CultNEWS101 Articles: 7/2/2025

Religion, Meditation, Ayurveda, FLDS

Federalist: Is Your Child's Public School Teaching Eastern Mysticism Like This Chicago Classroom?

"Meditation programs, often led by yoga instructors or trained facilitators. These initiatives are commonly labeled as nonreligious tools to reduce stress, improve focus, and enhance emotional regulation.

Programs like Mindful Schools, Calm Schools, and Quiet Time, the latter promoted by the New Age David Lynch Foundation, have made their way into classrooms across the United States. But what appears to be a neutral wellness intervention is often deeply rooted in Eastern religious traditions, raising concerns about religious freedom, consent, and the psychological safety of children.

One striking example occurred in Chicago, where a Christian student, Mariyah Green, won a $150,000 legal settlement after she said she was coerced into participating in the Quiet Time meditation program. The program involved chanting Sanskrit prayers during a ceremony known as a Puja, an act of worship in Hinduism that includes offerings to deities. Green alleged she wasn't informed of the religious significance and believed participation affected her academic standing and athletic eligibility. Both the Chicago Public Schools and the David Lynch Foundation settled the case, though they denied liability.

In addition to the Mariyah Green lawsuit, other legal battles have highlighted the spiritual nature of school-based mindfulness meditation programs. In Encinitas, California, a group of parents filed a lawsuit in 2013 against the school district for promoting yoga as part of the school day. The parents argued that the program, funded by a $500,000 grant from the K. P. Jois Foundation, a group that teaches Ashtanga Yoga, rooted in Hindu traditions, was inherently religious. Although the court ultimately ruled in favor of the school, the case revealed just how deeply spiritual ideologies can become embedded in the name of wellness. Children were reportedly taught poses named after Hindu deities and encouraged to chant "Om," a sacred syllable in Eastern religions. What the school called physical education, the plaintiffs recognized as indoctrination.

Such programs are spreading across the country. In addition to Mindful Schools, Calm Schools, and Quiet Time programs, many other programs are marketed as secular, science-based tools for improving focus and emotional regulation in schools. Yet a closer look reveals that many of these initiatives often include breathing rituals, body scans, and visualizations, practices directly tied to Hinduism, Buddhism, or New Age belief systems. By avoiding overt spiritual language, they slip past constitutional scrutiny while reshaping the spiritual landscape of the classroom."

JAMA, Medical News & Perspectives, Oct. 2, 1991: "Maharishi Ayur-Veda: guru's marketing scheme promises the world eternal 'perfect health'"

The Minnesota Star Tribune: Grand Marais trial over North Shore land sale renews questions about breakaway Mormon sect leader

"Elissa Wall hasn't seen a cent of the more than $10 million dollars she's owed from a lawsuit against self-described prophet and polygamous cult leader Warren Jeffs.

He doesn't have a bank account, she testified Wednesday afternoon.

Wall is trying to collect money from a land sale conducted, on paper, by his brother Seth Jeffs and his Montana-based Emerald Industries LLC. She's convinced that Seth Jeffs used Warren Jeffs' money to buy 40 acres here in 2018, property that he sold in 2023 for $130,000.

"I'm here to recover the money given to Seth Jeffs," she told the Cook County jury.

According to court documents, Seth Jeffs claims he used his own money to buy the land. He's expected to testify on Thursday.

Warren Jeffs is also named in the lawsuit, but he's currently in a Texas prison where he is serving a life sentence for child sexual assault. He's still in the leadership role he inherited with the Fundamentalist Church of Jesus Christ of Latter-Day Saints, according to Wall.

The fundamentalist sect broke away from Mormonism after the latter moved away from polygamy."

The selection of articles for CultNEWS101 does not imply that Patrick Ryan or Joseph Kelly endorse the content. We provide information from multiple perspectives to foster dialogue.

Lawsuit alleges religious coercion through meditation in Chicago Public Schools

Chicago public high school students allege they were coerced into participating in a Hindu puja ceremony as part of a multiyear study of Transcendental Meditation's ability to reduce crime from University of Chicago's Urban Labs and the David Lynch Foundation.

Richa Karmarkar

RNS

May 13, 2024

(RNS) — Kaya Hudgins was a 16-year-old sophomore at a southwest-side Chicago public high school when her teachers announced a new mandatory program called “Quiet Time,” a twice-daily Transcendental Meditation practice designed to “decrease stress and the effects of trauma” for students living in high-crime neighborhoods. 

“I didn’t think much of it,” said Hudgins, now 21 and living in Texas. “I thought that, you know, it would just be basic meditation. I had no clue about what Hinduism was or what it was about.”

