1 (Slip Opinion) OCTOBER TERM, 2021
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CARSON, AS PARENT AND NEXT FRIEND OF O. C., ET AL. v.
MAKIN
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE FIRST CIRCUIT
No. 20–1088. Argued December 8, 2021—Decided June 21, 2022
Maine has enacted a program of tuition assistance for parents who live
in school districts that neither operate a secondary school of their own
nor contract with a particular school in another district. Under that
program, parents designate the secondary school they would like their
child to attend, and the school district transmits payments to that
school to help defray the costs of tuition. Participating private schools
must meet certain requirements to be eligible to receive tuition pay-
ments, including either accreditation from the New England Associa-
tion of Schools and Colleges (NEASC) or approval from the Maine De-
partment of Education. But they may otherwise differ from Maine
public schools in various ways. Since 1981, however, Maine has lim-
ited tuition assistance payments to “nonsectarian” schools.
Petitioners sought tuition assistance to send their children to Ban-
gor Christian Schools (BCS) and Temple Academy. Although both
BCS and Temple Academy are accredited by NEASC, the schools do
not qualify as “nonsectarian” and are thus ineligible to receive tuition
payments under Maine’s tuition assistance program. Petitioners sued
the commissioner of the Maine Department of Education, alleging that
the “nonsectarian” requirement violated the Free Exercise Clause and
the Establishment Clause of the First Amendment, as well as the
Equal Protection Clause of the Fourteenth Amendment. The District
Court rejected petitioners’ constitutional claims and granted judgment
to the commissioner. The First Circuit affirmed.
Held: Maine’s “nonsectarian” requirement for otherwise generally avail-
able tuition assistance payments violates the Free Exercise Clause.
Pp. 6–18.
(a) The Free Exercise Clause of the First Amendment protects
2 CARSON v. MAKIN
Syllabus
against “indirect coercion or penalties on the free exercise of religion,
not just outright prohibitions.” Lyng v. Northwest Indian Cemetery
Protective Assn., 485 U. S. 439, 450. The Court recently applied this
principle in the context of two state efforts to withhold otherwise avail-
able public benefits from religious organizations. In Trinity Lutheran
Church of Columbia, Inc. v. Comer, 582 U. S. ___, the Court considered
a Missouri program that offered grants to qualifying nonpr.
Lunenburg, fred c[1]. state aid to private schools focus v4 n1 2010William Kritsonis
The document summarizes the history of state aid to private schools in the United States regarding the separation of church and state. It discusses key Supreme Court cases that have shifted from preventing public funds from going to religious schools to now allowing it. The crumbling of the separation of church and state is based on Chief Justice Rehnquist's view that the Establishment Clause prohibits a national religion but not government aid to religion. As a result, public funds can now go to religious schools as long as no single religion is preferred.
Chapter 10· Page 241Using public funds for private schools hasEstelaJeffery653
Chapter 10
· Page 241
Using public funds for private schools has a major impact on the overall aspects of school finance. Although the public, in general, supports its local public schools, forces continue to promote using taxpayer dollars to assist in providing revenues for nonpublic schools. Legislators, private entrepreneurs, and some citizens are questioning the ability of personnel in the public sector to operate the schools efficiently and to offer enough options to meet the needs of students. Privately sponsored schools have been encouraged for those groups and individuals who are willing to support them financially in addition to participating in financing the public school system. However, such groups have become more vocal, stressing that because the states have a responsibility to provide a free education for the school-age population, they should provide for students in both private and public schools. The use of public funds for educating children in private schools was essentially a non-issue for more than a century. The interpretation of the First Amendment of the U.S. Constitution as part of the Bill of Rights (1791), as well as established state codes, was that an interrelationship between church and state was prohibited, and that direct government support for private or parochial schools was illegal. In 1875, President Ulysses S. Grant called for a Constitutional Amendment that would prohibit the use of public funds for private “sectarian schools.” Motivated by Grant’s speech, Congressman James G. Blaine proposed the following amendment in the U.S. House of Representatives: No State shall make any law respecting an establishment of religion, or prohibiting the free exercise thereof, and no money raised by taxation in any State for the support of public schools, or derived from any public fund therefore, nor any public lands devoted therein, shall ever by under the control of any religious sect, nor shall any money so raised or lands so devoted be divided between religious sects or denominations.1 Blaine’s proposal passed the House but did not pass by two-thirds vote in the Senate. The proposal had a great impact on states; however, as many as 37 states included laws with similar criteria with some included in state constitutions.2 The State Blaine influence has been felt in several court cases as late as 2015. The first court case that opened a door for those who advocated using public funds for church-related schools was Pierce v. Society of Sisters (268 U.S. 510, 1925). In its ruling, the U.S. Supreme Court stated, “The fundamental theory of liberty under which all governments in this union repose excludes any general power of the State to standardize its children by forcing them to accept instruction from public teachers.”3 From this decision to the present day, many changes have occurred that have had and will have a great effect on financing public schools during the next decade. The arguments for and against the use of ...
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
This document summarizes the legal framework around religion in public schools according to court rulings and legislation. It discusses key Supreme Court cases that established religion cannot be established by law and there must be separation of church and state, but that individuals have the right to free exercise of religion. It also examines contemporary issues in Texas schools around topics like school prayer, wearing religious symbols, and student religious groups having equal access to facilities. The goal across rulings is for schools to maintain religious neutrality while protecting individual religious freedom and expression.
The document provides an overview of key topics in school law, including the legal system, types of laws, how laws are made and enforced, landmark Supreme Court rulings affecting education, and other legal issues pertaining to schools such as desegregation, school finance, student and teacher rights, special education, church-state separation, and school choice. Key Supreme Court cases discussed include Brown v. Board of Education, which ruled that segregation was unequal, and San Antonio v. Rodriguez, which found that education is not a fundamental right.
The document discusses Christian rights and expression in public education according to the First Amendment. It provides context on the intent of the First Amendment to prevent establishment of religion while protecting religious freedom. It summarizes key court cases that have established guidelines allowing for individual expression but prohibiting school-endorsed or -led prayer and religious activities. Teachers are limited in discussing their personal faith with students but can discuss objectively different religious beliefs.
Lunenburg, fred c[1]. state aid to private schools focus v4 n1 2010William Kritsonis
The document summarizes the history of state aid to private schools in the United States regarding the separation of church and state. It discusses key Supreme Court cases that have shifted from preventing public funds from going to religious schools to now allowing it. The crumbling of the separation of church and state is based on Chief Justice Rehnquist's view that the Establishment Clause prohibits a national religion but not government aid to religion. As a result, public funds can now go to religious schools as long as no single religion is preferred.
Chapter 10· Page 241Using public funds for private schools hasEstelaJeffery653
Chapter 10
· Page 241
Using public funds for private schools has a major impact on the overall aspects of school finance. Although the public, in general, supports its local public schools, forces continue to promote using taxpayer dollars to assist in providing revenues for nonpublic schools. Legislators, private entrepreneurs, and some citizens are questioning the ability of personnel in the public sector to operate the schools efficiently and to offer enough options to meet the needs of students. Privately sponsored schools have been encouraged for those groups and individuals who are willing to support them financially in addition to participating in financing the public school system. However, such groups have become more vocal, stressing that because the states have a responsibility to provide a free education for the school-age population, they should provide for students in both private and public schools. The use of public funds for educating children in private schools was essentially a non-issue for more than a century. The interpretation of the First Amendment of the U.S. Constitution as part of the Bill of Rights (1791), as well as established state codes, was that an interrelationship between church and state was prohibited, and that direct government support for private or parochial schools was illegal. In 1875, President Ulysses S. Grant called for a Constitutional Amendment that would prohibit the use of public funds for private “sectarian schools.” Motivated by Grant’s speech, Congressman James G. Blaine proposed the following amendment in the U.S. House of Representatives: No State shall make any law respecting an establishment of religion, or prohibiting the free exercise thereof, and no money raised by taxation in any State for the support of public schools, or derived from any public fund therefore, nor any public lands devoted therein, shall ever by under the control of any religious sect, nor shall any money so raised or lands so devoted be divided between religious sects or denominations.1 Blaine’s proposal passed the House but did not pass by two-thirds vote in the Senate. The proposal had a great impact on states; however, as many as 37 states included laws with similar criteria with some included in state constitutions.2 The State Blaine influence has been felt in several court cases as late as 2015. The first court case that opened a door for those who advocated using public funds for church-related schools was Pierce v. Society of Sisters (268 U.S. 510, 1925). In its ruling, the U.S. Supreme Court stated, “The fundamental theory of liberty under which all governments in this union repose excludes any general power of the State to standardize its children by forcing them to accept instruction from public teachers.”3 From this decision to the present day, many changes have occurred that have had and will have a great effect on financing public schools during the next decade. The arguments for and against the use of ...
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
This document summarizes the legal framework around religion in public schools according to court rulings and legislation. It discusses key Supreme Court cases that established religion cannot be established by law and there must be separation of church and state, but that individuals have the right to free exercise of religion. It also examines contemporary issues in Texas schools around topics like school prayer, wearing religious symbols, and student religious groups having equal access to facilities. The goal across rulings is for schools to maintain religious neutrality while protecting individual religious freedom and expression.
The document provides an overview of key topics in school law, including the legal system, types of laws, how laws are made and enforced, landmark Supreme Court rulings affecting education, and other legal issues pertaining to schools such as desegregation, school finance, student and teacher rights, special education, church-state separation, and school choice. Key Supreme Court cases discussed include Brown v. Board of Education, which ruled that segregation was unequal, and San Antonio v. Rodriguez, which found that education is not a fundamental right.
The document discusses Christian rights and expression in public education according to the First Amendment. It provides context on the intent of the First Amendment to prevent establishment of religion while protecting religious freedom. It summarizes key court cases that have established guidelines allowing for individual expression but prohibiting school-endorsed or -led prayer and religious activities. Teachers are limited in discussing their personal faith with students but can discuss objectively different religious beliefs.
Dr. William Allan Kritsonis - Religion in the Schools PPT.William Kritsonis
This document discusses religion in public schools and the legal framework surrounding issues of establishment of religion and free exercise of religion. It covers US Supreme Court rulings establishing guidelines like the Lemon Test to determine if laws violate the separation of church and state. Contemporary issues covered include requirements to say the Pledge of Allegiance, limits on school prayer, exemptions for religious reasons, wearing religious symbols, and rights of student religious groups. The document aims to outline the complex legal issues around religion in schools.
William Allan Kritsonis, PhD
William H. Parker Leadership Academy Hall of Honor
In 2008, Dr. Kritsonis was inducted into the William H. Parker Leadership Academy Hall of Honor, Graduate School, Prairie View A&M University – The Texas A&M University System. He was nominated by doctoral and master’s degree students.
Dr. Kritsonis Lectures at the University of Oxford, Oxford, England
In 2005, Dr. Kritsonis was an Invited Visiting Lecturer at the Oxford Round Table at Oriel College in the University of Oxford, Oxford, England. His lecture was entitled the Ways of Knowing Through the Realms of Meaning.
Dr. Kritsonis Recognized as Distinguished Alumnus
In 2004, Dr. William Allan Kritsonis was recognized as the Central Washington University Alumni Association Distinguished Alumnus for the College of Education and Professional Studies. Dr. Kritsonis was nominated by alumni, former students, friends, faculty, and staff. Final selection was made by the Alumni Association Board of Directors. Recipients are CWU graduates of 20 years or more and are recognized for achievement in their professional field and have made a positive contribution to society. For the second consecutive year, U.S. News and World Report placed Central Washington University among the top elite public institutions in the west. CWU was 12th on the list in the 2006 On-Line Education of “America’s Best Colleges.”
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
This document summarizes a presentation on the future of school choice in Idaho. It discusses the debate around whether taxpayer dollars should fund public schools only or if parents should be able to choose other schools. It provides an overview of current school choice programs in the US and Idaho, including public charter schools, private school vouchers, and education savings accounts. It outlines opportunities and challenges for expanding choice, including support from President Trump but opposition from teachers unions. It concludes by identifying lessons for Idaho, such as addressing constitutional barriers and gaining political and business support.
William Allan Kritsonis, PhD
William H. Parker Leadership Academy Hall of Honor
In 2008, Dr. Kritsonis was inducted into the William H. Parker Leadership Academy Hall of Honor, Graduate School, Prairie View A&M University – The Texas A&M University System. He was nominated by doctoral and master’s degree students.
Dr. Kritsonis Lectures at the University of Oxford, Oxford, England
In 2005, Dr. Kritsonis was an Invited Visiting Lecturer at the Oxford Round Table at Oriel College in the University of Oxford, Oxford, England. His lecture was entitled the Ways of Knowing Through the Realms of Meaning.
Dr. Kritsonis Recognized as Distinguished Alumnus
In 2004, Dr. William Allan Kritsonis was recognized as the Central Washington University Alumni Association Distinguished Alumnus for the College of Education and Professional Studies. Dr. Kritsonis was nominated by alumni, former students, friends, faculty, and staff. Final selection was made by the Alumni Association Board of Directors. Recipients are CWU graduates of 20 years or more and are recognized for achievement in their professional field and have made a positive contribution to society. For the second consecutive year, U.S. News and World Report placed Central Washington University among the top elite public institutions in the west. CWU was 12th on the list in the 2006 On-Line Education of “America’s Best Colleges.”
Professor William Allan Kritsonis, PhD - Distinguished Alumnus, Central Washington University, College of Education and Professional Studies, Ellensburg, Washington.Dr. Kritsonis has traveled and lectured extensively throughout the United States and world-wide. Some international travels include Australia, New Zealand, Tasmania, Turkey, Italy, Greece, Monte Carlo, England, Holland, Denmark, Sweden, Finland, Russia, Estonia, Poland, Germany, Mexico, the Caribbean Islands, Mexico, Switzerland, Grand Cayman, Haiti, St. Maarten, St. John, St. Thomas, St. Croix, St. Lucia, Puerto Rico, Nassau, Freeport, Jamaica, Barbados, Martinique, Canada, Curacao, Costa Rico, Aruba, Venezuela, Panama, Bora Bora, Tahiti, Latvia, Spain, Honduras, and many more. He has been invited to lecture and serve as a guest professor at many universities across the nation and abroad.
DEBATE 22 EDUCATION POLICYASSIGNING STUDENTS TO SCHOOLS BA.docxedwardmarivel
DEBATE
22
EDUCATION POLICY
ASSIGNING STUDENTS TO SCHOOLS BASED ON RACE:
Justified or Unacceptable? ADVOCATE: National Education Association, et al.
JUSTIFIED
SOURCE: Amicus curiae brief to the U.S. Supreme Court in Parents
Involved in Community Schools v. Seattle School District No. 1 (2007) UNACCEPTABLE
ADVOCATE: Asian American Legal Foundation
SOURCE: Amicus curiae brief to the U.S. Supreme Court in Parents
Involved in Community Schools v. Seattle School District No. 1 (2007)
The intersection between education and race has long sparked emotional debate. Prior to the Civil War it was uncommon and in some places illegal to educate children who were not white. The Fourteenth Amendment (1868) requiring equal protection of the law for all citizens made it illegal to overtly deny children of color an education or to give them an expressly inferior one. However, the changes were more cosmetic that substantive. In many places, Jim Crow laws legalized accommo- dations that were supposedly “separate but equal,” but in reality were highly unequal. Blacks were the most numerous victims, but Asian Americans, Hispanics, and others also were relegated to second-class facilities and services. The Supreme Court upheld this fictitious equality in Plessy v. Ferguson (1896), a case that involved railroad car accommodations but also applied to schools and many other points of segregation. That decision stood until the Supreme Court overturned it in Brown v. Board of Education (1954). Writing for the unanimous court, Chief Justice Earl Warren opined that in “public education the doctrine of ‘separate but equal’ has no place. Separate educational facilities are inherently unequal.”
Over the years, the application Brown v. Board of Education slowly eliminated the overtly intentional school segregation, but, like the Fourteenth Amendment, there was a large gap between theoretical importance and practical impact. Two factors lim- ited Brown. One was that some school districts build schools or drew district lines in ways that maintained or created schools that were de facto racially segregated. The second factor involved living patterns. Whites fled cities to the suburbs or sent their children to private schools to avoid racially integrated schools, and urban schools became more and more minority dominated. These population shifts also left cities with diminished tax bases, and the schools declined for want of adequate funding.
In response, the courts moved to a more proactive stance. In a case involving the region centered on Charlotte, North Carolina, where schools remained very segre- gated and the school board resisted moving to desegregate, a federal judge in 1965 found that the segregation was intentional, ordered that all 105 schools integrate, and specified that children be bussed between schools in necessary. The Supreme Court in Swann v. Charlotte-Mecklenburg Board of Education (1971) unanimously backed
2
John T. Rourke, You Decide! 2012 Copy.
Project Case Briefs - Freedom of Religion - Due Process - Freedom of Express...William Kritsonis
This case involved a challenge to a school district's policy of including prayers led by clergy at middle school graduation ceremonies. A rabbi was invited to deliver prayers at a graduation ceremony according to the school district's guidelines. A student's father sued, arguing this violated the Establishment Clause. The Supreme Court ruled 5-4 that including clergy-led prayers at public school graduations is unconstitutional, as it places public school students in a position of participating in a state-sponsored religious exercise. While the government can acknowledge religion, it cannot coerce participation in religious activities. This established limits on prayer and religious exercises in public schools.
The document discusses several key issues regarding religion in public schools under the US and Texas constitutions:
1) It outlines the legal framework of the Establishment Clause and Free Exercise Clause of the First Amendment and how these have been interpreted by the Supreme Court to require separation of church and state but allow freedom of religious expression.
2) It examines several contemporary issues like school prayer, teaching of creationism, holiday celebrations, and student religious groups that public schools have grappled with in light of these constitutional principles.
3) It also discusses related issues like assistance to religious schools, religious exemptions, and limits on proselytizing or advancing particular religious beliefs in schools. Maintaining neutrality while protecting religious freed
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
Ch. 5 Legal Issues in American Schooling - Dr. William Allan KritsonisWilliam Kritsonis
1. The document discusses several key legal issues in American schooling, including the constitutional basis of education and the separation of church and state.
2. It outlines that the Tenth Amendment gives states responsibility for public education and that state constitutions provide for this. Local boards of education derive their power from state governments.
3. Courts have largely upheld the separation of church and state in schools, prohibiting organized religious activities but allowing voluntary student participation outside of school. Students' and teachers' rights are also addressed.
Dr. William Allan Kritsonis (Excellent) Religion in the Schools, PPT.William Kritsonis
This document discusses legal issues surrounding religion in public schools. It begins by outlining the Establishment and Free Exercise clauses of the First Amendment and key Supreme Court cases related to religion and education. It then examines specific contemporary issues like school prayer, teaching creationism, holidays, and more. Throughout, it references federal and state laws and court cases related to finding the appropriate separation of church and state in schools. The document aims to clarify the complex legal framework around this issue.
BAKER DONELSON & BUTLER SNOW - MISSISSIPPI CHARTER SCHOOL SCAMSVogelDenise
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Since Vogel Denise Newsome and/or Interim Prime Minister Vogel Denise Newsome has been BANNED from using the United States’ DESPOTISM Government Regime’s Courts, documentation such as this will be used in EXPOSING the United States of America and/or State of Mississippi Lawyers’ (Baker Donelson Bearman Caldwell & Berkowitz and Butler Snow O’Mara Stevens & Cannada) and their CO-Conspirators’ (Page Kruger & Holland and Phelps Dunbar) roles in the CONSPIRACIES to TAKEOVER the Mississippi Public School System. Since the ISSUANCE of the CEASE and DESIST, it appears that in efforts to get around such LEGAL and LAWFUL actions taken to PROTECT the Children of Natives, Native Americans and Blacks/Negroes/African-Americans/People-Of-Color, Baker Donelson/Butler Snow, etc. – i.e. WHITE Jewish/Zionist/Supremacist Law Firms - have made a WILLFUL, DELIBERATE and MALICIOUS decision to move forward with their TERRORIST and HOSTILE attacks against these PROTECTED Group of SOVEREIGN Citizens; therefore, such attacks may be DEEMED TERRORIST Acts as well as HOSTILE Attacks led by Baker Donelson – i.e. the TERRORIST Regime that PLANNED, ORCHESTRATED and CARRIED OUT the September 11, 2001, BOMBINGS of the World Trade Center Towers, etc.!
The WHITE Jews/Zionists/Supremacists IMPLEMENTED “Integration” and “Desegregation” for purposes of DESTROYING the Communities, Businesses, Schools, Hospitals, etc. of Natives, Native Americans and Blacks/Negroes/African-Americans/People-Of-Color!
