Wood v. Arnold (P)

In this suit to vindicate a student’s First Amendment rights, two statements concerning Islamic beliefs, presented as part of a high school world history class, did not violate the student’s rights under either the Establishment Clause or the Free Speech Clause.

The record doesn’t support the student’s contention that school officials used the statements about Islam to endorse that religion over Christianity or that the officials compelled the student to profess a belief in Islam against her will. Contrary to the student’s contention, the court should analyze each statement in context, not apart from the subject matter of the class in which the statements appeared.

In a required world history class, the smallest unit focused on “The Muslim World” and contained material on “formation of Middle Eastern empires including the basic concepts of the Islamic faith and how it along with politics, culture, economics, and geography contributed to the development of those empires.” The student was required to complete a fill-in-the-blank worksheet that included the “Five Pillars” of Islam, including the statement that “There is no god but Allah and Muhammad is the messenger of Allah.”

The worksheet included a variety of factual information related to Islam and merely asked the students to demonstrate their understanding of the material by completing the partial sentences. This is precisely the sort of academic exercise that the Supreme Court has indicated would not run afoul of the Establishment Clause. A reasonable observer, aware of the world history curriculum being taught, would not view the challenged materials as communicating a message of endorsement. Because the challenged materials satisfy all three prongs of the Lemon test, the district court properly granted summary judgment to the defendants on the Establishment Clause claim.

As to the student’s Free Speech rights, a student’s right against compelled speech has limited application in a classroom setting in which a student is asked to study and discuss materials with which she disagrees. Here, the worksheet didn’t rise to the level of compelled speech prohibited by the constitution in schools.


Wood v. Arnold (P), No. 18-1430, Feb. 11, 2019. 4th Cir. (Keenan) from DMD at Greenbelt (Hazel).

Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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