To be “initiated” into the Quiet Time practice, Hudgins recalls, she and her classmates were taken individually to a small room, told to place an offering of fruit at an altar with a man’s photograph and brass cups of camphor, incense and rice, and made to repeat the Sanskrit words a representative uttered. At the end, the representative whispered a unique, one-word mantra into her ear, according to Hudgins, and told her not to repeat it to anyone. The man in the photograph, she would later find out, was Brahmananda Saraswati, or Guru Dev: the master of Maharishi Mahesh Yogi, the Hindu guru who started the global TM movement in 1955.

“It was unusual,” added Hudgins, who said she later researched her mantra online and found it was another name for a Hindu god. “The setting was just dark, and there were objects in front of me. The lady, she rang a bell and had me repeat something after her. It felt really weird.”

This “ceremony of gratitude” as it was put forth by the David Lynch Foundation, the organization behind the $3 million Quiet Time program, resembles a form of Hindu puja, or worship ritual. This practice was “deceptively marketed to public schools as non-religious,” according to Hudgins’ attorney, John Mauck, and serves as the basis of an ongoing lawsuit against the David Lynch Foundation and the Board of Education of the City of Chicago for violating the establishment clause of the First Amendment.

“There’s no gratitude here,” said Mauck. “It’s all invocation to Hindu deities to channel their energies through the participants. So that’s where it’s not teaching about Hinduism; it’s practicing Hinduism.”

The David Lynch foundation did not respond to multiple requests for comment.

CPS told RNS in a statement, that the district “continuously” reviews its programs “to ensure they are operating as intended and implement changes as needed to ensure students can continue to learn, grow, and thrive.”

Hudgins’ case, which was filed in January of last year and is pending a court date, was granted class action status by a federal judge last month, meaning anyone who reached the age of 18 on or after Jan. 13, 2021, and who was a student between 2015-2019 could have a standing in the lawsuit. During those four years, the David Lynch Foundation and University of Chicago’s Urban Labs, a social and behavioral research initiative on community violence, were testing the Quiet Time study in five Chicago public schools.

Of the more than 2,000 student participants in the program, many, according to Mauck, were told not to tell their parents about it, “especially if they were religious,” he said. And if they did not want to participate or sign the waiver — like Hudgins, who said it went against her Muslim beliefs — students were reprimanded or told that not signing would affect their academic standing.

“I feel like that affected my faith in a weird way, because I felt like I wasn’t committed to my faith, like I wasn’t praying five daily prayers but was required to do the meditation,” said Hudgins.

After a 2019 presentation to the Chicago Public School board by a former staff member, including complaints about Quiet Time from more than 60 students, CPS came to the David Lynch Foundation with a compromise: They would continue the 15-minute meditations during class time but would no longer do the initiation puja. The Lynch foundation refused, instead ending the study and partnership.

Mauck, whose firm has settled two other similar cases, said his legal action has been informed by the 1979 landmark case Malnak vs. Yogi, when a TM course was offered to students at five New Jersey high schools by the World Plan Executive Council, under Maharishi’s purview. After a review of the meanings behind the Sanskrit incantations involved in the puja, the implementation of TM in public schools was found to be unlawful. 

Transcendental Meditation movement founder Maharishi Mahesh Yogi in 1977. (RNS archive photo)

“Maybe the Lynch foundation thought people would forget about it, and they tried to say it was a different case, different group,” he said. “But it was the same Transcendental Meditation that has a plan and a process and a ceremony. The puja doesn’t really change. Transcendental Meditation is the same everywhere.”

Transcendental Meditation, as described on the David Lynch Foundation’s website, is an “effortless technique” that “allows the active thinking mind to settle inward to experience a naturally calm, peaceful level of awareness.” TM, as compared to other forms of meditation, focuses on one sound or mantra, the repetition of which, proponents say, may cause one to get deeper and deeper into a meditative state of self-hypnosis, thus increasing focus and lessening stress. The foundation’s websites claims more than 450 peer-reviewed published studies on TM documenting its positive effects on stress-related disorders, cognitive functioning and overall health and well-being.

According to those familiar, like former TM instructor Aryeh Siegel, Maharishi initially sought to share this simple sound meditation technique with the world, intent on getting anyone, regardless of religious background, closer to “cosmic consciousness.”

Siegel used to believe in this message. A former TM instructor, Siegel met his wife at the national headquarters during the six years he taught there in the 1970s, along with a group of fellow adherents he described as “pretty normal people.”

“We were smart, young, committed, going to save the world by bringing meditation to everybody,” he said.

But, as TM gained traction, spurred on by its A-list celebrity adherents, like the Beatles and Clint Eastwood, Siegel said he saw the organization shift from its original ideals to a “scam to make money.” As hundreds of thousands of Americans became interested in TM — and paid course fees in the thousands — Siegel said Maharishi’s claims became increasingly grandiose — promising TM could help you fly, levitate, turn invisible — and the movement “became like really, very, very cultish.”

Maharishi died in 2008 and today Siegel operates a website called Transcendental Deception and has written an insider tell-all book of the same title. He hopes to be a resource to lawyers and others seeking to expose TM and what he describes as the “lies” about its religious aspects.