Here we are in the 21st Century and there SEGREGATION is STILL “ALIVE” and “THRIVING” within the Lands/Territories known as the United States of America as well as in States as Mississippi where WHITE Jews/Zionists/Supremacists have PLACED their Members/People in Legislative positions and BUILT UP Law Firms for the purposes of PROMOTING “WHITE SUPREMACY” and DESTROYING the LIVELIHOOD, CULTURE, etc. of Natives, Native Americans and Blacks/Negros/African-Americans/People-Of-Color. White Jews/Zionists/Supremacists are seeking the EDUCATIONAL Institutions of these PROTECTED Sovereign Citizens for purposes of BUILDING UP the PRISON INDUSTRY and ENSLAVEMENT, etc.
We look forward to exercising our RIGHTS and PRIVILEGES as Sovereign Citizens to Legally and Lawfully LIBERATE ourselves from the WHITE Jews/Zionists/Supremacists and their United States’ DESPOTISM Government Regime/Empire. . .
Utica International Embassy
c/o Interim Prime Minister Vogel Denise Newsome
Post Office Box 31265
Jackson, Mississippi 39286
(888) 700-5056 – (601) 885-3358 - (513) 680-2922
Website: www.vogeldenisenewsome.com
The Teachers Unions’ Fight for Universal PreschoolJames Dellinger
This summer, Congress will
consider reauthorization of the 2002 No
Child Left Behind Act, the Bush
Administration’s centerpiece education
legislation. This time around, Sen. Edward
Kennedy (D-Mass.) and Rep.
George Miller (D- California) are in the
driver’s seat. What kind of spoils will they
give their teachers union allies—perhaps
funding for “universal preschool”?
Dr. William Allan Kritsonis - Religion in the Schools, PPT.William Kritsonis
The document discusses the legal framework around religion in schools established by the First Amendment and subsequent Supreme Court rulings. It outlines guidelines from the Lemon Test that determine if a law or practice involving religion is constitutional. Key issues addressed include school prayer, teaching of creationism, religious expression of students and teachers, and inclusion of religious elements in programs and ceremonies. The document notes the complexity of balancing religious free expression with the separation of church and state in public schools.
Public schools fall under state control according to the 10th Amendment. States have police power over education and set curriculum standards, while school boards are the local policy-making entities. Teachers are in a contractual relationship with school boards and must follow their policies. Students have constitutional rights to freedom of expression, protest, limited censorship, and due process. Schools aim to provide a safe environment and have policies against violence, bullying, and gangs, enforcing discipline fairly while respecting students' rights. Parents and students have rights regarding access and privacy of educational records.
The document provides background information on the Alabama Accountability Act (AAA) which was passed in 2013 and amended in April 2022. It allows flexibility contracts between the state and local school districts, and creates tax credits for families and donors to private schools. Opponents argue it takes funding from struggling public schools. Supporters see it as providing alternatives for families in "failing" schools and competition for public schools. Key concerns are how "failing" schools are defined, using public funds for private schools, and limiting choice for transfer students.
The document provides guidance on religion in public schools. It discusses several issues including voluntary student prayer, student-initiated classroom prayer, student proselytization, religious content in homework, religious exemptions, religious books in curriculum, religious holiday observances, and student garb/religious symbols. The general principles are that students have rights to religious expression as long as it does not endorse or promote religion or substantially disrupt school activities. School policies must be neutral towards religion.
This document discusses legal issues related to education in the United States. It begins by explaining that the 10th Amendment gives states responsibility for public education. Key court cases are discussed, including those related to separation of church and state, desegregation, students' rights, and teachers' rights. The rights of teachers can differ slightly from other citizens, as schools have an interest in maintaining order, but teachers are generally afforded due process protections.
1IntroductionThe objective of this study plan is to evaluate.docxrobert345678
1
Introduction
The objective of this study plan is to evaluate the viability of our solution in relation to previously conducted test cases for companies operating in industries analogous to those of our own. In this section, we will concentrate on the manner in which these use cases measure the performance characteristics of various technical and behavioral qualities connected with an investment in technology made on behalf of a business. The viewpoints and data sources of stakeholders will be incorporated into our measuring system. This measurement framework will be utilized by us in order to assess and analyze the overall performance of our product. After the solution has been implemented, we will conduct post-implementation evaluations to determine how the solution affected the organization. The management of change will play a significant role in our overall research agenda. The plan will adhere to a certain format in providing the findings of the data analysis.
Measurement framework
In order to present an all-encompassing picture of performance, the measuring framework must to take into account the many stakeholder viewpoints as well as the various data sources. Perspectives from stakeholders may come from a variety of sources, such as the user community, project managers, or senior leadership. Customer feedback, system logs, and performance statistics are three examples of potential data sources (Thabane, 2009).
The purpose of the measurement framework is to supply stakeholders with viewpoints and data sources that may be utilized to evaluate the effectiveness of an investment in technology. The framework consists of four dimensions: behavioral characteristics, organizational aspects, user factors, and technological qualities (McShane, 2018). To evaluate how well the technology investment is working out, there is a separate set of performance indicators linked with each of the dimensions of the evaluation.
Indicators such as system uptime, reaction time, and throughput are examples of technical qualities. Indicators that make up behavioral qualities include things like user happiness, adoption rates, and the costs of training. Indicators like as return on investment (ROI) and total cost of ownership are included in the category of organizational variables (TCO). The metrics that make up user factors include things like user happiness, adoption rates, and training expenses (McShane, 2018).
The measuring framework draws its information from a variety of data sources, including organizational data, user data, performance data, and financial data. The return on investment (ROI) and total cost of ownership (TCO) of the technological investment may both be calculated using financial data (Jalal, 2017). The uptime, reaction time, and throughput of the system may all be evaluated based on the performance statistics. Data from users may be analyzed to determine factors such as user happiness, adoption rates, and the costs of training (Thabane,.
Dr. William Allan Kritsonis - Religion in the Schools PPT.William Kritsonis
This document discusses religion in public schools and the legal framework surrounding issues of establishment of religion and free exercise of religion. It covers US Supreme Court rulings establishing guidelines like the Lemon Test to determine if laws violate the separation of church and state. Contemporary issues covered include requirements to say the Pledge of Allegiance, limits on school prayer, exemptions for religious reasons, wearing religious symbols, and rights of student religious groups. The document aims to outline the complex legal issues around religion in schools.
William Allan Kritsonis, PhD
William H. Parker Leadership Academy Hall of Honor
In 2008, Dr. Kritsonis was inducted into the William H. Parker Leadership Academy Hall of Honor, Graduate School, Prairie View A&M University – The Texas A&M University System. He was nominated by doctoral and master’s degree students.
Dr. Kritsonis Lectures at the University of Oxford, Oxford, England
In 2005, Dr. Kritsonis was an Invited Visiting Lecturer at the Oxford Round Table at Oriel College in the University of Oxford, Oxford, England. His lecture was entitled the Ways of Knowing Through the Realms of Meaning.
Dr. Kritsonis Recognized as Distinguished Alumnus
In 2004, Dr. William Allan Kritsonis was recognized as the Central Washington University Alumni Association Distinguished Alumnus for the College of Education and Professional Studies. Dr. Kritsonis was nominated by alumni, former students, friends, faculty, and staff. Final selection was made by the Alumni Association Board of Directors. Recipients are CWU graduates of 20 years or more and are recognized for achievement in their professional field and have made a positive contribution to society. For the second consecutive year, U.S. News and World Report placed Central Washington University among the top elite public institutions in the west. CWU was 12th on the list in the 2006 On-Line Education of “America’s Best Colleges.”
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
This document summarizes a presentation on the future of school choice in Idaho. It discusses the debate around whether taxpayer dollars should fund public schools only or if parents should be able to choose other schools. It provides an overview of current school choice programs in the US and Idaho, including public charter schools, private school vouchers, and education savings accounts. It outlines opportunities and challenges for expanding choice, including support from President Trump but opposition from teachers unions. It concludes by identifying lessons for Idaho, such as addressing constitutional barriers and gaining political and business support.
William Allan Kritsonis, PhD
William H. Parker Leadership Academy Hall of Honor
In 2008, Dr. Kritsonis was inducted into the William H. Parker Leadership Academy Hall of Honor, Graduate School, Prairie View A&M University – The Texas A&M University System. He was nominated by doctoral and master’s degree students.
Dr. Kritsonis Lectures at the University of Oxford, Oxford, England
In 2005, Dr. Kritsonis was an Invited Visiting Lecturer at the Oxford Round Table at Oriel College in the University of Oxford, Oxford, England. His lecture was entitled the Ways of Knowing Through the Realms of Meaning.
Dr. Kritsonis Recognized as Distinguished Alumnus
In 2004, Dr. William Allan Kritsonis was recognized as the Central Washington University Alumni Association Distinguished Alumnus for the College of Education and Professional Studies. Dr. Kritsonis was nominated by alumni, former students, friends, faculty, and staff. Final selection was made by the Alumni Association Board of Directors. Recipients are CWU graduates of 20 years or more and are recognized for achievement in their professional field and have made a positive contribution to society. For the second consecutive year, U.S. News and World Report placed Central Washington University among the top elite public institutions in the west. CWU was 12th on the list in the 2006 On-Line Education of “America’s Best Colleges.”
Professor William Allan Kritsonis, PhD - Distinguished Alumnus, Central Washington University, College of Education and Professional Studies, Ellensburg, Washington.Dr. Kritsonis has traveled and lectured extensively throughout the United States and world-wide. Some international travels include Australia, New Zealand, Tasmania, Turkey, Italy, Greece, Monte Carlo, England, Holland, Denmark, Sweden, Finland, Russia, Estonia, Poland, Germany, Mexico, the Caribbean Islands, Mexico, Switzerland, Grand Cayman, Haiti, St. Maarten, St. John, St. Thomas, St. Croix, St. Lucia, Puerto Rico, Nassau, Freeport, Jamaica, Barbados, Martinique, Canada, Curacao, Costa Rico, Aruba, Venezuela, Panama, Bora Bora, Tahiti, Latvia, Spain, Honduras, and many more. He has been invited to lecture and serve as a guest professor at many universities across the nation and abroad.
DEBATE 22 EDUCATION POLICYASSIGNING STUDENTS TO SCHOOLS BA.docxedwardmarivel
DEBATE
22
EDUCATION POLICY
ASSIGNING STUDENTS TO SCHOOLS BASED ON RACE:
Justified or Unacceptable? ADVOCATE: National Education Association, et al.
JUSTIFIED
SOURCE: Amicus curiae brief to the U.S. Supreme Court in Parents
Involved in Community Schools v. Seattle School District No. 1 (2007) UNACCEPTABLE
ADVOCATE: Asian American Legal Foundation
SOURCE: Amicus curiae brief to the U.S. Supreme Court in Parents
Involved in Community Schools v. Seattle School District No. 1 (2007)
The intersection between education and race has long sparked emotional debate. Prior to the Civil War it was uncommon and in some places illegal to educate children who were not white. The Fourteenth Amendment (1868) requiring equal protection of the law for all citizens made it illegal to overtly deny children of color an education or to give them an expressly inferior one. However, the changes were more cosmetic that substantive. In many places, Jim Crow laws legalized accommo- dations that were supposedly “separate but equal,” but in reality were highly unequal. Blacks were the most numerous victims, but Asian Americans, Hispanics, and others also were relegated to second-class facilities and services. The Supreme Court upheld this fictitious equality in Plessy v. Ferguson (1896), a case that involved railroad car accommodations but also applied to schools and many other points of segregation. That decision stood until the Supreme Court overturned it in Brown v. Board of Education (1954). Writing for the unanimous court, Chief Justice Earl Warren opined that in “public education the doctrine of ‘separate but equal’ has no place. Separate educational facilities are inherently unequal.”
Over the years, the application Brown v. Board of Education slowly eliminated the overtly intentional school segregation, but, like the Fourteenth Amendment, there was a large gap between theoretical importance and practical impact. Two factors lim- ited Brown. One was that some school districts build schools or drew district lines in ways that maintained or created schools that were de facto racially segregated. The second factor involved living patterns. Whites fled cities to the suburbs or sent their children to private schools to avoid racially integrated schools, and urban schools became more and more minority dominated. These population shifts also left cities with diminished tax bases, and the schools declined for want of adequate funding.
In response, the courts moved to a more proactive stance. In a case involving the region centered on Charlotte, North Carolina, where schools remained very segre- gated and the school board resisted moving to desegregate, a federal judge in 1965 found that the segregation was intentional, ordered that all 105 schools integrate, and specified that children be bussed between schools in necessary. The Supreme Court in Swann v. Charlotte-Mecklenburg Board of Education (1971) unanimously backed
2
John T. Rourke, You Decide! 2012 Copy.
Project Case Briefs - Freedom of Religion - Due Process - Freedom of Express...William Kritsonis
This case involved a challenge to a school district's policy of including prayers led by clergy at middle school graduation ceremonies. A rabbi was invited to deliver prayers at a graduation ceremony according to the school district's guidelines. A student's father sued, arguing this violated the Establishment Clause. The Supreme Court ruled 5-4 that including clergy-led prayers at public school graduations is unconstitutional, as it places public school students in a position of participating in a state-sponsored religious exercise. While the government can acknowledge religion, it cannot coerce participation in religious activities. This established limits on prayer and religious exercises in public schools.
The document discusses several key issues regarding religion in public schools under the US and Texas constitutions:
1) It outlines the legal framework of the Establishment Clause and Free Exercise Clause of the First Amendment and how these have been interpreted by the Supreme Court to require separation of church and state but allow freedom of religious expression.
2) It examines several contemporary issues like school prayer, teaching of creationism, holiday celebrations, and student religious groups that public schools have grappled with in light of these constitutional principles.
3) It also discusses related issues like assistance to religious schools, religious exemptions, and limits on proselytizing or advancing particular religious beliefs in schools. Maintaining neutrality while protecting religious freed
Dr. William Allan Kritsonis, School Law, Use of School Facilities, Religous Rights of Teachers, Religous Freedom of Expression, Religous Rights in Schooling, Due Process, Freedom of Expression, School Prayers, Termination, Due Process
Ch. 5 Legal Issues in American Schooling - Dr. William Allan KritsonisWilliam Kritsonis
1. The document discusses several key legal issues in American schooling, including the constitutional basis of education and the separation of church and state.
2. It outlines that the Tenth Amendment gives states responsibility for public education and that state constitutions provide for this. Local boards of education derive their power from state governments.
3. Courts have largely upheld the separation of church and state in schools, prohibiting organized religious activities but allowing voluntary student participation outside of school. Students' and teachers' rights are also addressed.
Dr. William Allan Kritsonis (Excellent) Religion in the Schools, PPT.William Kritsonis
This document discusses legal issues surrounding religion in public schools. It begins by outlining the Establishment and Free Exercise clauses of the First Amendment and key Supreme Court cases related to religion and education. It then examines specific contemporary issues like school prayer, teaching creationism, holidays, and more. Throughout, it references federal and state laws and court cases related to finding the appropriate separation of church and state in schools. The document aims to clarify the complex legal framework around this issue.
BAKER DONELSON & BUTLER SNOW - MISSISSIPPI CHARTER SCHOOL SCAMSVogelDenise
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Since Vogel Denise Newsome and/or Interim Prime Minister Vogel Denise Newsome has been BANNED from using the United States’ DESPOTISM Government Regime’s Courts, documentation such as this will be used in EXPOSING the United States of America and/or State of Mississippi Lawyers’ (Baker Donelson Bearman Caldwell & Berkowitz and Butler Snow O’Mara Stevens & Cannada) and their CO-Conspirators’ (Page Kruger & Holland and Phelps Dunbar) roles in the CONSPIRACIES to TAKEOVER the Mississippi Public School System. Since the ISSUANCE of the CEASE and DESIST, it appears that in efforts to get around such LEGAL and LAWFUL actions taken to PROTECT the Children of Natives, Native Americans and Blacks/Negroes/African-Americans/People-Of-Color, Baker Donelson/Butler Snow, etc. – i.e. WHITE Jewish/Zionist/Supremacist Law Firms - have made a WILLFUL, DELIBERATE and MALICIOUS decision to move forward with their TERRORIST and HOSTILE attacks against these PROTECTED Group of SOVEREIGN Citizens; therefore, such attacks may be DEEMED TERRORIST Acts as well as HOSTILE Attacks led by Baker Donelson – i.e. the TERRORIST Regime that PLANNED, ORCHESTRATED and CARRIED OUT the September 11, 2001, BOMBINGS of the World Trade Center Towers, etc.!
The WHITE Jews/Zionists/Supremacists IMPLEMENTED “Integration” and “Desegregation” for purposes of DESTROYING the Communities, Businesses, Schools, Hospitals, etc. of Natives, Native Americans and Blacks/Negroes/African-Americans/People-Of-Color!
Here we are in the 21st Century and there SEGREGATION is STILL “ALIVE” and “THRIVING” within the Lands/Territories known as the United States of America as well as in States as Mississippi where WHITE Jews/Zionists/Supremacists have PLACED their Members/People in Legislative positions and BUILT UP Law Firms for the purposes of PROMOTING “WHITE SUPREMACY” and DESTROYING the LIVELIHOOD, CULTURE, etc. of Natives, Native Americans and Blacks/Negros/African-Americans/People-Of-Color. White Jews/Zionists/Supremacists are seeking the EDUCATIONAL Institutions of these PROTECTED Sovereign Citizens for purposes of BUILDING UP the PRISON INDUSTRY and ENSLAVEMENT, etc.
We look forward to exercising our RIGHTS and PRIVILEGES as Sovereign Citizens to Legally and Lawfully LIBERATE ourselves from the WHITE Jews/Zionists/Supremacists and their United States’ DESPOTISM Government Regime/Empire. . .
Utica International Embassy
c/o Interim Prime Minister Vogel Denise Newsome
Post Office Box 31265
Jackson, Mississippi 39286
(888) 700-5056 – (601) 885-3358 - (513) 680-2922
Website: www.vogeldenisenewsome.com
The Teachers Unions’ Fight for Universal PreschoolJames Dellinger
This summer, Congress will
consider reauthorization of the 2002 No
Child Left Behind Act, the Bush
Administration’s centerpiece education
legislation. This time around, Sen. Edward
Kennedy (D-Mass.) and Rep.
George Miller (D- California) are in the
driver’s seat. What kind of spoils will they
give their teachers union allies—perhaps
funding for “universal preschool”?
Dr. William Allan Kritsonis - Religion in the Schools, PPT.William Kritsonis
The document discusses the legal framework around religion in schools established by the First Amendment and subsequent Supreme Court rulings. It outlines guidelines from the Lemon Test that determine if a law or practice involving religion is constitutional. Key issues addressed include school prayer, teaching of creationism, religious expression of students and teachers, and inclusion of religious elements in programs and ceremonies. The document notes the complexity of balancing religious free expression with the separation of church and state in public schools.
Public schools fall under state control according to the 10th Amendment. States have police power over education and set curriculum standards, while school boards are the local policy-making entities. Teachers are in a contractual relationship with school boards and must follow their policies. Students have constitutional rights to freedom of expression, protest, limited censorship, and due process. Schools aim to provide a safe environment and have policies against violence, bullying, and gangs, enforcing discipline fairly while respecting students' rights. Parents and students have rights regarding access and privacy of educational records.
The document provides background information on the Alabama Accountability Act (AAA) which was passed in 2013 and amended in April 2022. It allows flexibility contracts between the state and local school districts, and creates tax credits for families and donors to private schools. Opponents argue it takes funding from struggling public schools. Supporters see it as providing alternatives for families in "failing" schools and competition for public schools. Key concerns are how "failing" schools are defined, using public funds for private schools, and limiting choice for transfer students.
The document provides guidance on religion in public schools. It discusses several issues including voluntary student prayer, student-initiated classroom prayer, student proselytization, religious content in homework, religious exemptions, religious books in curriculum, religious holiday observances, and student garb/religious symbols. The general principles are that students have rights to religious expression as long as it does not endorse or promote religion or substantially disrupt school activities. School policies must be neutral towards religion.
This document discusses legal issues related to education in the United States. It begins by explaining that the 10th Amendment gives states responsibility for public education. Key court cases are discussed, including those related to separation of church and state, desegregation, students' rights, and teachers' rights. The rights of teachers can differ slightly from other citizens, as schools have an interest in maintaining order, but teachers are generally afforded due process protections.
