays such as Christmas and Easter."
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