“I don’t have a problem with it, if they’re honest about it,” said Siegel. “How do you not tell people that this is what goes on here. If you want to learn Transcendental Meditation, this is the ceremony.”

Filmmaker David Lynch, who began his own TM practice in 1973, founded the organization in 2005 with the goal of bringing TM to “at-risk populations” around the world, including inner-city students, according to its website. Today, the foundation runs on million dollar donations and testimonies from celebrities ranging from Gwyneth Paltrow to Arnold Schwarzenegger.

The research study of which Hudgins was a part reportedly released preliminary results in 2019 that showed a reduction in the incidents of violent crime arrests for students who took the Transcendental Meditation program compared to the control group. But Mauck is skeptical.

“We have been looking after a document, arguing court motions to get further discovery,” said Mauck. “‘How did you come up with this number?’ and then being stonewalled. So as far as I’m concerned, it’s another assertion without a factual basis.”

For Syama Allard, a practicing Hindu and content writer for the Hindu American Foundation, the ordeal rings alarm bells of co-opting Hindu practices, like meditation or yoga, for “negative” intentions. “You can definitely rationalize in your mind or justify doing corrupt, sort of absurd things when you think you’re doing it in the name of spirituality.”

“At what point is something positive being used for some sort of selfish motivation, self aggrandizement or money?” he said. “That’s the point where it really starts to veer off from what Hindu spirituality is really supposed to be about.”

Hudgins, who now works in the makeup industry, hopes this lawsuit will help others in her situation.

“Now that I’m old enough, I can actually see what was going on and I’m actually happy to prevent it from happening to other children,” she said. “I can make sure that other students won’t be deceived.”

https://religionnews.com/2024/05/13/4147609/?fbclid=IwAR2w089ijCpMYdVOWCWBIzQR0tid6Ohlsn55jB6IJGxPXOm8BuTL2Fz6zUE

Federal Judge Grants Class Action to Students Alleging Coercion in Religious Rituals in Chicago Public Schools

(April 24, 2024 – Chicago) 

A petition for class action status by a former Chicago Public School student (Kaya Hudgins) who alleged that her school coerced her to participate in Transcendental Meditation (TM) and Hindu practices has been granted by a federal judge in a lawsuit against the Board of Education of the City of Chicago and the David Lynch Foundation. Attorneys at Mauck & Baker, representing Kaya Hudgins, received an order from The United States District Court for the Northern District of Illinois awarding class certification to Hudgins and her peers. The class action lawsuit alleges that while minor students were attending certain Chicago Public Schools (who chose to participate in the David Lynch Foundation “Quiet Time” program), they were required to participate in Transcendental Meditation that incorporated Hindu religious rituals, which Hudgins claims on behalf of the class is an egregious violation of their constitutional rights. 

The design, implementation, and conduct of a Chicago Public Schools program, dubbed Quiet Time, was handled by the David Lynch Foundation for World Peace, an organization teaching Transcendental Meditation. As alleged in Hudgins’ First Amended Complaint, the Foundation worked together with Chicago Public Schools and the University of Chicago to implement the program at Chicago Public School high schools.

Hudgins, by her own Declaration, was made to take part in Quiet Time.

“A Chicago Public Schools teacher told me and my entire class to sign a consent form to participate in Quiet Time,” Hudgins wrote. “My entire class and I signed the consent because we felt pressure to sign. Our teacher told us that we would get in trouble and be sent to the dean if we did not consent. The teacher also told us that not signing the consent would affect our academics. We also received the same kind of pressure to participate in the Quiet Time program on a regular basis.”

Hudgins was 16 years old at the time.

“Additionally, I, like many of my classmates, signed a nondisclosure not to tell anyone, including our parents, about the program,” added Hudgins. “My classmates and I were particularly warned by a David Lynch Foundation representative not to tell our parents if our parents were ‘religious.’”

“Not only were these minor school children coerced by Chicago Public School teacher into signing a document they had no business signing,” shared John Mauck, a partner at Mauck and Baker, “They were duped into practicing Hindu rituals and Transcendental Meditation during class time and instructed to hide their mandated participation in them from their parents.”

Hudgins recalled being escorted into an uncomfortably private one-on-one Hindu “Puja” worship ceremony in a darkened room, with chanting and a variety of religious paraphernalia. During instruction about meditation the adult woman who was alone with her whispered a “mantra” into her ear and told Hudgins not to disclose the mantra to anyone. However, Hudgins revealed that she and her classmates discussed their mantras with each other.

“Eventually I researched on the internet many of our mantras and they turned out to be the names of Hindu gods,” reported Hudgins. “My classmates and I were very hurt to learn how the school and the instructor had us participating in a religious practice without our knowledge.”