1IntroductionThe objective of this study plan is to evaluate.docxrobert345678
1
Introduction
The objective of this study plan is to evaluate the viability of our solution in relation to previously conducted test cases for companies operating in industries analogous to those of our own. In this section, we will concentrate on the manner in which these use cases measure the performance characteristics of various technical and behavioral qualities connected with an investment in technology made on behalf of a business. The viewpoints and data sources of stakeholders will be incorporated into our measuring system. This measurement framework will be utilized by us in order to assess and analyze the overall performance of our product. After the solution has been implemented, we will conduct post-implementation evaluations to determine how the solution affected the organization. The management of change will play a significant role in our overall research agenda. The plan will adhere to a certain format in providing the findings of the data analysis.
Measurement framework
In order to present an all-encompassing picture of performance, the measuring framework must to take into account the many stakeholder viewpoints as well as the various data sources. Perspectives from stakeholders may come from a variety of sources, such as the user community, project managers, or senior leadership. Customer feedback, system logs, and performance statistics are three examples of potential data sources (Thabane, 2009).
The purpose of the measurement framework is to supply stakeholders with viewpoints and data sources that may be utilized to evaluate the effectiveness of an investment in technology. The framework consists of four dimensions: behavioral characteristics, organizational aspects, user factors, and technological qualities (McShane, 2018). To evaluate how well the technology investment is working out, there is a separate set of performance indicators linked with each of the dimensions of the evaluation.
Indicators such as system uptime, reaction time, and throughput are examples of technical qualities. Indicators that make up behavioral qualities include things like user happiness, adoption rates, and the costs of training. Indicators like as return on investment (ROI) and total cost of ownership are included in the category of organizational variables (TCO). The metrics that make up user factors include things like user happiness, adoption rates, and training expenses (McShane, 2018).
The measuring framework draws its information from a variety of data sources, including organizational data, user data, performance data, and financial data. The return on investment (ROI) and total cost of ownership (TCO) of the technological investment may both be calculated using financial data (Jalal, 2017). The uptime, reaction time, and throughput of the system may all be evaluated based on the performance statistics. Data from users may be analyzed to determine factors such as user happiness, adoption rates, and the costs of training (Thabane,.
1Project One Executive SummaryCole Staats.docxrobert345678
1
Project One: Executive Summary
Cole Staats
Southern New Hampshire University
BUS 225: Critical Business Skills for Success
Jennyfer Puentes
November 14, 2022
Project One: Executive SummaryProblem
With the restricted economic activity expected because of the COVID-19 outbreak, and the rise in inflation the revenue for the automobile engine and parts manufacturing industry has been adjusted to decline by 10.9% by the end of 2022 (Pantalon, 2022). Based on the current challenges the automotive industry faces, we must diversify our engine manufacturing and its operations to expand our revenue. In this presentation, I will be using qualitative and quantitative data to explain why I think our company should rapidly explore the ever-evolving and growing popularity of the electric car industry and develop electric motors. I will show the qualitative data which will focus on the industry reports of engine manufacturing inside the automotive industry. The quantitative data that I will provide will estimate the projections for future operations and provide fact-checked historical data on the automotive industry. Automotive Manufacturing Industry
After conducting extensive research into the current automotive industry status, where I focused on the performance and expectations for the industry's future, the 2021 measured revenue of the US car and automobile manufacturing was $75 billion. This is compared to previous years, such as 2020 $69 billion, and in 2019 and 2018 $92 billion (MarketLine 2021). Although we saw a rise from 2020 to 2021 in revenue the automobile manufacturing industry revenue will continue to not keep pace with previous years. As the domestic demand for new vehicles trends higher, three automotive hubs are expected to gain greater traction over the next few years. With that said the US automotive industry is heavily established in the Great Lakes region. This region represents just over 36% of the automobile manufacturers in the US. Some of the most successful automobile making are located here which include the Ford Motor Company, General Motors, and Fiat Chrysler. All these manufacturers are in Michigan which makes up 15% of all automobile manufacturing revenue in the US. With that said there are 2 more regions where automobile manufacturers operate that make up 50% of all us manufacturers' locations. The Regions are the West Region, making up 25.4% of the industry locations, and the Southeast Region, making up 24.6% of the industry locations. After conducting research, the consumer's current mindset is shifting towards a “greener” option for the automobile. This option would have a smaller carbon footprint, providing an increase in producing vehicles that are more environmentally friendly. As a result of this new stance on a “greener” option by the consumer the hybrid and the electric car are gaining popularity and are expected to multiply over the next five years (MarketLine 2018). “In 2025 the North American hybri.
1
Management Of Care
Chamberlain University
NR452: Capstone
Professor Alison Colvin.
Date: November 23, 2022.
Management of Care
Management of care involves organizing, prioritizing, maintaining strict patient confidentiality, providing patient with efficient care, education to patient and families, risk stratification, coordination of care transition and medication management. Patient care management is provided to client by nurses and other health care professionals “Management of the critically injured patient is optimized by a coordinated team effort in an organized trauma system that allow for rapid assessment and initiation of life- preserving therapies. (Cantrell, E., & Doucet, J. 2018). Effective patient care management can impact patient heath more positively, when all healthcare professionals work together to provide quality care in promoting patient centered care. Adequate patient care can prevent readmission or admission, also can reduce distress, total cost of care, improve self-management, disease control and patient overall health.
Patient care is important to patient because its ensure that patient receive the needed possible care they deserve when in the hospital and out of the hospital, patient will feel their demand is understood and listened to if they health needs are met and understood by professionals that know how to manage their health care needs, health care management team member work together to ensure patient safety through effective communication and collaboration, advocating for patient by connecting patient to community and social services resources that will promote their health care needs can be beneficial to patient, environmental and home risk assessment, and effective facilitation of communication between members of the healthcare team.
Nurses play a role in managing a patient health, roles such as: Critical thinking skills, in this case the nurse can recognize any shift in patient health status which plays a significant role in decision making and patient centered care. Time management: delegation, prioritization such as knowing what to do first, what is important, and knowing what task is more important for the patient at a particular time. Patient education is also one of the many role’s nurses do to educate patient on what to expect during a procedure, or during recovery, also teachings on complications or adverse effects of a medication. Clinical reasoning and judgement which will promote quality of health through patient centered care that addresses patient specific health care needs. Holman, H. C., Williams, “et al”. (2019).
References
Cantrell, E., & Doucet, J. (2018). Initial Management of Life-Threatening Trauma.
DeckerMed Critical Care of the Surgical Patient.
https://doi.org/10.2310/7ccsp.2129
Holman, H. C., Williams, D., Johnson, J., Sommer, S., Ball, B. S., Lemon, T.,
& Assessment Technologies Institute. (2019). Nursing leadership
an.
1NOTE This is a template to help you format Project Part .docxrobert345678
This document provides a template for a student to complete a statistical analysis project involving descriptive statistics, hypothesis testing, and regression analysis. The template outlines the content and statistical analyses to be performed on two variables - sales and calls - including descriptive statistics, hypothesis tests, correlation, regression equation, and estimates. The student is instructed to input their results, analyses, and conclusions into the template for their assignment submission.
15Problem Orientation and Psychologica.docxrobert345678
1
5
Problem Orientation and Psychological Distress Among Adolescents: Do Cognitive Emotion Regulation Strategies Mediate Their Relationship?
Student's name; students' names
Department affiliation; university affiliation
Course name; course number
Instructors’ name
Assignment due date
Part One
The development of essential attitudes and abilities that help determine a person's susceptibility to psychological discomfort occurs throughout adolescence's formative years. This particular research aimed to investigate the relationship between problem-solving-oriented and cognitive-behavioral techniques for emotion regulation and levels of psychological discomfort (Speyer etal.,2021).
Notably, the issue of violence among adolescents is increasingly recognized as a severe problem in terms of public health. However, little research has investigated the importance of techniques to control cognitive emotion in teenagers, despite the increased interest in psychographic risk factors for violent conduct. The primary focus of this study will be to investigate the frequency of violent behaviors shown by adolescents and to determine the nature of the connection that exists between specific coping mechanisms for regulating cognition and emotion and various manifestations of aggressive behavior. Using confidential, self-reporting questionnaires, the research will conduct a cross-sectional survey of 3,315 students in grades 7 to 10 to investigate methods by which young adolescents may manage their cognitive processes, emotions, and actions connected to violence. The participants will be notified about the survey, but their personal information will not be public under any circumstances since this would violate ethical standards.
The influence of a father on his children might also vary depending on the gender and age of the kid. For boys, parental psychological distress is related to higher internalizing and externalizing issues throughout early adolescence. This finding lends credence to the notion that this stage of development may be especially significant in father-son exchanges. On the other hand, there is a correlation between maternal and paternal psychological discomfort in early infancy and increased levels of internalizing and externalizing difficulties in females (Speyer et al.,2021). Growing up with a father who struggles with mental illness may make girls more reserved, reducing the possibility that they would acquire issues that are manifested outside their bodies. This is one of the possible explanations.
Part Two
The whole of this project shall be guided by the research questions below: (what is the prevalence of adolescent violent behaviors? what is the relationship between specific strategies to regulate cognitive emotion and forms of violent behavior?)
To help operationalize the variables, a logistic regression model will be used to determine the nature of the connection between specific violent actions .
122422, 850 AMHow to successfully achieve business integrat.docxrobert345678
12/24/22, 8:50 AMHow to successfully achieve business integration - Chakray
Page 1 of 8https://www.chakray.com/how-to-successfully-achieve-business-integration/
How to successfully achieve
business integration
The whole process of integrated
business computing is a big step for
any company. From the moment it
decides to group all systems and
applications, the company must devote
much effort in creating a more
productive environment in accordance
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12/24/22, 8:50 AMHow to successfully achieve business integration - Chakray
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to the environment in which it is
located. Business integration is a
necessity. From many points of view
and experiences, the different strategies
have brought success to many
companies that were therefore
encouraged to carry out the entire
integration process. The benefits speak
for themselves: lower expenses for
systems, automation of processes, less
time spent in work, better control of
information.
-You can’t miss the 7 benefits of
Enterprise Application Integration!-
This is due to the fact that integrated
business computing works better. The
company’s IT works as a stage for the
renewal of its functions. Its capacity for
updating and deleting errors, as well as
cloud adaptation or hybrid operation,
allows it to generate unparalleled
results.
Companies with integrated business
computing are not only more
productive, but they also stand above
their competitors thanks to the great
work capacity they can assume. It
doesn’t matter if the systems they have
are complex, the management is simple
and allows work policies to be fulfilled
and its employees to perform better.
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1PAGE 5West Chester Private School Case StudyGrand .docxrobert345678
1
PAGE
5
West Chester Private School Case Study
Grand Canyon University
MGT-420: Organizational Behavior and Management
December 11th, 2022
West Chester Private School
Your introduction should be typed here. It should be at least four sentences and include a thesis statement that introduces all the key points of the paper. Please note that you should follow all APA writing rules within your essay. This means avoid first and second person, do not use contractions, and use citations throughout your paper. The final sentence in your introduction must be a strong thesis statement that introduces every key topic that will be introduced in the paper. Remember that a thesis should be one sentence. Here is an example: In the pages to follow, West Chester Private School (WCPS) will be discussed in the context of open systems, organizational culture, the decision to close and the closure process, the impact of technology and innovation on stakeholders, administration closure options, the plans for future direction of WCPS, along with the four functions of management.
External Environment and Open Systems
There are certain ways in which organizations interact with their external environment (as open systems). These ways rely on the Systems Approach to Management Theory, which perceives an organization as an open system that consists of interdependent and interrelated parts interacting as sub-systems (Jackson, 2017). Generally, organizations rely on the exchange of resources and information with their environments. More so, they cannot hold complete control over their behavior and actions, which are significantly impacted by external forces. For example, an organization may be impacted by various environmental conditions such as government regulations, client demands, and raw material availability. As an open system, an organization can interact with the external environment in the context of inputs, transformations, and outputs. Inputs refer to both human and non-human resources like materials, energy, and information. Transformations refer to the conversion of inputs into outputs. For example, a school can transform a student into an educated individual. Finally, outputs refer to what an organization is giving to the environment.
Internal Environment and Organizational Culture
At the time of the closure, the effectiveness of West Chester Private School (WCPS) as an open system was inadequate. One important factor that impacts the effectiveness of an open system is feedback. Feedback refers to the information that an open system receives from the external environment, which can be used to maintain a system at optimal working conditions or a steady state (Jung & Vakharia, 2019). In the case of WCPS, feedback could be received from parents, teachers, and students. At the time of the closure, none of these stakeholders was consulted. Instead, WCPS made a unilateral decision to close down two campuses without considering the input of parents, te.
12Toxoplasmosis and Effects on Abortion, And Fetal A.docxrobert345678
12
Toxoplasmosis and Effects on Abortion, And Fetal Abnormalities
Toxoplasmosis and Effects on Abortion, And Fetal Abnormalities
Abstract
The placenta is an immune-privileged organ that may tolerate antigen exposure without eliciting a strong inflammatory response that could result in an abortion. After that, the pregnancy can progress normally. Th1 answers, characterized by interferon-, are essential for suppressing intracellular infections. Therefore, the maternal immune system finds a catch-22 when intracellular parasites invade the placenta. The pro-inflammatory response required to eradicate the virus carries the danger of causing an abortion. Toxoplasma is a potent parasite that causes lifetime infections and is a leading cause of abortions in people and animals. This paper speculates that the pregnancy outcome may be affected by the Toxoplasma strain and the effectors of the parasite, both of which can modify the signaling pathways of the host cell.
Introduction
Fetuses infected with the protozoan parasite Toxoplasma gondii can develop a disorder known as toxoplasmosis, sometimes called congenital toxoplasmosis. This disease is transmitted from mother to child in the womb. A miscarriage or a stillbirth might happen as a result. A child with this illness may also have significant and progressively deteriorating difficulties in their vision, hearing, motor skills, cognitive ability, and other areas of development. The parasite Toxoplasma gondii is blamed for many pregnancies ending in miscarriage (Arranz-Solís et al., 2021). Most abortions happen in the first trimester of pregnancy or during the early stages of acute sickness. This research aimed to determine if women who had an abortion were more likely to be infected with toxoplasmosis.
To make matters worse, the toxoplasmosis-causing Toxoplasma gondii is an obligate intracellular pathogen that infects nearly every animal species with a thermoregulatory system. Transferring Toxoplasma from one host to another requires the development of tissue cysts that are infectious when ingested. This means the parasite is incentivized to ensure that the host organism lives during the infection. The parasite does this by stimulating an immune response powerful enough to limit parasite reproduction. Toxoplasma, on the other hand, uses a unique set of effectors to evade the immune response and ensure that the parasite population does not decrease to zero.
Results
Type II strains are the most common cause of infection in both animal and human hosts. However, all four clonal lineages of Toxoplasma may be found throughout Europe and North America. It has been established, however, that the bulk of the South American isolates identified is genetically distinct from the strains seen in North America and Europe. Certain sorts of isolates have been labeled as atypical strains. Birth abnormalities apart, type II strains are the most common in Europe and North America, where the great majority of .
122022, 824 PM Rubric Assessment - SOC1001-Introduction to .docxrobert345678
This document contains a rubric used to assess a student's draft and final submission of a sociology project. The rubric evaluates students on criteria such as including an introduction and conclusion, developing body paragraphs with support and examples, using proper grammar and APA style, and submitting a draft for feedback. Points are awarded on a scale from 0 to 40 for each criterion, with 0 being no submission and higher scores reflecting more developed, error-free work. The total possible score is 120 points.
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1 of 1 DOCUMENT
JAMES E. PETERSON, Plaintiff-Appellant, v. HAROLD KENNEDY, RICHARD
A. BERTHELSEN, and NATIONAL FOOTBALL LEAGUE PLAYERS
ASSOCIATION, Defendants-Appellees
No. 84-5788
UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
771 F.2d 1244; 1985 U.S. App. LEXIS 23077; 120 L.R.R.M. 2520; 103 Lab. Cas.
(CCH) P11,677
February 6, 1985, Argued and Submitted - Los Angeles, California
September 16, 1985, Decided
PRIOR HISTORY: [**1] Appeal from the United States District Court for the Southern District of California, D.C.
NO. CV-80-1810-N, Honorable Leland C. Nielsen, District Judge, Presiding.
CASE SUMMARY:
PROCEDURAL POSTURE: Plaintiff professional football player appealed from judgments of the United States
District Court for the Southern District of California entered in favor of defendant union on plaintiff's claim for breach
of the duty of fair representation and in favor of defendant attorneys on plaintiff's legal malpractice claim.
OVERVIEW: Plaintiff football player filed suit against defendant union for breach of the duty of fair representation,
alleging that defendant attorneys, who were staff counsel for defendant union, erroneously advised him to file the wrong
type of grievance and failed to rectify the error when there was an opportunity to do so. Plaintiff also claimed that
defendant attorneys committed malpractice. The trial court entered judgment for defendants. On appeal, the court
affirmed. The court found that defendant union did not act in an arbitrary, discriminatory, or bad faith manner and held
that mere negligence or an error in judgment was insufficient to impose liability for breach of the duty of fair
representation. The court affirmed the directed verdict in favor of defendant first attorney because a union attorney may
not be held liable in malpractice to an individual union member for acts performed as the union's agent in the collective
bargaining process. The court affirmed the summary judgment entered in favor of defendant second attorney. The trial
court lacked personal jurisdiction over him because his only contact with the forum state were phone calls and letters.
OUTCOME: The court affirmed the judgment in favor of defendant union because it did not breach its duty of fair
representation. The court affirmed the directed verdict in favor of defendant first attorney because he was not liable in
malpractice to plaintiff football player for acts he performed as the union's agent. The court affi.
121122, 1204 AM Activities - IDS-403-H7189 Technology and S.docxrobert345678
12/11/22, 12:04 AM Activities - IDS-403-H7189 Technology and Society 22EW2 - Southern New Hampshire University
https://learn.snhu.edu/d2l/common/dialogs/nonModal/blank.d2l?d2l_body_type=1&d2l_nonModalDialog_cb=d2l_cntl_68566de1f6094c60a65417448e14cb1f_1&d2l_nonModalDialog_cbwin=68566de1f6094c60a6541744… 1/5
IDS 403 Module Six Activity Rubric
Activity: 6-2 Activity: Reflection: Society
Course: IDS-403-H7189 Technology and Society 22EW2
Name: Jayee Johnson
Criteria Proficient Needs Improvement Not Evident Criterion Score
Reliable Evidence
from Varied Sources
30 / 30
Criterion Feedback
30 points
Integrates reliable
evidence from varied
sources throughout
the paper to support
analysis
22.5 points
Shows progress
toward proficiency,
but with errors or
omissions; areas for
improvement may
include drawing from
a diverse pool of
perspectives, using
more varied sources
to support the
analysis, or
integrating evidence
and sources
throughout the paper
to support the
analysis
0 points
Does not attempt
criterion
12/11/22, 12:04 AM Activities - IDS-403-H7189 Technology and Society 22EW2 - Southern New Hampshire University
https://learn.snhu.edu/d2l/common/dialogs/nonModal/blank.d2l?d2l_body_type=1&d2l_nonModalDialog_cb=d2l_cntl_68566de1f6094c60a65417448e14cb1f_1&d2l_nonModalDialog_cbwin=68566de1f6094c60a6541744… 2/5
Criteria Proficient Needs Improvement Not Evident Criterion Score
You did a good job in integrating evidence and support from outside sources.
Different General
Education Lens
22.5 / 30
Criterion Feedback
You needed to identify an alternative lens through which to view your specific technology. How would your analysis
of your identified technologyʼs role in your event have been different if viewed through this lens?
30 points
Explains at least one
way in which the
analysis might have
been different if
another general
education lens was
used to analyze the
technologyʼs role in
the event
22.5 points
Shows progress
toward proficiency,
but with errors or
omissions; areas for
improvement may
include connecting a
different lens to
technologyʼs role in
the event or
providing more
support of that
connection
0 points
Does not attempt
criterion
12/11/22, 12:04 AM Activities - IDS-403-H7189 Technology and Society 22EW2 - Southern New Hampshire University
https://learn.snhu.edu/d2l/common/dialogs/nonModal/blank.d2l?d2l_body_type=1&d2l_nonModalDialog_cb=d2l_cntl_68566de1f6094c60a65417448e14cb1f_1&d2l_nonModalDialog_cbwin=68566de1f6094c60a6541744… 3/5
Criteria Proficient Needs Improvement Not Evident Criterion Score
Interactions
30 / 30
Criterion Feedback
I thought that you did a really good job here in considering how your analysis of technology might impact your
interactions with those from other cultures or backgrounds.
30 points
Explains how
analyzing the
technologyʼs role in
the event can help
interactions with
those of a different
viewpoint, culture, or
perspectiv.
1. When drug prices increase at a faster rate than inflation, the .docxrobert345678
1. When drug prices increase at a faster rate than inflation, the groups of people that bear the burden of this increase are taxpayers and Medicare beneficiaries. Taxpayers are paying higher taxes as a result of increased government spending, and Medicare beneficiaries cannot keep up with the price of their prescriptions. When it comes to the factors in making a decision about increasing drug prices, I believe Big Pharma companies should act in a socially responsible manner, meaning they should base their decisions not solely on profit, and not solely on healthcare. There should be a balance, and new policies would be beneficial to help maintain that balance.
2. Lower-level employees have the responsibility to provide accurate information to management so that they can make the most informed decision. Lower-level employees also have the responsibility to not purposefully make material mistakes or purposefully not correct a known mistake.
3. Increased government spending will increase taxes for taxpayers and decrease available spending for other worthy issues. Taxpayers will essentially pay more in taxes and therefore have less income available. With drug prices rising faster than inflation, this will cause a widening gap between annual income and costs. Also, private health insurance costs will increase premiums and out of pocket costs for members. The stakeholders most directly impacted are the senior citizens that are dependent on their medication and can’t afford it or any other out of pocket costs because of the already wide gap between their income and expenses. I believe the government itself can be seen as a stakeholder as well because as they continue to increase Medicare funding, their deficit increases, causing them to take action to allocate resources effectively.
4. If the increase in price of existing drugs is preventing those who need those drugs from obtaining them, then to me it is hard to justify the increase based on R&D. There will always be a trade-off between affordable drugs and how quickly we can get new drugs. The government must devise a policy that improves Big Pharma companies’ incentive for affordability
and innovation.
5. Explain what you think each of the following statements means in the context of moral development.
. How far are you willing to go to do the right thing?
1. Stage 6 of moral development is about universal “self-chosen” ethical principles. This stage is about following your conscience even if it violates the law. In thinking of moral development, as time passes, one’s level of ethical reasoning advances and some issues may spark moral outrage that force a response.
. How much are you willing to give up to do what you believe is right?
1. This statement relates to moral development and how sometimes doing the right thing can have negative consequences. For example, an employee may notice a purposeful mistake by a manager. Let’s assume the employee is certain they will receiv.
1. Which of the following sentences describe a child functioning a.docxrobert345678
This document contains a 5 question multiple choice assessment about child language development and metalinguistic abilities. It tests understanding of rhyming, sound identification, syllable segmentation and blending skills in children ages 2-6. These skills develop as children progress from pre-linguistic to metalinguistic levels of language understanding. The document also contains a literature review on factors that impact work-life balance and job satisfaction such as stress, behavioral traits, attachment styles and domain interference/facilitation. It proposes a study using surveys and journaling to identify issues for employees and design interventions to improve work-life balance and performance.
1. How did the case study impact your thoughts about your own fina.docxrobert345678
1. How did the case study impact your thoughts about your own finances?
2. What were your thoughts and observations as you created your own balance sheet?
3. How might the balance sheet help you in future financial planning?
4. How close to reality do you think your estimated personal cash flow statement will be if you track your actual income and expenses for a month?
1. It gave me the desire to track my finances more closely and objectively. I liked how we can determine our net worth through some simple calculations and our inflows and outflows per month. Generally, I rely on simple finance apps like
Mint to track my finances. Currently, I do not create monthly budgets, but I now believe such action could be helpful.
2. I know that I have more assets than I am counting in the excel sheet. Therefore, my net worth is potentially higher. I also have a variety of streaming platforms.
I would benefit from switching from one platform to another month by month to save money. Streaming platforms are not a significant expense. Currently, my most considerable expense is transportation. Since gas prices are falling, this will help increase my surplus.
3. Accounting is math: it either works or doesn’t. Each can be traced from its inception (a sale, an expense, a money transfer) to the line on the financial statement. Since I don’t have much experience with financials, I try to seek out a mentor who is a family member. A balance sheet will ensure that I am not spending foolishly and ensure I am making appropriate purchases within the limits I set for myself. Proper planning will ensure I maximize my net worth.
4. It is important to consider cash flow when planning for the future
. It is important to save money every month in order to be able to make better financial decisions in the future. I hope to use some investing approaches for beginners to purchase funds without getting into debt. Most people underestimate how much they truly spend in a month. Therefore, I am underestimating how much I spend as well. I eat out quite a bit with friends and family, so my restaurant bill for the holidays might be higher than anticipated.
Foreign Policy Association
China and America
Author(s): David M. Lampton
Source: Great Decisions , 2018, (2018), pp. 35-46
Published by: Foreign Policy Association
Stable URL: https://www.jstor.org/stable/10.2307/26593695
JSTOR is a not-for-profit service that helps scholars, researchers, and students discover, use, and build upon a wide
range of content in a trusted digital archive. We use information technology and tools to increase productivity and
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Foreign Policy Association is collaborating with JSTOR to digitize, preserve.
1 The Biography of Langston Hughes .docxrobert345678
1
The Biography of Langston Hughes
Yanai Gonzalez
Ana G Mendez
November 17, 2022
The Biography of Langston Hughes
THE BIOGRAPHY OF LANGSTON HUGHES
2
On February 1, 1901, James Mercer Langston Hughes was born. He was born in
Joplin, Missouri, to James and Caroline Hughes, into a family of enslaved people and
enslavers (Leach, 2004). His father departed from the family, later divorcing their family,
forcing Langston's mother to move to Lawrence, Kansas, with his maternal grandmother. It
was from the latter that Langston learned about African American traditions, installing an
enormous sense of pride into the young man (Hughes et al., 2001). This greatly influenced his
writing, as evidenced by poems such as Mother to Son. He would then go on to join
Columbia University to study engineering, where he would write poetry for the Columbia
Daily Spectator. As a result of racial discrimination, he finally left the school and resided in
Harlem, where he was engulfed by the vibrant feeling of life (Leach, 2004).
Langston began cruising as a crewman aboard the S.S. Malone in 1923, after doing a
few odd jobs. He subsequently took his first white-collar job as Carter G. Woodson's assistant
at the Association for the Study of African American Life and History, a historian. He'd then
leave his work since it didn't enable him to write. He would later work as a busboy. He got
his big writing break when he met Vachel Lindsay, a famous poet of the time, with whom
Langston shared his poetry (Leach, 2004). Lindsay was heavily impressed and helped
Langston reach the big stage. Langston then went on to earn a Bachelor of Arts degree from
Lincoln University.
Langston began his literary career in 1921 by publishing The Crisis in the National
Association for the Advancement of Colored People magazine (Leach, 2004). The poem
Mother to Son was in this book and would go on to get much acclaim. He would go on to
release The Weary Blues along with other novels, short stories, and poems (Hughes et al.,
2001). He participated heavily in the Harlem Renaissance. Langston would pass away on
May 22, 1967, from surgery complications while being treated for prostate cancer.
Mother To Son by Langston Hughes
THE BIOGRAPHY OF LANGSTON HUGHES
3
Well, son, I’ll tell you:
Life for me ain’t been no crystal stair.
It’s had tacks in it,
And splinters,
And boards torn up,
And places with no carpet on the floor—
Bare.
But all the time
I’se been a-climbin’ on,
And reachin’ landin’s,
And turnin’ corners,
And sometimes goin’ in the dark
Where there ain’t been no light.
So boy, don’t you turn back.
Don’t you set down on the steps
’Cause you finds it’s kinder hard.
Don’t you fall now—
For I’se still goin’, honey,
I’se still climbin’,
And life for me ain’t been no crystal stair.
References
THE BIOGRAPHY OF LANGSTON HUGHES
4
Hughes, L., Hubbard, .
1 Save Our Doughmocracy A Moophoric Voter Registratio.docxrobert345678
This document provides a proposal for an event called "Save Our Doughmocracy: A Moophoric Voter Registration & Ice Cream Social Event" hosted by Ben & Jerry's and the Democratic National Committee. The event aims to help people register to vote in Georgia through a fun experience of sampling a new Ben & Jerry's ice cream flavor and connecting with Democratic candidates. The proposal outlines the event goals, strategy, SWOT analysis, target audience, location, timeline, budget, and marketing plan. The key goals are to support voter registration and Ben & Jerry's social mission of advocating for democracy. The event's uniqueness of combining voter registration, politics, and ice cream into one experience gives it a competitive advantage over similar
1 MINISTRY OF EDUCATION UNIVERSITY OF HAIL .docxrobert345678
1
MINISTRY OF EDUCATION
UNIVERSITY OF HAIL
COLLEGE OF ENGINEERING
كلية الهندسة
College of Engineering
Research Proposal Template
Please structure your Research Proposal based on the headings provided below, use a clear and legible font
and observe the page/word limit.
Research Project Title:
Motor Vehicle Safety Defects and Recall System: An Empirical Study in Saudi Arabia
Student Details:
Student Name
Student ID
Email Address
Date of Submission
Research Project
Serial No.
Supervisor Name Supervisor Signature Start Date
Only for College Officials Use
College Approval
Master of Quality Engineering and Management
Research Proposal
2
Master of Quality Engineering and Management 2020-2021
كلية الهندسة
College of Engineering
1- Research Title
Provide a short descriptive title of your proposed research (max. 20 words)
Motor Vehicle Safety Defects and Recall System: An Empirical Study in Saudi Arabia
2- Research Summary
Summarize the aims, significance and expected outcomes of your proposed research (max. 250 words).
It is to set the mechanism for recalling vehicles with manufacturing defects that affect in
one way or another the safety of vehicles and their users, and this is done by linking a
unified system in which the defective vehicle data is added and called in the system to
the maintenance centers of the concerned vehicle agencies. Workmanship defects are
classified as: (1) Basic defects, which are considered to have a serious and direct impact
on the safety of the vehicle and its users, and the inspection process cannot be passed
until after the defect is fixed. (2) Warning defects, which are considered a defect in the
product, but the effect of the defect does not threaten the safety of the vehicle and its
users pass the examination process and the defect is added as a warning only.
This research proposal aims to find the most effective way to reach every defected
vehicle and the effective way to deal with the vehicle owner to do the necessary changes
especially if it's related to safety in a systematic way. The purpose of the project is to
develop a new business model that was never used everywhere in the world and Saudi
Arabia will take the lead to publish this model to the rest of the world. Ensuring that the
practice will be used is the most effective practise as enabling to force the defected car
owner to have their vehicles fixed and the defected was solved.
Master of Quality Engineering and Management
Research Proposal
3
Master of Quality Engineering and Management 2020-2021
كلية الهندسة
College of Engineering
3- Introduction
This section should provide a description of the basic facts and importance of the research area - What is the research
area, the motivation of research, and how important is it for the industry practice/knowledge advancement? (max. 200 .
1
Assessment Brief
Module Code
Module Name Managing Operations and the Supply Chain
Level
7
Module Leader Andrew Gough
Module Code
BSOM046
Assessment title:
AS1: The Future of Work
Weighting: 40%
Submission dates:
13 December 2022, please see NILE (Northampton Integrated
Learning Environment) under Assessment Information
Feedback and Grades
due:
12 January 2023
Please read the whole assessment brief before starting work on the Assessment Task.
The Assessment Task
You will conduct a review of the literature to identify the origins of the concept of the
Technological Unemployment and to chart its development up to the present day.
Following your review, you are to critically evaluate the impact of Technological
Unemployment on a company of your choice.
You will be expected to illustrate your discussion with examples from the trade press
and other authoritative sources.
The word count limit for this assessment is 1800 words (+/- 10%). In line with normal
practice, tables, figures, references and appendices are excluded from this word count.
Pawanrat Meepian
Pawanrat Meepian
2
Assessment Breakdown
1. Establish the scenario for your report by selecting an organisation of any type, sector and
size to focus your report on. Describe:
a) Which organisation is it? (type, sector and size)
b) What are the main products and/or services provided by the organisation?
c) Who are the main customers?
(10% of word count)
2. Prepare a literature review, charting the development of the concept of Technological
Unemployment from its inception until the present day.
Ensure that you include references to at least 10 peer-reviewed articles, including the 2017
paper by Frey and Osborne that has been supplied. You may also find relevant reviews in
the trade press and from other authoritative sources.
(45% of word count)
3. Apply Frey and Osborne’s findings (Appendix A) in the context of your chosen company.
Consider a low impact scenario, when only jobs at high risk (> 70%) are replaced
by technology. How does Frey and Osborne’s study suggest that the company will change?
Compare the predictions implied by Frey and Osborne’s study with the recent work by
Cords and Prettner (2022).
In your view, is Technological Unemployment a net benefit to society?
(45% of word count)
Learning Outcomes
On successful completion of this assessment, you will be able to:
a) Recognise, analyse and critically reflect on key concepts, managerial frameworks
and techniques available to operations managers.
b) Demonstrate conceptual and practical understanding of the opportunities and
constraints that organisational characteristics place on operations managers and on
operational decision making in the supply chain context.
f) Demonstrate ability to relate theory to practice and to identify and proactively
anticipate broader implications for.
ISO/IEC 27001, ISO/IEC 42001, and GDPR: Best Practices for Implementation and...PECB
Denis is a dynamic and results-driven Chief Information Officer (CIO) with a distinguished career spanning information systems analysis and technical project management. With a proven track record of spearheading the design and delivery of cutting-edge Information Management solutions, he has consistently elevated business operations, streamlined reporting functions, and maximized process efficiency.
Certified as an ISO/IEC 27001: Information Security Management Systems (ISMS) Lead Implementer, Data Protection Officer, and Cyber Risks Analyst, Denis brings a heightened focus on data security, privacy, and cyber resilience to every endeavor.
His expertise extends across a diverse spectrum of reporting, database, and web development applications, underpinned by an exceptional grasp of data storage and virtualization technologies. His proficiency in application testing, database administration, and data cleansing ensures seamless execution of complex projects.
What sets Denis apart is his comprehensive understanding of Business and Systems Analysis technologies, honed through involvement in all phases of the Software Development Lifecycle (SDLC). From meticulous requirements gathering to precise analysis, innovative design, rigorous development, thorough testing, and successful implementation, he has consistently delivered exceptional results.
Throughout his career, he has taken on multifaceted roles, from leading technical project management teams to owning solutions that drive operational excellence. His conscientious and proactive approach is unwavering, whether he is working independently or collaboratively within a team. His ability to connect with colleagues on a personal level underscores his commitment to fostering a harmonious and productive workplace environment.
Date: May 29, 2024
Tags: Information Security, ISO/IEC 27001, ISO/IEC 42001, Artificial Intelligence, GDPR
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How to Build a Module in Odoo 17 Using the Scaffold MethodCeline George
Odoo provides an option for creating a module by using a single line command. By using this command the user can make a whole structure of a module. It is very easy for a beginner to make a module. There is no need to make each file manually. This slide will show how to create a module using the scaffold method.
বাংলাদেশের অর্থনৈতিক সমীক্ষা ২০২৪ [Bangladesh Economic Review 2024 Bangla.pdf] কম্পিউটার , ট্যাব ও স্মার্ট ফোন ভার্সন সহ সম্পূর্ণ বাংলা ই-বুক বা pdf বই " সুচিপত্র ...বুকমার্ক মেনু 🔖 ও হাইপার লিংক মেনু 📝👆 যুক্ত ..
আমাদের সবার জন্য খুব খুব গুরুত্বপূর্ণ একটি বই ..বিসিএস, ব্যাংক, ইউনিভার্সিটি ভর্তি ও যে কোন প্রতিযোগিতা মূলক পরীক্ষার জন্য এর খুব ইম্পরট্যান্ট একটি বিষয় ...তাছাড়া বাংলাদেশের সাম্প্রতিক যে কোন ডাটা বা তথ্য এই বইতে পাবেন ...
তাই একজন নাগরিক হিসাবে এই তথ্য গুলো আপনার জানা প্রয়োজন ...।
বিসিএস ও ব্যাংক এর লিখিত পরীক্ষা ...+এছাড়া মাধ্যমিক ও উচ্চমাধ্যমিকের স্টুডেন্টদের জন্য অনেক কাজে আসবে ...
How to Manage Your Lost Opportunities in Odoo 17 CRMCeline George
Odoo 17 CRM allows us to track why we lose sales opportunities with "Lost Reasons." This helps analyze our sales process and identify areas for improvement. Here's how to configure lost reasons in Odoo 17 CRM
Assessment and Planning in Educational technology.pptxKavitha Krishnan
In an education system, it is understood that assessment is only for the students, but on the other hand, the Assessment of teachers is also an important aspect of the education system that ensures teachers are providing high-quality instruction to students. The assessment process can be used to provide feedback and support for professional development, to inform decisions about teacher retention or promotion, or to evaluate teacher effectiveness for accountability purposes.
हिंदी वर्णमाला पीपीटी, hindi alphabet PPT presentation, hindi varnamala PPT, Hindi Varnamala pdf, हिंदी स्वर, हिंदी व्यंजन, sikhiye hindi varnmala, dr. mulla adam ali, hindi language and literature, hindi alphabet with drawing, hindi alphabet pdf, hindi varnamala for childrens, hindi language, hindi varnamala practice for kids, https://www.drmullaadamali.com
it describes the bony anatomy including the femoral head , acetabulum, labrum . also discusses the capsule , ligaments . muscle that act on the hip joint and the range of motion are outlined. factors affecting hip joint stability and weight transmission through the joint are summarized.
A review of the growth of the Israel Genealogy Research Association Database Collection for the last 12 months. Our collection is now passed the 3 million mark and still growing. See which archives have contributed the most. See the different types of records we have, and which years have had records added. You can also see what we have for the future.
This presentation was provided by Steph Pollock of The American Psychological Association’s Journals Program, and Damita Snow, of The American Society of Civil Engineers (ASCE), for the initial session of NISO's 2024 Training Series "DEIA in the Scholarly Landscape." Session One: 'Setting Expectations: a DEIA Primer,' was held June 6, 2024.
1. 1 (Slip Opinion) OCTOBER TERM, 2021
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be
released, as is
being done in connection with this case, at the time the opinion
is issued.
The syllabus constitutes no part of the opinion of the Court but
has been
prepared by the Reporter of Decisions for the convenience of
the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S.
321, 337.
2. SUPREME COURT OF THE UNITED STATES
Syllabus
CARSON, AS PARENT AND NEXT FRIEND OF O. C., ET AL.
v.
MAKIN
CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR
THE FIRST CIRCUIT
No. 20–1088. Argued December 8, 2021—Decided June 21,
2022
Maine has enacted a program of tuition assistance for parents
who live
in school districts that neither operate a secondary school of
their own
nor contract with a particular school in another district. Under
that
program, parents designate the secondary school they would
like their
child to attend, and the school district transmits payments to
that
school to help defray the costs of tuition. Participating private
schools
must meet certain requirements to be eligible to receive tuition
pay-
ments, including either accreditation from the New England
Associa-
tion of Schools and Colleges (NEASC) or approval from the
Maine De-
partment of Education. But they may otherwise differ from
Maine
3. public schools in various ways. Since 1981, however, Maine
has lim-
ited tuition assistance payments to “nonsectarian” schools.
Petitioners sought tuition assistance to send their children to
Ban-
gor Christian Schools (BCS) and Temple Academy. Although
both
BCS and Temple Academy are accredited by NEASC, the
schools do
not qualify as “nonsectarian” and are thus ineligible to receive
tuition
payments under Maine’s tuition assistance program. Petitioners
sued
the commissioner of the Maine Department of Education,
alleging that
the “nonsectarian” requirement violated the Free Exercise
Clause and
the Establishment Clause of the First Amendment, as well as the
Equal Protection Clause of the Fourteenth Amendment. The
District
Court rejected petitioners’ constitutional claims and granted
judgment
to the commissioner. The First Circuit affirmed.
Held: Maine’s “nonsectarian” requirement for otherwise
generally avail-
able tuition assistance payments violates the Free Exercise
Clause.
Pp. 6–18.
(a) The Free Exercise Clause of the First Amendment protects
4. 2 CARSON v. MAKIN
Syllabus
against “indirect coercion or penalties on the free exercise of
religion,
not just outright prohibitions.” Lyng v. Northwest Indian
Cemetery
Protective Assn., 485 U. S. 439, 450. The Court recently
applied this
principle in the context of two state efforts to withhold
otherwise avail-
able public benefits from religious organizations. In Trinity
Lutheran
Church of Columbia, Inc. v. Comer, 582 U. S. ___, the Court
considered
a Missouri program that offered grants to qualifying nonprofit
organi-
zations that installed cushioning playground surfaces, but
5. denied such
grants to any applicant that was owned or controlled by a
church, sect,
or other religious entity. The Court held that the Free Exercise
Clause
did not permit Missouri to “expressly discriminate[ ] against
otherwise
eligible recipients by disqualifying them from a public benefit
solely
because of their religious character.” 582 U. S., at ___–___.