Hudgins explained how the meditation sessions, a required part of the Quiet Time curriculum, “felt like hypnosis or being in a trance.” Despite the fact that these situations felt “abnormal,” according to Hudgins, she took part because she was informed that not participating would negatively affect her grades and her academic record.

Additionally, Hudgins recounted how students were rewarded with pizza for promoting Transcendental Meditation, which her instructor referred to as “following orders,” and how one friend was offered $100 by program coordinators to participate in promote Quiet Time.

“I complained a few times to my teacher about not wanting to participate in the Quiet Time program,” shared Hudgins. “Once, my teacher sent me to the dean's office because I was questioning why we had to participate in the program. I felt angry and hurt because the school did not care whether or not I wanted to participate.”

Now 21 years old, Hudgins has talked about the damaging effect that Transcendental Meditation had on her. At the time, she was a practicing Muslim and what the school was pushing on her contradicted her religious Islamic beliefs and caused her to question her Islamic beliefs particularly whenever they said that there was a different higher power than the god she believed in.

“This was extremely offensive and very confusing,” Hudgins intimated. “It made me feel guilty and sinful because Muslims are not to worship men.”

“As a Muslim, I was supposed to pray five times a day,” said Hudgins. “Although the school made me take time away from class to practice in Transcendental Meditation, it would not allow me to take time away from class for those five daily prayers.”

Hudgins and her Mauck & Baker attorneys petitioned the court on her own behalf and for other students similarly situated, asking them to hold the Board of Education of the City of Chicago and the David Lynch Foundation accountable for deprivations of these students’ Constitutional rights.

District Judge Matthew Kennelly granted class action status for all students who participated in the Quiet Time program in Chicago Public Schools during the academic calendar for Fall 2015 through Spring 2019 and reached age eighteen on or after January 13, 2021.

In a similar case, former Chicago Public Schools student Mariyah Green, also represented by Mauck & Baker, received $150,000 in damages and legal fees in an agreed Offer of Judgment entered by the Northern District of Illinois on October 23, 2023. The monies were an agreed judgement in Green’s favor for alleged Constitutional violations of her rights by the Board of Education of the City of Chicago and the David Lynch Foundation, over mandated participation in Hindu rituals while attending a Chicago Public School. Green’s Complaint was brought to the court in February, 2023 in an effort to hold educators and program developers responsible for requiring participation in a disingenuously promoted program that violated her Christian beliefs.

Read the Memorandum Opinion and Order issued April 19, 2024, by District Judge Matthew F. Kennelly of the United States District Court – Northern District of Illinois Eastern Division granting class certification in Kaya Hudgins v. Board of Education of the City of Chicago et al., under the Establishment Clause claim, for all students who participated in the Quiet Time program in Chicago Public Schools during Chicago Public School's academic calendars for Fall 2015 through Spring 2019, and reached age eighteen on or after January 13, 2021, here [https://www.scribd.com/document/725965003/Kaya-Hudgins-v-Board-of-Education-City-of-Chicago-et-al-Memorandum-Opinion-and-Order-04-19-2024].

Read the First Amended Complaint in Kaya Hudgins v. Board of Education of the City of Chicago et al. as filed on February 3, 2023, by Mauck and Baker attorneys on behalf of Kaya Hudgins in United States District Court – Northern District of Illinois – Eastern Division here[https://www.scribd.com/document/725967561/Kaya-Hudgins-v-Board-of-Education-City-of-Chicago-et-al-First-Amended-Complaint].

 About Mauck & Baker, LLC

Mauck & Baker, established in Chicago in 2001, is nationally known for its practice in the area of religious liberty. It works with individuals, religious institutions, and businesses. For more information, please visit mauckbaker.com.

Contact: Tom Ciesielka, 312.422.1333, tc@tcpr.net

Ex-Student’s Establishment Clause Claim Can Proceed As Class

Tre'Vaughn Howard

Bloomberg Law

April 22, 2024

Judge: Establishment clause claim satisfies Rule 23

But, Free Exercise claim fails for lack of typicality across class

A former Chicago public schools student, challenging implementation of a program with Hindu-influenced religious practices under the First Amendment, can proceed as a class action on her Establishment clause claim but not her Free Exercise claim, a federal judge said.

Kaya Hudgins sued Chicago’s Board of Education—among other named defendants—alleging that implementation of the “Quiet Time” program in eight CPS schools including where she attended for two years, violated the Establishment and Free Exercise Clauses of the US Constitution. The program consisted of two 15-minute meditation sessions where students participated in “Transcendental Meditation” or in another quiet activity, Judge Mattew F. Kennelly, of the US District Court for the Northern District of Illinois, wrote.

Hudgins alleged the program was presented as non-religious, but had “‘hidden religious’ elements” because students who participated in Transcendental Meditation were assigned a Sanskrit “‘mantra’” that honored specific Hindu deities. Hudgins also alleged that students who participated were required to complete a “‘Puja’” initiation ceremony that included chants to Hindu deities inviting them to channel their powers through those in attendance. Students that opted out of participating in the meditation were still in the same classroom as those who did, Hudgins asserted.