And in
Espinoza v. Montana Department of Revenue, 591 U. S. ___,
the Court
held that a provision of the Montana Constitution barring
government
aid to any school “controlled in whole or in part by any church,
sect, or
denomination” violated the Free Exercise Clause by prohibiting
fami-
lies from using otherwise available scholarship funds at
religious
schools. 591 U. S., at ___. “A State need not subsidize private
educa-
tion,” the Court concluded, “[b]ut once a State decides to do so,
it can-
not disqualify some private schools solely because they are
religious.”
Id., at ___. Pp. 6–8.
(b) The principles applied in Trinity Lutheran and Espinoza
suffice
to resolve this case. Maine offers its citizens a benefit: tuition
assis-
tance payments for any family whose school district does not
provide
a public secondary school. Just like the wide range of nonprofit
6. organ-
izations eligible to receive playground resurfacing grants in
Trinity
Lutheran, a wide range of private schools are eligible to receive
Maine
tuition assistance payments here. And like the daycare center in
Trin-
ity Lutheran, the religious schools in this case are disqualified
from
this generally available benefit “solely because of their
religious char-
acter.” 582 U. S., at ___. Likewise, in Espinoza, as here, the
Court
considered a state benefit program that provided public funds to
sup-
port tuition payments at private schools and specifically carved
out
private religious schools from those eligible to receive such
funds. Both
that program and this one disqualify certain private schools
from pub-
lic funding “solely because they are religious.” 591 U. S., at
___. A law
that operates in that manner must be subjected to “the strictest
scru-
tiny.” Id., at ___–___.
Maine’s program cannot survive strict scrutiny. A neutral
benefit
program in which public funds flow to religious organizations
through
the independent choices of private benefit recipients does not
offend
the Establishment Clause. See Zelman v. Simmons-Harris, 536
U. S.
639, 652–653. Maine’s decision to continue excluding religious
7. schools
3 Cite as: 596 U. S. ____ (2022)
Syllabus
from its tuition assistance program after Zelman thus promotes
stricter separation of church and state than the Federal
Constitution
requires. But a State’s antiestablishment interest does not
justify en-
actments that exclude some members of the community from an
oth-
erwise generally available public benefit because of their
religious ex-
ercise. Pp. 9–11.
8. (c) The First Circuit’s attempts to recharacterize the nature of
Maine’s tuition assistance program do not suffice to distinguish
this
case from Trinity Lutheran or Espinoza. Pp. 11–18.
(1) The First Circuit held that the “nonsectarian” requirement
was
constitutional because the benefit was properly viewed not as
tuition
payments to be used at approved private schools but instead as
fund-
ing for the “rough equivalent of the public school education that
Maine
may permissibly require to be secular.” 979 F. 3d 21, 44. But
the stat-
ute does not say anything like that. The benefit provided by
statute is
tuition at a public or private school, selected by the parent, with
no
suggestion that the “private school” must somehow provide a
“public”
education. Moreover, the differences between private schools
eligible
to receive tuition assistance under Maine’s program and a
Maine pub-
lic school are numerous and important. To start with, private
schools
do not have to accept all students, while public schools
generally do.
In addition, the free public education that Maine insists it is
providing
through the tuition assistance program is often not free, as some
par-
ticipating private schools charge several times the maximum
benefit
that Maine is willing to provide. And the curriculum taught at
9. partic-
ipating private schools need not even resemble that taught in the
Maine public schools.
The key manner in which participating private schools are
required
to resemble Maine public schools, however, is that they must be
secu-
lar. Maine may provide a strictly secular education in its public
schools. But BCS and Temple Academy—like numerous other
recipi-
ents of Maine tuition assistance payments—are not public
schools.
Maine has chosen to offer tuition assistance that parents may
direct to
the public or private schools of their choice. Maine’s
administration of
that benefit is subject to the free exercise principles governing
any
public benefit program—including the prohibition on denying
the ben-
efit based on a recipient’s religious exercise. Pp. 11–15.
(2) The Court of Appeals also attempted to distinguish this case
from
Trinity Lutheran and Espinoza on the ground that the funding
re-
strictions in those cases were “solely status-based religious
discrimi-
nation,” while the challenged provision here “imposes a use-
based re-
striction.” 979 F. 3d, at 35, 37–38. Trinity Lutheran and
Espinoza
held that the Free Exercise Clause forbids discrimination on the
basis
of religious status. But those decisions never suggested that
10. use-based
4 CARSON v. MAKIN
Syllabus
discrimination is any less offensive to the Free Exercise Clause.
This
case illustrates why. “[E]ducating young people in their faith,
incul-
cating its teachings, and training them to live their faith are
responsi-
bilities that lie at the very core of the mission of a private
religious
school.” Our Lady of Guadalupe School v. Morrissey-Berru,
591 U. S.
___, ___. In short, the prohibition on status-based
discrimination un-
der the Free Exercise Clause is not a permission to engage in
use-
based discrimination.
Locke v. Davey, 540 U. S. 712, does not assist Maine here. The
11. schol-
arship funds at issue in Locke were intended to be used “to
prepare for
the ministry.” Trinity Lutheran, 582 U. S., at ___. Locke’s
reasoning
expressly turned on what it identified as the “historic and
substantial
state interest” against using “taxpayer funds to support church
lead-
ers.” 540 U. S., at 722, 725. But “it is clear that there is no
‘historic
and substantial’ tradition against aiding [private religious]
schools”
that is “comparable.” Espinoza, 591 U. S., at ___. Locke
cannot be read
to generally authorize the State to exclude religious persons
from the
enjoyment of public benefits on the basis of their anticipated
religious
use of the benefits. Pp. 15–18.
979 F. 3d 21, reversed and remanded.
ROBERTS, C. J., delivered the opinion of the Court, in which
THOMAS,
ALITO, GORSUCH, KAVANAUGH, and BARRETT, JJ.,
joined. BREYER, J., filed
a dissenting opinion, in which KAGAN J., joined, and in which
SO-
TOMAYOR, J., joined as to all but Part I–B. SOTOMAYOR, J.,
filed a dissent-
ing opinion.
12. _________________
_________________
1 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
NOTICE: This opinion is subject to formal revision before
publication in the
preliminary print of the United States Reports. Readers are
requested to
notify the Reporter of Decisions, Supreme Court of the United
States, Wash-
ington, D. C. 20543, of any typographical or other formal
errors, in order that
corrections may be made before the preliminary print goes to
press.
SUPREME COURT OF THE UNITED STATES
No. 20–1088
DAVID CARSON, AS PARENT AND NEXT FRIEND OF O. C.,
13. ET AL., PETITIONERS v. A. PENDER MAKIN
ON WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF
APPEALS FOR THE FIRST CIRCUIT
[June 21, 2022]
CHIEF JUSTICE ROBERTS delivered the opinion of the
Court.
Maine has enacted a program of tuition assistance for
parents who live in school districts that do not operate a
secondary school of their own. Under the program, parents
designate the secondary school they would like their child
to attend—public or private—and the school district trans-
mits payments to that school to help defray the costs of tu-
ition. Most private schools are eligible to receive the pay-
ments, so long as they are “nonsectarian.” The question
presented is whether this restriction violates the Free Ex-
ercise Clause of the First Amendment.
I
A
Maine’s Constitution provides that the State’s legislature
shall “require . . . the several towns to make suitable provi-
sion, at their own expense, for the support and maintenance
of public schools.” Me. Const., Art. VIII, pt. 1, §1. In ac-
cordance with that command, the legislature has required
that every school-age child in Maine “shall be provided an
14. 2 CARSON v. MAKIN
Opinion of the Court
opportunity to receive the benefits of a free public educa-
tion,” Me. Rev. Stat. Ann., Tit. 20–A, §2(1) (2008), and that
the required schools be operated by “the legislative and gov-
erning bodies of local school administrative units,” §2(2).
But Maine is the most rural State in the Union, and for
many school districts the realities of remote geography and
low population density make those commands difficult to
heed. Indeed, of Maine’s 260 school administrative units
(SAUs), fewer than half operate a public secondary school
of their own. App. 4, 70, 73.
Maine has sought to deal with this problem in part by
creating a program of tuition assistance for families that
reside in such areas. Under that program, if an SAU nei-
ther operates its own public secondary school nor contracts
with a particular public or private school for the education
of its school-age children, the SAU must “pay the tuition . . .
at the public school or the approved private school of the
parent’s choice at which the student is accepted.” Me. Rev.
Stat. Ann., Tit. 20–A, §5204(4) (Cum. Supp. 2021). Parents
who wish to take advantage of this benefit first select the
15. school they wish their child to attend. Ibid. If they select a
private school that has been “approved” by the Maine De-
partment of Education, the parents’ SAU “shall pay the tu-
ition” at the chosen school up to a specified maximum rate.
See §§2902, 2951, 5204(4).
To be “approved” to receive these payments, a private
school must meet certain basic requirements under Maine’s
compulsory education law. §2951(1). The school must ei-
ther be “[c]urrently accredited by a New England associa-
tion of schools and colleges” or separately “approv[ed] for
attendance purposes” by the Department. §§2901(2), 2902.
Schools seeking approval from the Department must meet
specified curricular requirements, such as using English as
the language of instruction, offering a course in “Maine his-
tory, including the Constitution of Maine . . . and Maine’s
cultural and ethnic heritage,” and maintaining a student-
3 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
teacher ratio of not more than 30 to 1. §§2902(2), 2902(3),
4706(2), 2902(6)(C).
16. The program imposes no geographic limitation: Parents
may direct tuition payments to schools inside or outside the
State, or even in foreign countries. §§2951(3), 5808. In
schools that qualify for the program because they are ac-
credited, teachers need not be certified by the State,
§13003(3), and Maine’s curricular requirements do not ap-
ply, §2901(2). Single-sex schools are eligible. See Me. Rev.
Stat. Ann., Tit. 5, §4553(2–A) (exempting single-sex pri-
vate, but not public, schools from Maine’s antidiscrimina-
tion law).
Prior to 1981, parents could also direct the tuition assis-
tance payments to religious schools. Indeed, in the 1979–
1980 school year, over 200 Maine students opted to attend
such schools through the tuition assistance program. App.
72. In 1981, however, Maine imposed a new requirement
that any school receiving tuition assistance payments must
be “a nonsectarian school in accordance with the First
Amendment of the United States Constitution.” Me. Rev.
Stat. Ann., Tit. 20–A, §2951(2). That provision was enacted
in response to an opinion by the Maine attorney general
taking the position that public funding of private religious
schools violated the Establishment Clause of the First
Amendment. We subsequently held, however, that a bene-
fit program under which private citizens “direct govern-
ment aid to religious schools wholly as a result of their own
genuine and independent private choice” does not offend
the Establishment Clause. Zelman v. Simmons-Harris, 536
U. S. 639, 652 (2002). Following our decision in Zelman,
the Maine Legislature considered a proposed bill to repeal
the “nonsectarian” requirement, but rejected it. App. 100,
108.
The “nonsectarian” requirement for participation in
Maine’s tuition assistance program remains in effect today.
17. 4 CARSON v. MAKIN
Opinion of the Court
The Department has stated that, in administering this re-
quirement, it “considers a sectarian school to be one that is
associated with a particular faith or belief system and
which, in addition to teaching academic subjects, promotes
the faith or belief system with which it is associated and/or
presents the material taught through the lens of this faith.”
979 F. 3d 21, 38 (CA1 2020). “The Department’s focus is on
what the school teaches through its curriculum and related
activities, and how the material is presented.” Ibid. (em-
phasis deleted). “[A]ffiliation or association with a church
or religious institution is one potential indicator of a sec-
tarian school,” but “it is not dispositive.” Ibid.
B
This case concerns two families that live in SAUs that
neither maintain their own secondary schools nor contract
with any nearby secondary school. App. 70, 71. Petitioners
David and Amy Carson reside in Glenburn, Maine. Id., at
18. 74. When this litigation commenced, the Carsons’ daughter
attended high school at Bangor Christian Schools (BCS),
which was founded in 1970 as a ministry of Bangor Baptist
Church. Id., at 74, 80. The Carsons sent their daughter to
BCS because of the school’s high academic standards and
because the school’s Christian worldview aligns with their
sincerely held religious beliefs. Id., at 74. Given that BCS
is a “sectarian” school that cannot qualify for tuition assis-
tance payments under Maine’s program, id., at 80, the Car-
sons paid the tuition for their daughter to attend BCS
themselves, id., at 74.
Petitioners Troy and Angela Nelson live in Palermo,
Maine. Id., at 78. When this litigation commenced, the
Nelsons’ daughter attended high school at Erskine Acad-
emy, a secular private school, and their son attended mid-
dle school at Temple Academy, a “sectarian” school affili-
ated with Centerpoint Community Church. Id., at 78, 90,
91. The Nelsons sent their son to Temple Academy because
5 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
19. they believed it offered him a high-quality education that
aligned with their sincerely held religious beliefs. Id., at
78. While they wished to send their daughter to Temple
Academy too, they could not afford to pay the cost of the
Academy’s tuition for both of their children. Id., at 79.
BCS and Temple Academy are both accredited by the
New England Association of Schools and Colleges (NEASC),
and the Department considers each school a “private school
approved for attendance purposes” under the State’s com-
pulsory attendance requirement. Id., at 80, 90. Yet because
neither school qualifies as “nonsectarian,” neither is eligible
to receive tuition payments under Maine’s tuition assis-
tance program. Id., at 80, 90. Absent the “nonsectarian”
requirement, the Carsons and the Nelsons would have
asked their respective SAUs to pay the tuition to send their
children to BCS and Temple Academy, respectively. Id., at
79.
In 2018, petitioners brought suit against the commis-
sioner of the Maine Department of Education. Id., at 11–
12. They alleged that the “nonsectarian” requirement of
Maine’s tuition assistance program violated the Free Exer-
cise Clause and the Establishment Clause of the First
Amendment, id., at 23–27, as well as the Equal Protection
Clause of the Fourteenth Amendment, id., at 29–30. Their
complaint sought declaratory and injunctive relief against
enforcement of the requirement. Id., at 31–32. The parties
filed cross-motions for summary judgment on a stipulated
record. 401 F. Supp. 3d 207, 208 (Me. 2019). Applying Cir-
cuit precedent that had previously upheld the “nonsec-
tarian” requirement against challenge, see Eulitt v. Maine
Dept. of Ed., 386 F. 3d 344 (CA1 2004), the District Court
rejected petitioners’ constitutional claims and granted judg-
ment to the commissioner. 401 F. Supp. 3d, at 209–212.
20. While petitioners’ appeal to the First Circuit was pend-
ing, this Court decided Espinoza v. Montana Department of
6 CARSON v. MAKIN
Opinion of the Court
Revenue, 591 U. S. ___ (2020). Espinoza held that a provi-
sion of the Montana Constitution barring government aid
to any school “controlled in whole or in part by any church,
sect, or denomination,” Art. X, §6(1), violated the Free Ex-
ercise Clause by prohibiting families from using otherwise
available scholarship funds at the religious schools of their
choosing. The First Circuit recognized that, in light of Es-
pinoza, its prior precedent upholding Maine’s “nonsec-
tarian” requirement was no longer controlling. 979 F. 3d,
at 32–36. But it nevertheless affirmed the District Court’s
grant of judgment to the commissioner. Id., at 49.
As relevant here, the First Circuit offered two grounds to
distinguish Maine’s “nonsectarian” requirement from the
no-aid provision at issue in Espinoza. First, the panel rea-
21. soned that, whereas Montana had barred schools from re-
ceiving funding “simply based on their religious identity—
a status that in and of itself does not determine how a school
would use the funds”—Maine bars BCS and Temple Acad-
emy from receiving funding “based on the religious use that
they would make of it in instructing children.” 979 F. 3d,
at 40. Second, the panel determined that Maine’s tuition
assistance program was distinct from the scholarships at
issue in Espinoza because Maine had sought to provide “a
rough equivalent of the public school education that Maine
may permissibly require to be secular but that is not other-
wise accessible.” 979 F. 3d, at 44. Thus, “the nature of the
restriction at issue and the nature of the school aid program
of which it is a key part” led the panel to conclude “once
again” that Maine’s “nonsectarian” requirement did not vi-
olate the Free Exercise Clause. Id., at 46.
We granted certiorari. 594 U. S. ___ (2021).
II
A
The Free Exercise Clause of the First Amendment pro-
22. 7 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
tects against “indirect coercion or penalties on the free ex-
ercise of religion, not just outright prohibitions.” Lyng v.
Northwest Indian Cemetery Protective Assn., 485 U. S. 439,
450 (1988). In particular, we have repeatedly held that a
State violates the Free Exercise Clause when it excludes
religious observers from otherwise available public bene-
fits. See Sherbert v. Verner, 374 U. S. 398, 404 (1963) (“It
is too late in the day to doubt that the liberties of religion
and expression may be infringed by the denial of or placing
of conditions upon a benefit or privilege.”); see also Everson
v. Board of Ed. of Ewing, 330 U. S. 1, 16 (1947) (a State
“cannot exclude” individuals “because of their faith, or lack
of it, from receiving the benefits of public welfare legisla-
tion”). A State may not withhold unemployment benefits,
for instance, on the ground that an individual lost his job
for refusing to abandon the dictates of his faith. See Sher-
bert, 374 U. S., at 399–402 (Seventh-day Adventist who re-
fused to work on the Sabbath); Thomas v. Review Bd. of Ind.
Employment Security Div., 450 U. S. 707, 709, 720 (1981)
(Jehovah’s Witness who refused to participate in the pro-
duction of armaments).
We have recently applied these principles in the context
of two state efforts to withhold otherwise available public
benefits from religious organizations. In Trinity Lutheran
Church of Columbia, Inc. v. Comer, 582 U. S. ___ (2017), we
considered a Missouri program that offered grants to qual-
ifying nonprofit organizations that installed cushioning
playground surfaces made from recycled rubber tires. The
Missouri Department of Natural Resources maintained an
23. express policy of denying such grants to any applicant
owned or controlled by a church, sect, or other religious en-
tity. The Trinity Lutheran Church Child Learning Center
applied for a grant to resurface its gravel playground, but
the Department denied funding on the ground that the Cen-
ter was operated by the Church.
8 CARSON v. MAKIN
Opinion of the Court
We deemed it “unremarkable in light of our prior deci-
sions” to conclude that the Free Exercise Clause did not per-
mit Missouri to “expressly discriminate[] against otherwise
eligible recipients by disqualifying them from a public ben-
efit solely because of their religious character.” Id., at ___–
___ (slip op., at 9–10). While it was true that Trinity Lu-
theran remained “free to continue operating as a church,” it
could enjoy that freedom only “at the cost of automatic and
absolute exclusion from the benefits of a public program for
which the Center [was] otherwise fully qualified.” Id., at
___ (slip op., at 10) (citing McDaniel v. Paty, 435 U. S. 618,
24. 626 (1978) (plurality opinion)). Such discrimination, we
said, was “odious to our Constitution” and could not stand.
582 U. S., at ___ (slip op., at 15).
Two Terms ago, in Espinoza, we reached the same con-
clusion as to a Montana program that provided tax credits
to donors who sponsored scholarships for private school tu-
ition. The Montana Supreme Court held that the program,
to the extent it included religious schools, violated a provi-
sion of the Montana Constitution that barred government
aid to any school controlled in whole or in part by a church,
sect, or denomination. As a result of that holding, the State
terminated the scholarship program, preventing the peti-
tioners from accessing scholarship funds they otherwise
would have used to fund their children’s educations at reli-
gious schools.
We again held that the Free Exercise Clause forbade the
State’s action. The application of the Montana Constitu-
tion’s no-aid provision, we explained, required strict scru-
tiny because it “bar[red] religious schools from public bene-
fits solely because of the religious character of the schools.”
Espinoza, 591 U. S., at ___ (slip op., at 9). “A State need not
subsidize private education,” we concluded, “[b]ut once a
State decides to do so, it cannot disqualify some private
schools solely because they are religious.” Id., at ___ (slip
op., at 20).
25. 9 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
B
The “unremarkable” principles applied in Trinity Lu-
theran and Espinoza suffice to resolve this case. Maine of-
fers its citizens a benefit: tuition assistance payments for
any family whose school district does not provide a public
secondary school. Just like the wide range of nonprofit or-
ganizations eligible to receive playground resurfacing
grants in Trinity Lutheran, a wide range of private schools
are eligible to receive Maine tuition assistance payments
here. And like the daycare center in Trinity Lutheran, BCS
and Temple Academy are disqualified from this generally
available benefit “solely because of their religious charac-
ter.” 582 U. S., at ___ (slip op., at 10). By “condition[ing]
the availability of benefits” in that manner, Maine’s tuition
assistance program—like the program in Trinity Lu-
theran—“effectively penalizes the free exercise” of religion.
Ibid. (quoting McDaniel, 435 U. S., at 626 (plurality opin-
ion)).
Our recent decision in Espinoza applied these basic prin-
ciples in the context of religious education that we consider
today. There, as here, we considered a state benefit pro-
gram under which public funds flowed to support tuition
payments at private schools. And there, as here, that pro-
gram specifically carved out private religious schools from
those eligible to receive such funds. While the wording of
26. the Montana and Maine provisions is different, their effect
is the same: to “disqualify some private schools” from fund-
ing “solely because they are religious.” 591 U. S., at ___
(slip op., at 20). A law that operates in that manner, we
held in Espinoza, must be subjected to “the strictest scru-
tiny.” Id., at ___–___ (slip op., at 11–12).
To satisfy strict scrutiny, government action “must ad-
vance ‘interests of the highest order’ and must be narrowly
tailored in pursuit of those interests.” Church of Lukumi
Babalu Aye, Inc. v. Hialeah, 508 U. S. 520, 546 (1993) (quot-
ing McDaniel, 435 U. S., at 628 (plurality opinion)). “A law
10 CARSON v. MAKIN
Opinion of the Court
that targets religious conduct for distinctive treatment . . .
will survive strict scrutiny only in rare cases.” 508 U. S., at
546.
This is not one of them. As noted, a neutral benefit pro-
27. gram in which public funds flow to religious organizations
through the independent choices of private benefit recipi-
ents does not offend the Establishment Clause. See Zel-
man, 536 U. S., at 652–653. Maine’s decision to continue
excluding religious schools from its tuition assistance pro-
gram after Zelman thus promotes stricter separation of
church and state than the Federal Constitution requires.
See also post, at 4 (BREYER, J., dissenting) (States may
choose “not to fund certain religious activity . . . even when
the Establishment Clause does not itself prohibit the State
from funding that activity”); post, at 1 (SOTOMAYOR, J., dis-
senting) (same point).
But as we explained in both Trinity Lutheran and Espi-
noza, such an “interest in separating church and state ‘more
fiercely’ than the Federal Constitution . . . ‘cannot qualify
as compelling’ in the face of the infringement of free exer-
cise.” Espinoza, 591 U. S., at ___ (slip op., at 18) (quoting
Trinity Lutheran, 582 U. S., at ___ (slip op., at 14)); see also
Widmar v. Vincent, 454 U. S. 263, 276 (1981) (“[T]he state
interest . . . in achieving greater separation of church and
State than is already ensured under the Establishment
Clause . . . is limited by the Free Exercise Clause.”).
JUSTICE BREYER stresses the importance of “government
neutrality” when it comes to religious matters, post, at 13,
but there is nothing neutral about Maine’s program. The
State pays tuition for certain students at private schools—
so long as the schools are not religious. That is discrimina-
tion against religion. A State’s antiestablishment interest
does not justify enactments that exclude some members of
28. 11 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
the community from an otherwise generally available pub-
lic benefit because of their religious exercise.*
III
The First Circuit attempted to distinguish our precedent
by recharacterizing the nature of Maine’s tuition assistance
program in two ways, both of which Maine echoes before
this Court. First, the panel defined the benefit at issue as
the “rough equivalent of [a Maine] public school education,”
an education that cannot include sectarian instruction. 979
F. 3d, at 44; see also Brief for Respondent 22. Second, the
panel defined the nature of the exclusion as one based not
on a school’s religious “status,” as in Trinity Lutheran and
Espinoza, but on religious “uses” of public funds. 979 F. 3d,
at 38–40; see also Brief for Respondent 35. Neither of these
formal distinctions suffices to distinguish this case from
Trinity Lutheran or Espinoza, or to affect the application of
the free exercise principles outlined above.
A
The First Circuit held that the “nonsectarian” require-
29. ment was constitutional because the benefit was properly
viewed not as tuition assistance payments to be used at ap-
proved private schools, but instead as funding for the
“rough equivalent of the public school education that Maine
may permissibly require to be secular.” 979 F. 3d, at 44. As
Maine puts it, “[t]he public benefit Maine is offering is a
free public education.” Brief for Respondent 1–2.
To start with, the statute does not say anything like that.
It says that an SAU without a secondary school of its own
——————
*Both dissents articulate a number of other reasons not to
extend the
tuition assistance program to BCS and Temple Academy, based
on the
schools’ particular policies and practices. Post, at 15–16
(opinion of
BREYER, J.); post, at 4 (opinion of SOTOMAYOR, J.). Maine
rightly does not
attempt to defend its law on such grounds, however, because the
law rig-
idly excludes any and all sectarian schools regardless of
particular char-
acteristics. See supra, at 3.
30. 12 CARSON v. MAKIN
Opinion of the Court
“shall pay the tuition . . . at the public school or the ap-
proved private school of the parent’s choice at which the
student is accepted.” Me. Rev. Stat. Ann., Tit. 20–A,
§5204(4). The benefit is tuition at a public or private school,
selected by the parent, with no suggestion that the “private
school” must somehow provide a “public” education.
This reading of the statute is confirmed by the program’s
operation. The differences between private schools eligible
to receive tuition assistance under Maine’s program and a
Maine public school are numerous and important. To start
with the most obvious, private schools are different by def-
inition because they do not have to accept all students. Pub-
lic schools generally do. Second, the free public education
that Maine insists it is providing through the tuition assis-
tance program is often not free. That “assistance” is avail-
able at private schools that charge several times the maxi-
mum benefit that Maine is willing to provide. See
Stipulated Record, Exh. 2, in No. 1:18–cv–327 (Me., Mar.
12, 2019), ECF Doc. 24–2, p. 11; Brief for Respondent 32.
Moreover, the curriculum taught at participating private
schools need not even resemble that taught in the Maine
public schools. For example, Maine public schools must
abide by certain “parameters for essential instruction in
English language arts; mathematics; science and technol-
ogy; social studies; career and education development; vis-
ual and performing arts; health, physical education and
wellness; and world languages.” §6209. But NEASC-
accredited private schools are exempt from these require-
31. ments, and instead subject only to general “standards and
indicators” governing the implementation of their own cho-
sen curriculum. Brief for Respondent 32; see NEASC,
Standards—20/20 Process (rev. Aug. 2021), https://cis.
neasc.org/standards2020 (requiring, for instance, that
“[c]urriculum planning supports the school’s core beliefs
and the needs of the students,” and that the “[w]ritten cur-
riculum aligns horizontally and vertically”).
13 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
Private schools approved by the Department (rather than
accredited by NEASC) are likewise exempt from many of
the State’s curricular requirements, so long as fewer than
60% of their students receive tuition assistance from the
State. For instance, such schools need not abide by Maine’s
“comprehensive, statewide system of learning results,” in-
cluding the “parameters for essential instruction” refer-
32. enced above, and they need not administer the annual state
assessments in English language arts, mathematics, and
science. §§2951(6), 6209; see also ECF Doc. 24–2, at 9.
There are other distinctions, too. Participating schools
need not hire state-certified teachers. Compare Me. Rev.
Stat. Ann., Tit. 20–A, §13003(1), with §13003(3). And the
schools can be single-sex. See ECF Doc. 24–2, at 11. In
short, it is simply not the case that these schools, to be eli-
gible for state funds, must offer an education that is equiv-
alent—roughly or otherwise—to that available in the Maine
public schools.
But the key manner in which the two educational experi-
ences are required to be “equivalent” is that they must both
be secular. Saying that Maine offers a benefit limited to
private secular education is just another way of saying that
Maine does not extend tuition assistance payments to par-
ents who choose to educate their children at religious
schools. But “the definition of a particular program can al-
ways be manipulated to subsume the challenged condition,”
and to allow States to “recast a condition on funding” in this
manner would be to see “the First Amendment . . . reduced
to a simple semantic exercise.” Agency for Int’l Development
v. Alliance for Open Society Int’l, Inc., 570 U. S. 205, 215
(2013) (quoting Legal Services Corporation v. Velazquez,
531 U. S. 533, 547 (2001)); see also Walz v. Tax Comm’n of
City of New York, 397 U. S. 664, 696 (1970) (Harlan, J., con-
curring) (“The Court must survey meticulously the circum-
stances of governmental categories to eliminate, as it were,
religious gerrymanders.”). Maine’s formulation does not
33. 14 CARSON v. MAKIN
Opinion of the Court
answer the question in this case; it simply restates it.
Indeed, were we to accept Maine’s argument, our decision
in Espinoza would be rendered essentially meaningless. By
Maine’s logic, Montana could have obtained the same result
that we held violated the First Amendment simply by rede-
fining its tax credit for sponsors of generally available schol-
arships as limited to “tuition payments for the rough equiv-
alent of a Montana public education”—meaning a secular
education. But our holding in Espinoza turned on the sub-
stance of free exercise protections, not on the presence or
absence of magic words. That holding applies fully whether
the prohibited discrimination is in an express provision like
§2951(2) or in a party’s reconceptualization of the public
benefit.
Maine may provide a strictly secular education in its pub-
lic schools. But BCS and Temple Academy—like numerous
other recipients of Maine tuition assistance payments—are
not public schools. In order to provide an education to chil-
dren who live in certain parts of its far-flung State, Maine
has decided not to operate schools of its own, but instead to
offer tuition assistance that parents may direct to the public
or private schools of their choice. Maine’s administration of
that benefit is subject to the free exercise principles govern-
34. ing any such public benefit program—including the prohi-
bition on denying the benefit based on a recipient’s religious
exercise.
The dissents are wrong to say that under our decision to-
day Maine “must” fund religious education. Post, at 7
(BREYER, J., dissenting). Maine chose to allow some par-
ents to direct state tuition payments to private schools; that
decision was not “forced upon” it. Post, at 4 (SOTOMAYOR,
J., dissenting). The State retains a number of options: it
could expand the reach of its public school system, increase
the availability of transportation, provide some combina-
tion of tutoring, remote learning, and partial attendance, or
15 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
even operate boarding schools of its own. As we held in Es-
pinoza, a “State need not subsidize private education. But
once a State decides to do so, it cannot disqualify some pri-
vate schools solely because they are religious.” 591 U. S.,
35. at ___ (slip op., at 20).
B
The Court of Appeals also attempted to distinguish this
case from Trinity Lutheran and Espinoza on the ground
that the funding restrictions in those cases were “solely sta-
tus-based religious discrimination,” while the challenged
provision here “imposes a use-based restriction.” 979 F. 3d,
at 35, 37–38. JUSTICE BREYER makes the same argument.
Post, at 8–9, 13–14 (dissenting opinion).
In Trinity Lutheran, the Missouri Constitution banned
the use of public funds in aid of “any church, sect or denom-
ination of religion.” 582 U. S., at ___–___ (slip op., at 2–3).
We noted that the case involved “express discrimination
based on religious identity,” which was sufficient unto the
day in deciding it, and that our opinion did “not address re-
ligious uses of funding.” Id., at ___, n. 3 (plurality opinion)
(slip op., at 14, n. 3).
So too in Espinoza, the discrimination at issue was de-
scribed by the Montana Supreme Court as a prohibition on
aiding “schools controlled by churches,” and we analyzed
the issue in terms of “religious status and not religious use.”
591 U. S., at ___ (slip op., at 10). Foreshadowing Maine’s
argument here, Montana argued that its case was different
from Trinity Lutheran’s because it involved not playground
resurfacing, but general funds that “could be used for reli-
gious ends by some recipients, particularly schools that be-
lieve faith should ‘permeate[]’ everything they do.” Id., at
___ (slip op., at 11). We explained, however, that the strict
scrutiny triggered by status-based discrimination could not
be avoided by arguing that “one of its goals or effects [was]
36. 16 CARSON v. MAKIN
Opinion of the Court
preventing religious organizations from putting aid to reli-
gious uses.” Ibid. (emphasis added). And we noted that
nothing in our analysis was “meant to suggest that we
agree[d] with [Montana] that some lesser degree of scrutiny
applies to discrimination against religious uses of govern-
ment aid.” Id., at ___ (slip op., at 12).
Maine’s argument, however—along with the decision be-
low and JUSTICE BREYER’s dissent—is premised on pre-
cisely such a distinction. See Brief for Respondent 44
(“Maine has not broadly excluded private schools simply be-
cause they are affiliated with or controlled by a religious
organization. Rather, a school is excluded only if it pro-
motes a particular faith and presents academic material
through the lens of that faith.”); 979 F. 3d, at 40 (Maine pro-
vision “does not bar schools from receiving funding simply
based on their religious identity” but instead “based on the
religious use that they would make of it in instructing chil-
dren.”); post, at 9 (BREYER, J., dissenting) (“[U]nlike the cir-
cumstances present in Trinity Lutheran and Espinoza, it is
37. religious activity, not religious labels, that lies at the heart
of this case.”).
That premise, however, misreads our precedents. In
Trinity Lutheran and Espinoza, we held that the Free Ex-
ercise Clause forbids discrimination on the basis of religious
status. But those decisions never suggested that use-based
discrimination is any less offensive to the Free Exercise
Clause. This case illustrates why. “[E]ducating young peo-
ple in their faith, inculcating its teachings, and training
them to live their faith are responsibilities that lie at the
very core of the mission of a private religious school.” Our
Lady of Guadalupe School v. Morrissey-Berru, 591 U. S.
___, ___ (2020) (slip op., at 18); see also Hosanna-Tabor
Evangelical Lutheran Church and School v. EEOC, 565
U. S. 171, 192 (2012).
Any attempt to give effect to such a distinction by scruti-
17 Cite as: 596 U. S. ____ (2022)
Opinion of the Court
38. nizing whether and how a religious school pursues its edu-
cational mission would also raise serious concerns about
state entanglement with religion and denominational fa-
voritism. See Our Lady, 591 U. S., at ___ (slip op., at 26);
Larson v. Valente, 456 U. S. 228, 244 (1982). Indeed, Maine
concedes that the Department barely engages in any such
scrutiny when enforcing the “nonsectarian” requirement.
See Brief for Respondent 5 (asserting that there will be no
need to probe private schools’ uses of tuition assistance
funds because “schools self-identify as nonsectarian” under
the program and the need for any further questioning is
“extremely rare”). That suggests that any status-use dis-
tinction lacks a meaningful application not only in theory,
but in practice as well. In short, the prohibition on status-
based discrimination under the Free Exercise Clause is not
a permission to engage in use-based discrimination.
Maine and the dissents invoke Locke v. Davey, 540 U. S.
712 (2004), in support of the argument that the State may
preclude parents from designating a religious school to re-
ceive tuition assistance payments. In that case, Washing-
ton had established a scholarship fund to assist academi-
cally gifted students with postsecondary education
expenses. But the program excluded one particular use of
the scholarship funds: the “essentially religious endeavor”
of pursuing a degree designed to “train[] a minister to lead
a congregation.” Id., at 721; Espinoza, 591 U. S., at ___ (slip
op., at 13). We upheld that restriction against a free exer-
cise challenge, reasoning that the State had “merely chosen
not to fund a distinct category of instruction.” Locke, 540
U. S., at 721.
Our opinions in Trinity Lutheran and Espinoza, however,
have already explained why Locke can be of no help to
Maine here. Both precedents emphasized, as did Locke it-
self, that the funding in Locke was intended to be used “to
39. prepare for the ministry.” Trinity Lutheran, 582 U. S., at
___ (slip op., at 12); see also Espinoza, 591 U. S., at ___ (slip
18 CARSON v. MAKIN
Opinion of the Court
op., at 13); Locke, 540 U. S., at 725. Funds could be and
were used for theology courses; only pursuing a “vocational
religious” degree was excluded. Ibid.; see also Trinity Lu-
theran, 582 U. S., at ___–___ (slip op., at 12–13) (explaining
narrow reach of Locke); Espinoza, 591 U. S., at ___–___ (slip
op., at 13–14) (same).
Locke’s reasoning expressly turned on what it identified
as the “historic and substantial state interest” against us-
ing “taxpayer funds to support church leaders.” 540 U. S.,
at 722, 725. But as we explained at length in Espinoza, “it
is clear that there is no ‘historic and substantial’ tradition
against aiding [private religious] schools comparable to the
tradition against state-supported clergy invoked by Locke.”
591 U. S., at ___ (slip op., at 16). Locke cannot be read be-
yond its narrow focus on vocational religious degrees to gen-
erally authorize the State to exclude religious persons from
the enjoyment of public benefits on the basis of their antic-
40. ipated religious use of the benefits.
* * *
Maine’s “nonsectarian” requirement for its otherwise
generally available tuition assistance payments violates
the Free Exercise Clause of the First Amendment. Regard-
less of how the benefit and restriction are described, the
program operates to identify and exclude otherwise eligible
schools on the basis of their religious exercise. The judg-
ment of the Court of Appeals is reversed, and the case is
remanded for further proceedings consistent with this opin-
ion.
It is so ordered.
_________________
_________________
1 Cite as: 596 U. S. ____ (2022)
41. BREYER, J., dissenting
SUPREME COURT OF THE UNITED STATES
No. 20–1088
DAVID CARSON, AS PARENT AND NEXT FRIEND OF O. C.,
ET AL., PETITIONERS v. A. PENDER MAKIN
ON WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF
APPEALS FOR THE FIRST CIRCUIT
[June 21, 2022]
JUSTICE BREYER, with whom JUSTICE KAGAN joins, and
with whom JUSTICE SOTOMAYOR joins except as to Part I–
B, dissenting.
The First Amendment begins by forbidding the govern-
ment from “mak[ing] [any] law respecting an establishment
of religion.” It next forbids them to make any law “prohib-
iting the free exercise thereof.” The Court today pays al-
most no attention to the words in the first Clause while giv-
ing almost exclusive attention to the words in the second.
The majority also fails to recognize the “ ‘play in the joints’ ”
between the two Clauses. See Trinity Lutheran Church of
Columbia, Inc. v. Comer, 582 U. S. ___, ___ (2017) (slip op.,
at 6). That “play” gives States some degree of legislative
leeway. It sometimes allows a State to further antiestab-
lishment interests by withholding aid from religious insti-
tutions without violating the Constitution’s protections for
the free exercise of religion. In my view, Maine’s nonsec-
tarian requirement falls squarely within the scope of that
constitutional leeway. I respectfully dissent.
42. I
A
The First Amendment’s two Religion Clauses together
provide that the government “shall make no law respecting
an establishment of religion, or prohibiting the free exercise
2 CARSON v. MAKIN
BREYER, J., dissenting
thereof.” Each Clause, linguistically speaking, is “cast in
absolute terms.” Walz v. Tax Comm’n of City of New York,
397 U. S. 664, 668 (1970). The first Clause, the Establish-
ment Clause, seems to bar all government “sponsorship, fi-
nancial support, [or] active involvement . . . in religious ac-
tivity,” while the second Clause, the Free Exercise Clause,
seems to bar all “governmental restraint on religious prac-
tice.” Id., at 668, 670. The apparently absolutist nature of
these two prohibitions means that either Clause, “if ex-
panded to a logical extreme, would tend to clash with the
other.” Id., at 668–669. Because of this, we have said, the
two Clauses “are frequently in tension,” Locke v. Davey,
540 U. S. 712, 718 (2004), and “often exert conflicting pres-
43. sures” on government action, Cutter v. Wilkinson, 544 U. S.
709, 719 (2005).
On the one hand, the Free Exercise Clause “ ‘protect[s]
religious observers against unequal treatment.’ ” Trinity
Lutheran, 582 U. S., at ___ (slip op., at 6) (quoting Church
of Lukumi Babalu Aye, Inc. v. Hialeah, 508 U. S. 520, 542
(1993); alteration in original). We have said that, in the
education context, this means that States generally cannot
“ba[r] religious schools from public benefits solely because
of the religious character of the schools.” Espinoza v. Mon-
tana Dept. of Revenue, 591 U. S. ___, ___ (2020) (slip op., at
9); see Trinity Lutheran, 582 U. S., at ___–___ (slip op., at
9–10).
On the other hand, the Establishment Clause “commands
a separation of church and state.” Cutter, 544 U. S., at 719.