Hudgins sought to certify a class that included all students who participated in the Quiet Program during the academic years from 2015 to 2019, and a subclass for students who participated in Quiet Time, but weren’t trained in Transcendental Meditation. CPS argued Hudgins’s claims are “overbroad,” barred the

statute of limitations, and fail to meet several requirements for certification under Rule 23.

Kennelly granted Hudgins motion in part regarding her Establishment clause claim, but denied it as to her Free Exercise claim. Citing Seventh Circuit precedent—Kennelly said CPS’s overbroad defense construes Hudgins claims “too narrowly” because students that didn’t participate in Transcendental Meditation still could have suffered harm from the alleged coercion and endorsement in violation of the Establishment clause.

Regarding the Free Exercise claim, Kennelly said adjudicating the claim would require individualized inquiries for each students’ religious beliefs. So, common questions didn’t predominate for the entire class or any variation of the subclass and, therefore, Rule 23(b)(3) wasn’t satisfied. Kennelly also amended the class definition to include students who reached age 18 on or after January 13, 2021—in order to account for an Illinois law that allows people to sue within two years of turning 18.

Kennelly disregarded CPS’s argument and exercised discretion to revise the class definition because Illinois law grants a person that was a minor when the cause of action occurred within two years of their eighteenth birthday to file a claim. And although Kennelly said Hudgins satisfied the numerosity, commonality, and typicality requirements under Rule 23 for her Establishment clause claim, Hudgins’ Free Exercise claim lacked typicality.

Specifically, Hudgins’ Free Exercise claim is not typical of the subclass since the subclass wasn’t trained in Transcendental Meditation, and would lack a representative, Kennelly said.

“Hudgins and members of the subclass do not share ‘the same essential characteristics’ with respect to their Free Exercise claims. Separating these students into the subclass Hudgins proposes does not mitigate this fundamental discrepancy,” Kennelly wrote.

Kennelly also said the four attorneys representing and Hudgins were adequate representatives, despite CPS’s citation of Hudgins’ probation status, which borders on attempted “character assassination.” The four attorneys were appointed class counsel by Kennelly.

Mauck & Baker LLC and Leahu Law Group LLC represent Hudgins and the Establishment Clause class. Pretzel & Stouffer represents Defendant David Lynch Foundation. Greenberg Traurig LLP and in-house attorneys represent the Chicago Board of Education.

The case is Hudgins v. Bd. of Educ. of City of Chi., N.D. Ill., No. 1:23-cv-00218, 4/19/24.

https://news.bloomberglaw.com/us-law-week/ex-students-establishment-clause-claim-can-proceed-as-class

Maharishi Mahesh Yogi and the Controversial Meditation Movement

I Love Docs
June 3, 2023

When a spiritual luminary dies, how do his adherents continue? With intimate access to two of Transcendental Meditation’s new leaders – iconic filmmaker David Lynch and dedicated disciple Bobby Roth – Shadows of Paradise documents the Movement’s metamorphosis following the passing of its founder, Maharishi Mahesh Yogi.

https://youtu.be/v7omqh2JE1E

Establishment Clause Related to School's Transcendental Meditation Program

OK, not really, but the judge partly denied the motion for summary judgment, which would allow it to go to trial.

EUGENE VOLOKH

Reason

May 18, 2023

 

From Williams v. Bd. of Ed., decided Tuesday by Judge Matthew Kennelly (N.D. Ill.):

Williams attended Bogan Computer Technical High School (Bogan) in Chicago from fall 2017 until he graduated on June 18, 2019. While Williams was a student, Bogan implemented the Quiet Time program during the 2017–18 and 2018–19 school years….

According to Williams, his first experience with Transcendental Meditation as a part of the Quiet Time program occurred during the 2018–19 school year, when he was eighteen years old. He stated that he did not receive any letters about the program to give to his parents, but in October 2018 he and other students were given a document titled "Quiet Time Program Student Application for Transcendental Meditation Instruction Bogan High School." He also stated that he had been informed that Transcendental Meditation was "a really effective way to meditate and find yourself" and that he signed the form when it was first presented to him because he "was interested learning [meditation] properly."

Although the document included language stating that "learning the TM technique is an optional activity," Williams maintained it was "not optional" and "mandated" for students to sign the document. He explained that this was because students who initially chose not to learn Transcendental Meditation "eventually had to sign up," though "off the top of [his] head at the [moment]" he was unable to name any student who did not sign the document at first and later "was forced to do [Transcendental Meditation]." As for meditating during the fifteen-minute Quiet Time periods, Williams did not dispute that "if [he] didn't want to do [Transcendental Meditation], [he] didn't have to."