A State cannot act to “aid one religion, aid all religions, or
prefer one religion over another.” Everson v. Board of Ed.
of Ewing, 330 U. S. 1, 15 (1947). This means that a State
cannot use “its public school system to aid any or all reli-
gious faiths or sects in the dissemination of their doctrines
and ideals.” Illinois ex rel. McCollum v. Board of Ed. of
School Dist. No. 71, Champaign Cty., 333 U. S. 203, 211
(1948). Nor may a State “adopt programs or practices in its
44. 3 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
public schools . . . which ‘aid or oppose’ any religion.” Ep-
person v. Arkansas, 393 U. S. 97, 106 (1968). “This prohibi-
tion,” we have cautioned, “is absolute.” Ibid. See, e.g.,
McCollum, 333 U. S. 203 (no weekly religious teachings in
public schools); Engel v. Vitale, 370 U. S. 421 (1962) (no
prayers in public schools); School Dist. of Abington Town-
ship v. Schempp, 374 U. S. 203 (1963) (no Bible readings in
public schools); Epperson, 393 U. S. 97 (no religiously tai-
lored curriculum in public schools); Wallace v. Jaffree, 472
U. S. 38 (1985) (no period of silence for meditation or prayer
in public schools); Lee v. Weisman, 505 U. S. 577 (1992) (no
prayers during public school graduations); Santa Fe Inde-
pendent School Dist. v. Doe, 530 U. S. 290 (2000) (no pray-
ers during public school football games).
Although the Religion Clauses are, in practice, often in
tension, they nonetheless “express complementary values.”
Cutter, 544 U. S., at 719. Together they attempt to chart a
“course of constitutional neutrality” with respect to govern-
ment and religion. Walz, 397 U. S., at 669. They were writ-
ten to help create an American Nation free of the religious
conflict that had long plagued European nations with “gov-
ernmentally established religion[s].” Engel, 370 U. S., at
431. Through the Clauses, the Framers sought to avoid the
“anguish, hardship and bitter strife” that resulted from the
“union of Church and State” in those countries. Id., at 429;
45. see also Committee for Public Ed. & Religious Liberty v.
Nyquist, 413 U. S. 756, 795–796 (1973).
The Religion Clauses thus created a compromise in the
form of religious freedom. They aspired to create a “benev-
olent neutrality”—one which would “permit religious exer-
cise to exist without sponsorship and without interference.”
Walz, 397 U. S., at 669. “[T]he basic purpose of these pro-
visions” was “to insure that no religion be sponsored or fa-
vored, none commanded, and none inhibited.” Ibid. This
religious freedom in effect meant that people “were entitled
4 CARSON v. MAKIN
BREYER, J., dissenting
to worship God in their own way and to teach their chil-
dren” in that way. C. Radcliffe, The Law & Its Compass 71
(1960). We have historically interpreted the Religion
Clauses with these basic principles in mind. See, e.g.,
Nyquist, 413 U. S., at 771–772, 794–796; Walz, 397 U. S., at
668–670; Engel, 370 U. S., at 429–432.
46. And in applying these Clauses, we have often said that
“there is room for play in the joints” between them. Walz,
397 U. S., at 669; see, e.g., Norwood v. Harrison, 413 U. S.
455, 469 (1973); Cutter, 544 U. S., at 719; Locke, 540 U. S.,
at 718–719; Trinity Lutheran, 582 U. S., at ___ (slip op., at
6); Espinoza, 591 U. S., at ___ (slip op., at 6). This doctrine
reflects the fact that it may be difficult to determine in any
particular case whether the Free Exercise Clause requires
a State to fund the activities of a religious institution, or
whether the Establishment Clause prohibits the State from
doing so. Rather than attempting to draw a highly reticu-
lated and complex free-exercise/establishment line that
varies based on the specific circumstances of each state-
funded program, we have provided general interpretive
principles that apply uniformly in all Religion Clause cases.
At the same time, we have made clear that States enjoy a
degree of freedom to navigate the Clauses’ competing pro-
hibitions. See, e.g., Cutter, 544 U. S., at 713, 719–720. This
includes choosing not to fund certain religious activity
where States have strong, establishment-related reasons
for not doing so. See, e.g., Locke, 540 U. S., at 719–722.
And, States have freedom to make this choice even when
the Establishment Clause does not itself prohibit the State
from funding that activity. Id., at 719 (“[T]here are some
state actions permitted by the Establishment Clause but
not required by the Free Exercise Clause”). The Court to-
day nowhere mentions, and I fear effectively abandons, this
longstanding doctrine.
47. 5 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
B
I have previously discussed my views of the relationship
between the Religion Clauses and how I believe these
Clauses should be interpreted to advance their goal of
avoiding religious strife. See, e.g., Espinoza, 591 U. S., at
___–___ (dissenting opinion) (slip op., at 13–20); Van Orden
v. Perry, 545 U. S. 677, 698–705 (2005) (opinion concurring
in judgment); Zelman v. Simmons-Harris, 536 U. S. 639,
717–729 (2002) (dissenting opinion). Here I simply note the
increased risk of religiously based social conflict when gov-
ernment promotes religion in its public school system.
“[T]he prescription of prayer and Bible reading in the public
schools, during and as part of the curricular day, involving
young impressionable children whose school attendance is
statutorily compelled,” can “give rise to those very divisive
influences and inhibitions of freedom which both religion
clauses of the First Amendment” sought to prevent.
Schempp, 374 U. S., at 307 (Goldberg, J., concurring).
This potential for religious strife is still with us. We are
today a Nation with well over 100 different religious
groups, from Free Will Baptist to African Methodist, Bud-
48. dhist to Humanist. See Pew Research Center, America’s
Changing Religious Landscape 21 (May 12, 2015). People
in our country adhere to a vast array of beliefs, ideals, and
philosophies. And with greater religious diversity comes
greater risk of religiously based strife, conflict, and social
division. The Religion Clauses were written in part to help
avoid that disunion. As Thomas Jefferson, one of the lead-
ing drafters and proponents of those Clauses, wrote, “ ‘to
compel a man to furnish contributions of money for the
propagation of opinions which he disbelieves, is sinful and
tyrannical.’ ” Everson, 330 U. S., at 13. And as James Mad-
ison, another drafter and proponent, said, compelled tax-
payer sponsorship of religion “is itself a signal of persecu-
tion,” which “will destroy that moderation and harmony
6 CARSON v. MAKIN
BREYER, J., dissenting
which the forbearance of our laws to intermeddle with Re-
ligion, has produced amongst its several sects.” Id., at 68–
49. 69 (appendix to dissenting opinion of Rutledge, J.). To in-
terpret the Clauses with these concerns in mind may help
to further their original purpose of avoiding religious-based
division.
I have also previously explained why I believe that a
“rigid, bright-line” approach to the Religion Clauses—an
approach without any leeway or “play in the joints”—will
too often work against the Clauses’ underlying purposes.
Espinoza, 591 U. S., at ___ (dissenting opinion) (slip op., at
18); see also Van Orden, 545 U. S., at 669–700 (opinion con-
curring in judgment). “[G]overnment benefits come in
many shapes and sizes.” Espinoza, 591 U. S., at ___ (slip
op., at 16) (dissenting opinion). Not all state-funded pro-
grams that have religious restrictions carry the same risk
of creating social division and conflict. In my view, that risk
can best be understood by considering the particular benefit
at issue, along with the reasons for the particular religious
restriction at issue. See ibid.; Trinity Lutheran, 582 U. S.,
at ___ (slip op., at 1) (BREYER, J., concurring in judgment).
Recognition that States enjoy a degree of constitutional lee-
way allows States to enact laws sensitive to local circum-
stances while also allowing this Court to consider those cir-
cumstances in light of the basic values underlying the
Religion Clauses.
In a word, to interpret the two Clauses as if they were
joined at the hip will work against their basic purpose: to
allow for an American society with practitioners of over 100
different religions, and those who do not practice religion at
all, to live together without serious risk of religion-based
social divisions.
II
The majority believes that the principles set forth in this
50. Court’s earlier cases easily resolve this case. But they do
7 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
not.
We have previously found, as the majority points out,
that “a neutral benefit program in which public funds flow
to religious organizations through the independent choices
of private benefit recipients does not offend the Establish-
ment Clause.” Ante, at 10 (citing Zelman, 536 U. S., at 652–
653). We have thus concluded that a State may, consistent
with the Establishment Clause, provide funding to religious
schools through a general public funding program if the
“government aid . . . reach[es] religious institutions only by
way of the deliberate choices of . . . individual [aid] recipi-
ents.” Id., at 652.
51. But the key word is “may.” We have never previously
held what the Court holds today, namely, that a State must
(not may) use state funds to pay for religious education as
part of a tuition program designed to ensure the provision
of free statewide public school education.
What happens once “may” becomes “must”? Does that
transformation mean that a school district that pays for
public schools must pay equivalent funds to parents who
wish to send their children to religious schools? Does it
mean that school districts that give vouchers for use at
charter schools must pay equivalent funds to parents who
wish to give their children a religious education? What
other social benefits are there the State’s provision of which
means—under the majority’s interpretation of the Free Ex-
ercise Clause—that the State must pay parents for the re-
ligious equivalent of the secular benefit provided? The con-
cept of “play in the joints” means that courts need not, and
should not, answer with “must” these questions that can
more appropriately be answered with “may.”
The majority also asserts that “[t]he ‘unremarkable’ prin-
ciples applied in Trinity Lutheran and Espinoza suffice to
resolve this case.” Ante, at 9. Not so. The state-funded
program at issue in Trinity Lutheran provided payment for
52. 8 CARSON v. MAKIN
BREYER, J., dissenting
resurfacing school playgrounds to make them safer for chil-
dren. Any Establishment Clause concerns arising from
providing money to religious schools for the creation of safer
play yards are readily distinguishable from those raised by
providing money to religious schools through the program
at issue here—a tuition program designed to ensure that all
children receive their constitutionally guaranteed right to
a free public education. After all, cities and States normally
pay for police forces, fire protection, paved streets, munici-
pal transport, and hosts of other services that benefit
churches as well as secular organizations. But paying the
salary of a religious teacher as part of a public school tuition
program is a different matter.
In addition, schools were excluded from the playground
resurfacing program at issue in Trinity Lutheran because
of the mere fact that they were “owned or controlled by a
church, sect, or other religious entity.” 582 U. S., at ___
(slip op., at 2). Schools were thus disqualified from receiv-
ing playground funds “solely because of their religious char-
acter,” not because of the “religious uses of [the] funding”
they would receive. Id., at ___, ___, n. 3 (slip op., at 10, 14,
n. 3). Here, by contrast, a school’s “ ‘affiliation or associa-
tion with a church or religious institution . . . is not dispos-
itive’ ” of its ability to receive tuition funds. 979 F. 3d 21,
38 (CA1 2020) (quoting then-commissioner of Maine’s De-
partment of Education). Instead, Maine chooses not to fund
only those schools that “ ‘promot[e] the faith or belief system
with which [the schools are] associated and/or presen[t] the
53. [academic] material taught through the lens of this
faith’ ”—i.e., schools that will use public money for religious
purposes. Ibid. Maine thus excludes schools from its tui-
tion program not because of the schools’ religious character
but because the schools will use the funds to teach and pro-
mote religious ideals.
For similar reasons, Espinoza does not resolve the pre-
sent case. In Espinoza, Montana created “a scholarship
9 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
program for students attending private schools.” 591 U. S.,
at ___ (slip op., at 1). But the State prohibited families from
using the scholarship at any private school “ ‘owned or con-
trolled in whole or in part by any church, religious sect, or
54. denomination.’ ” Id., at ___ (slip op., at 3) (quoting Mont.
Admin. Rule §42.4.802(1)(a) (2015)). As in Trinity Lu-
theran, Montana denied funds to schools based “expressly
on religious status and not religious use”; “[t]o be eligible”
for scholarship funds, a school had to “divorce itself from
any religious control or affiliation.” 591 U. S. at ___–___
(slip op., at 10–11). Here, again, Maine denies tuition
money to schools not because of their religious affiliation,
but because they will use state funds to promote religious
views.
These distinctions are important. The very point of the
Establishment Clause is to prevent the government from
sponsoring religious activity itself, thereby favoring one re-
ligion over another or favoring religion over nonreligion.
See Engel, 370 U. S., at 430 (“Under [the Establishment
Clause] . . . government in this country, be it state or fed-
eral, is without power to prescribe by law . . . any program
of governmentally sponsored religious activity”); Walz, 397
U. S., at 668 (“[F]or the men who wrote the Religion Clauses
. . . the ‘establishment’ of a religion connoted . . . [any] ac-
tive involvement of the sovereign in religious activity”);
Everson, 330 U. S., at 15 (States may not “pass laws which
aid one religion, aid all religions, or prefer one religion over
another”). State funding of religious activity risks the very
social conflict based upon religion that the Religion Clauses
were designed to prevent. And, unlike the circumstances
present in Trinity Lutheran and Espinoza, it is religious ac-
tivity, not religious labels, that lies at the heart of this case.
III
A
I turn now to consider the Maine program at issue here.
55. 10 CARSON v. MAKIN
BREYER, J., dissenting
Maine’s Constitution guarantees Maine’s children a free
public education by requiring that all towns provide “for the
support and maintenance of public schools.” Art. VIII, pt.
1, §1; see also Me. Rev. Stat. Ann., Tit. 20–A, §2(1) (2008).
Because of the State’s rural geography and dispersed popu-
lation, however, over half of Maine’s school districts do not
operate public secondary schools. App. 70. To fulfill its con-
stitutional promise, Maine created a program that provides
some parents in these districts with a monetary grant to
help them educate their children “at the public school or the
approved private school of the parent’s choice.” Me. Rev.
Stat. Ann., Tit. 20–A, §5204(4) (Cum. Supp. 2021). The pro-
gram’s “function is limited to authorizing the provision of
tuition subsidies to the parents of children who live within
school [districts] that simply do not have the resources to
operate a public school system, and whose children would
otherwise not be given an opportunity to receive a free pub-
56. lic education.” Hallissey v. School Administrative Dist. No.
77, 2000 ME 143, ¶16, 755 A. 2d 1068, 1073.
Under Maine law, an “approved” private school must be
“nonsectarian.” §2951(2). A school fails to meet that re-
quirement (and is deemed “sectarian”) only if it is both (1)
“ ‘associated with a particular faith or belief system’” and
also (2) “ ‘promotes the faith or belief system with which it
is associated and/or presents the [academic] material
taught through the lens of this faith.’ ” 979 F. 3d, at 38
(quoting Maine’s then-education commissioner). To deter-
mine whether a school is sectarian, the “ ‘focus is on what
the school teaches through its curriculum and related activ-
ities, and how the material is presented.’ ” Ibid. (emphasis
deleted). “ ‘[A]ffiliation or association with a church or reli-
gious institution . . . is not dispositive’ ” of sectarian status.
Ibid.
The two private religious schools at issue here satisfy
both of these criteria. They are affiliated with a church or
religious organization. See App. 80, 91. And they also teach
57. 11 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
students to accept particular religious beliefs and to engage
in particular religious practices.
The first school, Bangor Christian, has “educational ob-
jectives” that include “ ‘lead[ing] each unsaved student to
trust Christ as his/her personal savior and then to follow
Christ as Lord of his/her life,’ ” and “ ‘develop[ing] within
each student a Christian world view and Christian philoso-
phy of life.’ ” Id., at 84. Bangor Christian “does not believe
there is any way to separate the religious instruction from
the academic instruction.” Id., at 85. Academic instruction
and religious instruction are thus “completely intertwined.”
Ibid. Bangor Christian teaches in its social studies class,
for example, “ ‘that God has ordained evangelism.’ ” Id., at
87. And in science class, students learn that atmospheric
layers “ ‘are evidence of God’s good design.’ ” Id., at 89.
The second school, Temple Academy, similarly promotes
religion through academics. Its “educational philosophy ‘is
based on a thoroughly Christian and Biblical world view.’ ”
Id., at 92. The school’s “objectives” include “ ‘foster[ing]
within each student an attitude of love and reverence of the
Bible as the infallible, inerrant, and authoritative Word of
58. God.’ ” Ibid. And the school’s “ ‘academic growth’ objectives”
include “ ‘provid[ing] a sound academic education in which
the subjec[t] areas are taught from a Christian point of
view,’ ” and “ ‘help[ing] every student develop a truly Chris-
tian world view by integrating studies with the truths of
Scripture.’ ” Id., at 93. Like Bangor Christian, Temple “pro-
vides a ‘biblically-integrated education,’ which means that
the Bible is used in every subject that is taught.” Id., at 96.
In mathematics classes, for example, students learn that “a
creator designed the universe such that ‘one plus one is al-
ways going to be two.’ ” Ibid.
The differences between this kind of education and a
purely civic, public education are important. “The religious
education and formation of students is the very reason for
the existence of most private religious schools.” Our Lady
12 CARSON v. MAKIN
59. BREYER, J., dissenting
of Guadalupe School v. Morrissey-Berru, 591 U. S. ___, ___
(2020) (slip op., at 2). “[E]ducating young people in their
faith, inculcating its teachings, and training them to live
their faith,” we have said, “are responsibilities that lie at
the very core of the mission of a private religious school.”
Id., at ___ (slip op., at 18). Indeed, we have recognized that
the “connection that religious institutions draw between
their central purpose and educating the young in the faith”
is so “close” that teachers employed at such schools act as
“ministers” for purposes of the First Amendment. Id., at
___, ___ (slip op., at 2, 21); see also Hosanna-Tabor Evan-
gelical Lutheran Church and School v. EEOC, 565 U. S. 171
(2012).
By contrast, public schools, including those in Maine,
seek first and foremost to provide a primarily civic educa-
tion. We have said that, in doing so, they comprise “a most
vital civic institution for the preservation of a democratic
system of government, and . . . the primary vehicle for
transmitting the values on which our society rests.” Plyler
v. Doe, 457 U. S. 202, 221 (1982) (citation and internal quo-
tation marks omitted). To play that role effectively, public
schools are religiously neutral, neither disparaging nor pro-
moting any one particular system of religious beliefs. We
accordingly have, as explained above, consistently required
public school education to be free from religious affiliation
or indoctrination. Cf. Edwards v. Aguillard, 482 U. S. 578,
583–584 (1987) (“The Court has been particularly vigilant
in monitoring compliance with the Establishment Clause in
elementary and secondary [public] schools”).
Maine legislators who endorsed the State’s nonsectarian
requirement recognized these differences between public
60. and religious education. They did not want Maine taxpay-
ers to finance, through a tuition program designed to en-
sure the provision of free public education, schools that
would use state money for teaching religious practices. See,
e.g., App. 104 (Maine representative stating that “[f]rom a
13 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
public policy position, we must believe that a religiously
neutral classroom is the best if funded by public dollars”);
id., at 106 (Maine senator asserting that the State’s “lim-
ited [tax] dollars for schools” should be spent on those “that
are non-religious and that are neutral on religion”). Under-
lying these views is the belief that the Establishment
Clause seeks government neutrality. And the legislators
thought that government payment for this kind of religious
education would be antithetical to the religiously neutral
education that the Establishment Clause requires in public
61. schools. Cf. Epperson, 393 U. S., at 106; McCollum, 333
U. S., at 211. Maine’s nonsectarian requirement, they be-
lieved, furthered the State’s antiestablishment interests in
not promoting religion in its public school system; the re-
quirement prevented public funds—funds allocated to en-
sure that all children receive their constitutional right to a
free public education—from being given to schools that
would use the funds to promote religion.
In the majority’s view, the fact that private individuals,
not Maine itself, choose to spend the State’s money on reli-
gious education saves Maine’s program from Establishment
Clause condemnation. But that fact, as I have said, simply
permits Maine to route funds to religious schools. See, e.g.,
Zelman, 536 U. S., at 652. It does not require Maine to
spend its money in that way. That is because, as explained
above, this Court has long followed a legal doctrine that
gives States flexibility to navigate the tension between the
two Religion Clauses. Supra, at 4. This doctrine “recog-
nize[s] that there is ‘play in the joints’ between what the
Establishment Clause permits and the Free Exercise
Clause compels.” Trinity Lutheran, 582 U. S., at ___ (slip
op., at 6) (quoting Locke, 540 U. S., at 718). This wiggle-
room means that “[t]he course of constitutional neutrality
in this area cannot be an absolutely straight line.” Walz,
397 U. S., at 669. And in walking this line of government
62. 14 CARSON v. MAKIN
BREYER, J., dissenting
neutrality, States must have “some space for legislative ac-
tion neither compelled by the Free Exercise Clause nor pro-
hibited by the Establishment Clause,” Cutter, 544 U. S., at
719, in which they can navigate the tension created by the
Clauses and consider their own interests in light of the
Clauses’ competing prohibitions. See, e.g., Walz, 397 U. S.,
at 669.
Nothing in our Free Exercise Clause cases compels Maine
to give tuition aid to private schools that will use the funds
to provide a religious education. As explained above, this
Court’s decisions in Trinity Lutheran and Espinoza prohibit
States from denying aid to religious schools solely because
of a school’s religious status—that is, its affiliation with or
control by a religious organization. Supra, at 7–9. But we
have never said that the Free Exercise Clause prohibits
States from withholding funds because of the religious use
to which the money will be put. Cf. Trinity Lutheran, 582
U. S., at ___ (slip op., at 12). To the contrary, we upheld in
Locke a State’s decision to deny public funding to a recipient
“because of what he proposed to do” with the money, when
what he proposed to do was to “use the funds to prepare for
the ministry.” Trinity Lutheran, 582 U. S., at ___ (slip op.,
at 12); see also Espinoza, 591 U. S., at ___ (slip op., at 13)
(characterizing Locke similarly). Maine does not refuse to
pay tuition at private schools because of religious status or
63. affiliation. The State only denies funding to schools that
will use the money to promote religious beliefs through a
religiously integrated education—an education that, in
Maine’s view, is not a replacement for a civic-focused public
education. See 979 F. 3d, at 38. This makes Maine’s deci-
sion to withhold public funds more akin to the state decision
that we upheld in Locke, and unlike the withholdings that
we invalidated in Trinity Lutheran and Espinoza.
The Free Exercise Clause thus does not require Maine to
fund, through its tuition program, schools that will use pub-
15 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
lic money to promote religion. And considering the Estab-
lishment Clause concerns underlying the program, Maine’s
decision not to fund such schools falls squarely within the
play in the joints between those two Clauses. Maine has
promised all children within the State the right to receive a
free public education. In fulfilling this promise, Maine en-
deavors to provide children the religiously neutral educa-
tion required in public school systems. And that, in signif-
64. icant part, reflects the State’s antiestablishment interests
in avoiding spending public money to support what is es-
sentially religious activity. The Religion Clauses give
Maine the ability, and flexibility, to make this choice.
B
In my view, Maine’s nonsectarian requirement is also
constitutional because it supports, rather than undermines,
the Religion Clauses’ goal of avoiding religious strife. Forc-
ing Maine to fund schools that provide the sort of religiously
integrated education offered by Bangor Christian and Tem-
ple Academy creates a similar potential for religious strife
as that raised by promoting religion in public schools. It
may appear to some that the State favors a particular reli-
gion over others, or favors religion over nonreligion. Mem-
bers of minority religions, with too few adherents to estab-
lish schools, may see injustice in the fact that only those
belonging to more popular religions can use state money for
religious education. Taxpayers may be upset at having to
finance the propagation of religious beliefs that they do not
share and with which they disagree. And parents in school
districts that have a public secondary school may feel indig-
nant that only some families in the State—those families in
the more rural districts without public schools—have the
opportunity to give their children a Maine-funded religious
education.
Maine legislators who endorsed the State’s nonsectarian
requirement understood this potential for social conflict.
65. 16 CARSON v. MAKIN
BREYER, J., dissenting
They recognized the important rights that religious schools
have to create the sort of religiously inspired curriculum
that Bangor Christian and Temple Academy teach. Legis-
lators also recognized that these private schools make reli-
giously based enrollment and hiring decisions. Bangor
Christian and Temple Academy, for example, have admis-
sions policies that allow them to deny enrollment to stu-
dents based on gender, gender-identity, sexual orientation,
and religion, and both schools require their teachers to be
Born Again Christians. App. 82–83, 89, 93, 98. Legislators
did not want Maine taxpayers to pay for these religiously
based practices—practices not universally endorsed by all
citizens of the State—for fear that doing so would cause a
significant number of Maine citizens discomfort or displeas-
ure. See, e.g., id., at 101 (Maine representative noting that
“private religious schools discriminate against citizens of
the State of Maine,” such as by “not hir[ing] individuals
whose beliefs are not consistent with the school’s religious
teachings,” and asserting that “it is fundamentally wrong
for us to fund” such discrimination); id., at 104 (Maine rep-
resentative stating that “the people of Maine” should not
use “public money” to advance “their religious pursuits,”
and that “discrimination in religious institutions” should
not be funded “with my dollar”); id., at 107 (Maine senator
expressing concern that “public funds could be used to teach
intolerant religious views”). The nonsectarian requirement
66. helped avoid this conflict—the precise kind of social conflict
that the Religion Clauses themselves sought to avoid.
Maine’s nonsectarian requirement also serves to avoid re-
ligious strife between the State and the religious schools.
Given that Maine is funding the schools as part of its effort
to ensure that all children receive the basic public education
to which they are entitled, Maine has an interest in ensur-
ing that the education provided at these schools meets cer-
tain curriculum standards. Religious schools, on the other
17 Cite as: 596 U. S. ____ (2022)
BREYER, J., dissenting
hand, have an interest in teaching a curriculum that ad-
vances the tenets of their religion. And the schools are of
67. course entitled to teach subjects in the way that best re-
flects their religious beliefs. But the State may disagree
with the particular manner in which the schools have de-
cided that these subjects should be taught.
This is a situation ripe for conflict, as it forces Maine into
the position of evaluating the adequacy or appropriateness
of the schools’ religiously inspired curriculum. Maine does
not want this role. As one legislator explained, one of the
reasons for the nonsectarian requirement was that
“[g]overnment officials cannot, and should not, review the
religious teachings of religious schools.” Ibid. Another leg-
islator cautioned that the State would be unable to “recon-
cile” the curriculum of “private religious schools who teach
religion in the classroom” with Maine “standards . . . that
do not include any sort of religion in them.” Id., at 102.
Nor do the schools want Maine in this role. Bangor Chris-
tian asserted that it would only consider accepting public
funds if it “did not have to make any changes in how it op-
erates.” Id., at 90. Temple Academy similarly stated that
it would only accept state money if it had “in writing that
the school would not have to alter its admissions standards,
hiring standards, or curriculum.” Id., at 99. The nonsec-
tarian requirement ensures that Maine is not pitted against
private religious schools in these battles over curriculum or
operations, thereby avoiding the social strife resulting from
this state-versus-religion confrontation. By invalidating
the nonsectarian requirement, the majority today subjects
the State, the schools, and the people of Maine to social con-
flict of a kind that they, and the Religion Clauses, sought to
prevent.
I emphasize the problems that may arise out of today’s
decision because they reinforce my belief that the Religion
Clauses do not require Maine to pay for a religious educa-
68. tion simply because, in some rural areas, the State will help
18 CARSON v. MAKIN
BREYER, J., dissenting
parents pay for a secular education. After all, the Estab-
lishment Clause forbids a State from paying for the practice
of religion itself. And state neutrality in respect to the
teaching of the practice of religion lies at the heart of this
Clause. See, e.g., Locke, 540 U. S., at 721–722 (noting that
there are “few areas in which a State’s antiestablishment
interests come more into play” than state funding of minis-
ters who will “lead [their] congregation[s]” in “religious en-
deavor[s]”). There is no meaningful difference between a
State’s payment of the salary of a religious minister and the
salary of someone who will teach the practice of religion to
a person’s children. At bottom, there is almost no area “as
central to religious belief as the shaping, through primary
education, of the next generation’s minds and spirits.” Zel-
man, 536 U. S., at 725 (BREYER, J., dissenting). The Estab-
lishment Clause was intended to keep the State out of this
area.
69. * * *
Maine wishes to provide children within the State with a
secular, public education. This wish embodies, in signifi-
cant part, the constitutional need to avoid spending public
money to support what is essentially the teaching and prac-
tice of religion. That need is reinforced by the fact that we
are today a Nation of more than 330 million people who as-
cribe to over 100 different religions. In that context, state
neutrality with respect to religion is particularly important.
The Religion Clauses give Maine the right to honor that
neutrality by choosing not to fund religious schools as part
of its public school tuition program. I believe the majority
is wrong to hold the contrary. And with respect, I dissent.
_________________
_________________
1 Cite as: 596 U. S. ____ (2022)
70. SOTOMAYOR, J., dissenting
SUPREME COURT OF THE UNITED STATES
No. 20–1088
DAVID CARSON, AS PARENT AND NEXT FRIEND OF O. C.,
ET AL., PETITIONERS v. A. PENDER MAKIN
ON WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF
APPEALS FOR THE FIRST CIRCUIT
[June 21, 2022]
JUSTICE SOTOMAYOR, dissenting.
This Court continues to dismantle the wall of separation
between church and state that the Framers fought to build.
JUSTICE BREYER explains why the Court’s analysis falters
on its own terms, and I join all but Part I–B of his dissent.
I write separately to add three points.
First, this Court should not have started down this path
five years ago. See Trinity Lutheran Church of Columbia,
Inc. v. Comer, 582 U. S. ___ (2017). Before Trinity Lu-
theran, it was well established that “both the United States
and state constitutions embody distinct views” on “the sub-
ject of religion”—“in favor of free exercise, but opposed to
establishment”—“that find no counterpart” with respect to
other constitutional rights. Locke v. Davey, 540 U. S. 712,
721 (2004). Because of this tension, the Court recognized
“ ‘room for play in the joints’ between” the Religion Clauses,
with “some state actions permitted by the Establishment
Clause but not required by the Free Exercise Clause.” Id.,
at 718–719 (quoting Walz v. Tax Comm’n of City of New
71. York, 397 U. S. 664, 669 (1970)); see ante, at 4 (BREYER, J.,
dissenting). Using this flexibility, and consistent with a
rich historical tradition, see Trinity Lutheran, 582 U. S., at
___–___ (SOTOMAYOR, J., dissenting) (slip op., at 11–16),
States and the Federal Government could decline to fund
2 CARSON v. MAKIN
SOTOMAYOR, J., dissenting
religious institutions. Moreover, the Court for many dec-
ades understood the Establishment Clause to prohibit gov-
ernment from funding religious exercise.*
Over time, the Court eroded these principles in certain
respects. See, e.g., Zelman v. Simmons-Harris, 536 U. S.
639, 662 (2002) (allowing government funds to flow to reli-
gious schools if private individuals selected the benefiting
schools; the government program was “entirely neutral
with respect to religion”; and families enjoyed a “genuine
72. choice among options public and private, secular and reli-
gious”). Nevertheless, the space between the Clauses con-
tinued to afford governments “some room to recognize the
unique status of religious entities and to single them out on
that basis for exclusion from otherwise generally applicable
laws.” Trinity Lutheran, 582 U. S., at ___ (SOTOMAYOR, J.,
dissenting) (slip op., at 9).
Trinity Lutheran veered sharply away from that under-
standing. After assuming away an Establishment Clause
violation, the Court revolutionized Free Exercise doctrine
by equating a State’s decision not to fund a religious organ-
ization with presumptively unconstitutional discrimination
on the basis of religious status. See id., at ___–___ (slip op.,
at 10–11). A plurality, however, limited the Court’s deci-
sion to “express discrimination based on religious identity”
(i.e., status), not “religious uses of funding.” Id., at ___, n. 3
(slip op., at 14, n. 3). In other words, a State was barred
——————
*See, e.g., Everson v. Board of Ed. of Ewing, 330 U. S. 1, 16
(1947) (“No
tax in any amount, large or small, can be levied to support any
religious
activities or institutions . . . ”); Agostini v. Felton, 521 U. S.
203, 222–223
(1997) (observing that government aid that impermissibly
“advanc[ed]
. . . religion” was constitutionally barred); Mitchell v. Helms,
530 U. S.
793, 840 (2000) (O’Connor, J., concurring in judgment) (“[O]ur
decisions
provide no precedent for the use of public funds to finance
religious ac-
tivities” (internal quotation marks omitted)); see also
73. Rosenberger v. Rec-
tor and Visitors of Univ. of Va., 515 U. S. 819, 875–876 (1995)
(Souter,
J., dissenting) (chronicling cases).
3 Cite as: 596 U. S. ____ (2022)
SOTOMAYOR, J., dissenting
from withholding funding from a religious entity “solely be-
cause of its religious character,” id., at ___ (opinion of the
Court) (slip op., at 14), but retained authority to do so on
the basis that the funding would be put to religious uses.
Two Terms ago, the Court reprised and extended Trinity
Lutheran’s error to hold that a State could not limit a pri-
vate-school voucher program to secular schools. Espinoza
v. Montana Dept. of Revenue, 591 U. S. ___, ___ (2020) (slip
op., at 9). The Court, however, again refrained from extend-
ing Trinity Lutheran from funding restrictions based on re-
ligious status to those based on religious uses. Espinoza,
591 U. S., at ___–___ (2020) (slip op., at 9–12).
As JUSTICE BREYER explains, see ante, at 8–9, this status-
74. use distinction readily distinguishes this case from Trinity
Lutheran and Espinoza. I warned in Trinity Lutheran,
however, that the Court’s analysis could “be manipulated to
call for a similar fate for lines drawn on the basis of reli-
gious use.” 582 U. S., at ___, n. 14 (dissenting opinion) (slip
op., at 25, n. 14). That fear has come to fruition: The Court
now holds for the first time that “any status-use distinction”
is immaterial in both “theory” and “practice.” Ante, at 17.
It reaches that conclusion by embracing arguments from
prior separate writings and ignoring decades of precedent
affording governments flexibility in navigating the tension
between the Religion Clauses. As a result, in just a few
years, the Court has upended constitutional doctrine, shift-
ing from a rule that permits States to decline to fund reli-
gious organizations to one that requires States in many cir-
cumstances to subsidize religious indoctrination with
taxpayer dollars.
Second, the consequences of the Court’s rapid transfor-
mation of the Religion Clauses must not be understated.
From a doctrinal perspective, the Court’s failure to apply
the play-in-the-joints principle here, see ante, at 13–14
(BREYER, J., dissenting), leaves one to wonder what, if any-
thing, is left of it. The Court’s increasingly expansive view
75. 4 CARSON v. MAKIN
SOTOMAYOR, J., dissenting
of the Free Exercise Clause risks swallowing the space be-
tween the Religion Clauses that once “permit[ted] religious
exercise to exist without sponsorship and without interfer-
ence.” Walz, 397 U. S., at 669.
From a practical perspective, today’s decision directs the
State of Maine (and, by extension, its taxpaying citizens) to
subsidize institutions that undisputedly engage in religious
instruction. See ante, at 10–11 (BREYER, J., dissenting). In
addition, while purporting to protect against discrimination
of one kind, the Court requires Maine to fund what many of
its citizens believe to be discrimination of other kinds. See
ante, at 16 (BREYER, J., dissenting) (summarizing Bangor
Christian Schools’ and Temple Academy’s policies denying
enrollment to students based on gender identity, sexual ori-
entation, and religion). The upshot is that Maine must
choose between giving subsidies to its residents or refrain-
ing from financing religious teaching and practices.
Finally, the Court’s decision is especially perverse be-
cause the benefit at issue is the public education to which
all of Maine’s children are entitled under the State Consti-
tution. As this Court has long recognized, the Establish-
ment Clause requires that public education be secular and
neutral as to religion. See ante, at 2–3, 12 (BREYER, J., dis-
senting) (collecting cases). The Court avoids this framing
of Maine’s benefit because, it says, “Maine has decided not
76. to operate schools of its own, but instead to offer tuition as-
sistance that parents may direct to the public or private
schools of their choice.” Ante, at 14. In fact, any such
“deci[sion],” ibid., was forced upon Maine by “the realities
of remote geography and low population density,” ante, at
2, which render it impracticable for the State to operate its
own schools in many communities.
The Court’s analysis does leave some options open to
Maine. For example, under state law, school administra-
tive units (SAUs) that cannot feasibly operate their own
5 Cite as: 596 U. S. ____ (2022)
SOTOMAYOR, J., dissenting
schools may contract directly with a public school in an-
other SAU, or with an approved private school, to educate
their students. See Me. Rev. Stat. Ann., Tit. 20–A, §§2701,
2702 (2008). I do not understand today’s decision to man-
date that SAUs contract directly with schools that teach re-
ligion, which would go beyond Zelman’s private-choice doc-
trine and blatantly violate the Establishment Clause.
77. Nonetheless, it is irrational for this Court to hold that the
Free Exercise Clause bars Maine from giving money to par-
ents to fund the only type of education the State may pro-
vide consistent with the Establishment Clause: a reli-
giously neutral one. Nothing in the Constitution requires
today’s result.
* * *
What a difference five years makes. In 2017, I feared that
the Court was “lead[ing] us . . . to a place where separation
of church and state is a constitutional slogan, not a consti-
tutional commitment.” Trinity Lutheran, 582 U. S., at ___
(dissenting opinion) (slip op., at 27). Today, the Court leads
us to a place where separation of church and state becomes
a constitutional violation. If a State cannot offer subsidies
to its citizens without being required to fund religious exer-
cise, any State that values its historic antiestablishment in-
terests more than this Court does will have to curtail the
support it offers to its citizens. With growing concern for
where this Court will lead us next, I respectfully dissent.
3
Analysis of “Partnership After Prison: Couple Relationships
During Reentry”
Sabrina Middleton
Southern New Hampshire University
78. Math - 133
November 4th, 2022
The study that I picked was Partnership after prison: Couples
relationships during reentry. The primary focus of this research
is on couples after the man has been released from prison and is
reentering society. They were thinking about how long the
relationship would last. They were also curious about the
relationship before and after prison. This study focused on men
who had recently been released from prison for the second time.
The study also focuses on what could potentially affect the
couple’s relationship.
The purpose of this study was to show what life is really like
when trying to adjust to life after getting out of jail. In addition,
the data and information obtained during the study were used
towards reducing the number of repeated offenders while
encouraging positive interaction and communication with their
partner. The use of statistical data made it easier to find out
what methods were most likely useful and which options should
be made available to the detained person both before and after
release to help with their relationship and the life challenges the
detainee may face once released. The study's goal is to
demonstrate how programs and support can help people
successfully reenter society with the person they are in a
relationship with.
For this study, 641 couples who were in relationships with the
male incarcerated were interviewed. The majority of the couples
in the study were not legally married but had long-term
relationships. A high percentage of the males in the research
couples had previous incarcerations on their record, with an
79. average of 6.5 and 7.0 prior incarcerations during adulthood
(Comfort et al., 2018). This demonstrated that the couples had
been through similar experiences and were not new to this type
of relationship. The demographics are released prisoners and
their spouses.
References
Comfort, M., Krieger, K. E., Landwehr, J., McKay, T.,
Lindquist, C. H., Feinberg, R., Kennedy, E. K., & Bir, A.
(2018). Partnership after prison: Couple relationships during
reentry. Journal of Offender Rehabilitation, 57(2), 188-205.
https://doi.org/10.1080/10509674.2018.1441208
Milestone two
Sabrina Middleton
SNHU
November 16th, 2022
80. Using quantitative and qualitative data to evaluate the
hypothesis that the couple's relationships would stay effective
with no symptoms of conflict or infidelity both while they were
in prison and after their release was one of the ways researchers
were looking for in this study. Researchers also predicted that
relationships between couples would be stronger than when they
were imprisoned. Before this study, there was no statistical
information regarding how the reentry process impacted
relationships; instead, there was information about how
imprisonment affected relationships between spouses and
inmates. Unmarried couples in long-term, committed romantic
relationships were the subjects of the research. According to the
sample's characteristics, "the majority of the couples in both the
quantitative and qualitative research groups reported being in
long-term, committed, and exclusively intimate relationships
that were not marriages. Most of the men and women who
participated in the research were parents of minor children and
had at least one kid together. Men's engagement in the criminal
justice system was rather substantial; they reported an average
of 6.5 (quantitative sample) and 7.0 (qualitative sample) prior
incarcerations throughout adulthood. Couples often mentioned
enduring multiple rounds of imprisonment and readmission
throughout their relationship in qualitative interviews. The
research couples' baseline characteristics for each sample are
summarized in Table 1, which was conducted on average
roughly 2.5 years following the male partner's admittance to jail
(Comfort et., 2018). While going through the reentry phase,
many male partners who are in prison encounter several
challenges, such as finding work given their criminal histories
and being forced to rely on their female partner's income to
continue taking care of the family's obligations. Men face daily
life as the caregivers for young children while the woman is at
work, which sometimes puts a strain on the father, kid, and
occasionally spouse. The study contrasts the effectiveness of
these relationships between male prisoners who are in intimate
relationships while they are incarcerated and those who are not.