In contrast, Principal Aziz-Sims testified during her deposition that students could choose not to learn Transcendental Meditation. She stated that although students who were disrupting others during Quiet Time may have been reprimanded by a teacher, an administrator, or the principal herself, she was not aware of any Bogan student being disciplined for choosing not to learn Transcendental Meditation. She also testified that she approved giving students at least two letters explaining Quiet Time to their parents and allowing their parents to opt out of the program, in accordance with the school's policy regarding student involvement in other school activities.

Sunita Martin, an independent contractor with DLF [David Lynch Foundation] who was involved in implementing Quiet Time, similarly stated that students were given an "opt-out packet" and instructed to "take it home and give to their parent or guardian so that they could look it over and if their parent was not interested in them learning, then they would return that to us so we could know." Students who were interested in learning Transcendental Meditation "could fill out a one-page form with their name, the classroom that they were in so that we could keep record of who was interested and who was not." Various other employees of the University and DLF also testified that learning Transcendental Meditation was optional and that they did not witness any students being required to meditate during Quiet Time.

Williams signed the consent form and began learning Transcendental Meditation in October 2018. He and other students who learned Transcendental Meditation participated in a training course for one hour each day over the course of four days. On the first day of his training, Williams was present for a three-to-four-minute initiation ceremony. The initiation took place at a classroom at Bogan. It involved a Transcendental Meditation instructor placing assorted items in front of a painting of a man and speaking in Sanskrit. The items varied from one initiation to the next, but could include flowers, fruit, a candle, rice, water, and sandalwood powder. Williams testified that he mostly stood and observed the initiation, but at one point the instructor asked him to repeat words in a language that he did not understand. He stated that when he asked what the words he repeated meant, the instructor informed him that those words did not have any meaning. The instructor also gave Williams a "mantra" on his first day of training and instructed him to repeat it while meditating. Williams said that the instructor told him the mantra "didn't have any meaning" and was a tool to help him relax during meditation. He further testified that the "only thing [the Quiet Time staff] claim[ed]" over the course of the program was that "anything they were showing us had no deep significance to it or meaning behind it and just to do [it]." Students who did not learn Transcendental Meditation were neither present for the initiation nor given a mantra.

On occasion throughout the 2018–19 school year, Transcendental Meditation instructors came to Williams's classroom and led him and other students through a meditation. During those sessions, the instructors rang a bell to start meditation, told the students to think of their mantra during the meditation, and rang another bell to end meditation. Not every student in Williams's class meditated during the instructor-led meditations, and Williams stated that he personally practiced Transcendental Meditation approximately twenty-five percent of the time during the fifteen-minute Quiet Time periods until the spring of 2019.

Around that time, substitute teacher Dasia Skinner approached Williams and informed him that she believed Transcendental Meditation was a religious practice. Williams testified that after speaking with Skinner—who was neither trained in Transcendental Meditation nor involved in implementing Quiet Time—and doing "his own research," he concluded that the mantra he received and the initiation ceremony were related to Hinduism. Williams also agreed, however, that the meditation instructors and Quiet Time program staff did not instruct him to "believe in a particular religion or particular deity." Williams stopped practicing Transcendental Meditation after speaking with Skinner, and he graduated from Bogan when the school year ended on June 18, 2019.

The court allowed Williams' Establishment Clause claim to move forward:

The Court … [concludes that] there is a genuine dispute of material fact and a reasonable jury could—but is not guaranteed to—find that Quiet Time violated the First Amendment….

The defendants contend that Williams has failed to satisfy Kennedy v. Bremerton School District's "historical practices and understandings" test. They point out that Williams at most distinguishes Kennedy on the facts but does not discuss or analyze any historical practices relating to allegedly religious activities in public schools. Yet a historical analysis is not necessary in this case. The Court stated in Kennedy that it did not overrule prior decisions in which "[the Supreme Court] has found prayer involving public school students to be problematically coercive." And the Court stated that it "has long held that government may not, consistent with a historically sensitive understanding of the Establishment Clause, 'make a religious observance compulsory.'" A state actor therefore "may not coerce anyone to attend church" or participate in "a formal religious exercise," and "coercion along these lines was among the foremost hallmarks of religious establishments the framers sought to prohibit when they adopted the First Amendment."

The Seventh Circuit has recognized that one test for evaluating Establishment Clause challenges "is known as the 'coercion' test[,]" and "[t]he Supreme Court has applied this test in school prayer cases." Kennedy's extensive discussion of coercion indicates that this test is still good law, as the decision makes it clear that compulsory prayer or other religious activities in schools do not align with this country's historical practices and understandings. Although "[the Supreme Court] has long recognized as well that 'secondary school students are mature enough … to understand that a school does not endorse,' let alone coerce them to participate in, 'speech that it merely permits on a nondiscriminatory basis[,]' " there is also a "traditional understanding that permitting private speech is not the same thing as coercing others to participate in it." To the extent that a school program or activity that causes "some [to] take offense to certain forms of speech or prayer they are sure to encounter in a society where those activities enjoy such robust constitutional protection[ ]" does not violate the Establishment Clause, the Supreme Court expressly stated that this was because "[o]ffense … does not equate to coercion."

In applying the "coercion" test, the Seventh Circuit appears to have considered several factors, including whether (1) the school "had a captive audience on its hands," (2) there was any "religious activity in which [students] had to partake," and (3) students "felt pressured to support the religious aspects of the [activity] when they saw others … reflecting on the religiosity of the [activity.]" A state actor need not "act with a religious motive in order to fail the coercion test" when it conducts a school activity "in an indisputably religious setting" or chooses to "affirmatively to involve religion in [a] mandatory [activity]." Because there is sufficient evidence to permit a reasonable jury to find in Williams's favor on each of these considerations, the defendants are not entitled to summary judgment on this point.

A reasonable jury could find that the school had a "captive audience" for both the Quiet Time program overall and the Transcendental Meditation initiation ceremony. The defendants do not dispute that Quiet Time was part of the school schedule at Bogan, and students who did not practice Transcendental Meditation were nonetheless present in classrooms when instructor-led meditation occurred. Nothing in the record suggests that students who did not meditate during Quiet Time could leave the classroom or go elsewhere for those fifteen minutes, and Williams testified that an instructor took him to a separate classroom to witness the initiation ceremony. There is conflicting testimony regarding whether it was optional for students to learn Transcendental Meditation and thus experience the initiation. Williams stated during his deposition that it was mandatory to sign up to learn Transcendental Meditation, but Principal Aziz-Sims [and others] … testified that learning and practicing Transcendental Meditation was optional for students. Because "district courts presiding over summary judgment proceedings may not 'weigh conflicting evidence,' or make credibility determinations," the conflicting testimony of the various witnesses is sufficient to create a genuine factual dispute on whether there was a captive audience for at least the initiation ceremony.

That dispute aside, a reasonable jury could find that the program included a "religious activity in which [students] had to partake[.]"Specifically, there is evidence that a Transcendental Meditation instructor separated Williams from his classmates and brought him individually to a different classroom for the initiation. A reasonable jury could find that Williams, having arguably signed up to be trained in Transcendental Meditation, was then required to observe a religious ceremony in order to learn meditation and was misled about the ceremony's religious nature. The scenario as presented by Williams differs from the school prayer cases and the situation in Malnak v. Yogi (3d Cir. 1979), because there was no imposition or mention of any specific beliefs by the defendants. But the initiation ceremony distinguishes this situation from those cases involving the simple practice of Yoga in schools. The evidence in this record—most notably the details of the initiation ceremony—suggest that a reasonable jury could find that the Transcendental Meditation training as implemented was religious in nature or at least included a required religious ceremony.

{The defendants contend that the Court should not focus on "a one-time, three-minute expression of gratitude the instructor performed[,]" citing to the Supreme Court's statement that "[f]ocus exclusively on the religious component of any activity would inevitably lead to its invalidation under the Establishment Clause." Lynch v. Donnelly, 465 U.S. 668 (1984). Yet the statement in Lynch was in reference to a nativity scene in the context of a Christmas display, and the Supreme Court held post-Lynch that even a two-minute prayer was sufficient to violate the Establishment Clause. Lee v. Weisman (1992).}

Lastly, the Seventh Circuit considered in Concord whether students "felt pressured to support the religious aspects of the [activity] when they saw others … reflecting on the religiosity of the [activity]" in deciding whether a school activity was coercive. Freedom From Religion Found., Inc. v. Concord Cmty. Schs. (7th Cir. 2018). A reasonable jury could find that Williams felt pressured to support the purportedly religious aspects of Transcendental Meditation during the initiation ceremony, when he saw various items placed around a picture of a teacher of Transcendental Meditation while the instructor spoke in a language he did not understand. It is less clear whether Williams would have felt pressured to support the instructor-led meditation in the classrooms, as he conceded that he could not tell whether other students were meditating or "reflecting on the religiosity" of the meditation. There is a genuine factual dispute on this point….

[T]he defendants move for summary judgment on compensatory damages, arguing that Williams has not provided sufficient proof of emotional damages. There is no evidence that Williams sought medical or mental health care as a result of his alleged distress from the Quiet Time program, but "an injured person's testimony may, by itself or in conjunction with the circumstances of a given case, be sufficient to establish emotional distress without more." "The more inherently degrading or humiliating the defendant's action is, the more reasonable it is to infer that a person would suffer humiliation or distress from that action; consequently, somewhat more conclusory evidence of emotional distress will be acceptable to support an award for emotional distress." However, "[w]hen the injured plaintiff's testimony is the only proof of emotional damages, [he] must explain the circumstances of [his] injury in reasonable detail; [he] may not rely on conclusory statements."

Williams testified that he experienced mental health challenges and suicidal thoughts prior to participating in the Quiet Time program, but that Transcendental Meditation made his struggles worse. When asked to explain how his condition worsened, Williams stated that "not many know about it, but like I killed a couple animals, I was getting in trouble for starting fires in people's garages, trash every in the alley on fire[.]" He then appeared to clarify that he was referring to animals he had harmed before he learned Transcendental Meditation, but viewing this testimony in Williams's favor as the non-movant, the Court concludes that Williams has described his emotional distress injury in "reasonable detail." Furthermore, if a jury concludes that Transcendental Meditation was a religious practice and that Williams was coerced into learning it, that jury could also reasonably conclude that the experience would be "inherently degrading or humiliating" and accept Williams's more conclusory statements as proof of his emotional distress injury….

EUGENE VOLOKH is the Gary T. Schwartz Distinguished Professor of Law at UCLA. Naturally, his posts here (like the opinions of the other bloggers) are his own, and not endorsed by any educational institution.

https://reason.com/volokh/2023/05/18/establishment-clause-related-to-schools-transcendental-meditation-program-send-to-transcendental-mediation/

CultNEWS101 Articles: 4/21/2022 (Legal, Lori Vallow, The Beatles, India, Maharishi, David Lynch, ICSA Event, Coercive Control, Religious Cultic Groups)

Legal, Lori Vallow, The Beatles, India, Maharishi, David Lynch, ICSA Event, Coercive Control, Religious Cultic Groups

Daily Mail: 'Cult mom' Lori Vallow is now deemed fit to stand trial for the murders of her children, JJ, 7, and Tylee, 17, ten months after she was placed in mental hospital

"The decision on Monday comes almost ten months after Vallow was committed to a psychiatric facility.  

Lori Vallow, 48, and her husband, Chad Daybell, 53, are charged with multiple counts of conspiracy to commit murder and first-degree murder, among other crimes.

The charges are in relation to the deaths of 7-year-old Joshua 'JJ' Vallow, 17-year-old Tylee Ryan - two of Lori Vallow's kids - and Chad Daybell's first wife, Tammy Daybell.  

The children's bodies were found in Chad Daybell's backyard in Idaho in 2020 after they were last seen in September 2019. Tammy Daybell was killed in October 2019, two weeks before Lori Vallow and Chad Daybell married, authorities said.

Vallow is also charged in Arizona with conspiring to kill her former estranged husband, Charles Vallow, with the help of her now-deceased brother, Alex Cox.

Their indictments allege that the couple became convinced that their victims were zombies who had been possessed by dark spirits and could only be released through death.

Vallow was transferred from the custody of Idaho Department of Health and Welfare to the Fremont County Sheriff's Office. She will be arraigned on April 19 at the Fremont County Courthouse."

First Post: The Beatles and India review: Ajoy Bose's documentary is a tender exploration of the band's time in the country

Did you know that George Harrison, lead guitarist of The Beatles, was introduced to the sitar much before Pandit Ravi Shankar came into his life? The guitarist's mother, Louise, used to listen to the sitar on her radio when she was pregnant. The sounds of the strings helped her calm down. No wonder then that Harrison was fascinated by the instrument when he encountered it in his adult life. He had not seen it before but it seemed intimately familiar.

This is one of many delightful anecdotes that emerged when author-filmmaker Ajoy Bose was in conversation with cricket commentator Gautam Bhimani at the Victoria Memorial Hall in Kolkata in the last week of March 2022. The event was part of the Kolkata Literary Meet, which also hosted the India premiere of Bose's documentary The Beatles and India (2021) at The Bengal Club after this conversation. The film draws inspiration from a book called Across the Universe: the Beatles in India (2018) that Bose wrote not so long ago.

I had a chance to watch the film in Kolkata. Bose plans to travel with it across India, so I highly recommend getting yourself to a screening if the film shows up near you. It is certainly a treat for fans of The Beatles but it also appealed to me – a person with little exposure to the music and the colourful lives of John Lennon, Paul McCartney, George Harrison and Ringo Starr.

What drew me in was Bose's exploration of the cultural encounter between East and West – neither a clash, nor a picture of harmony, but fun, messy and real.

Why did these four rock stars from England come to an ashram in Rishikesh in the 1960s? What drew them to Maharishi Mahesh Yogi in particular? How did the guru-shishya relationship change over time? What did they gain from their stay at the ashram? How did the ashram benefit from their fame? When did the trip, both literal and metaphorical, begin to go downhill? Armed with his experience as a journalist, Bose pursues each question rigorously.

He seems completely at home with his research material. This might come as a surprise to those who know that Bose's previous work does not have much to do with music or spirituality. He has written a book on the Emergency imposed by Prime Minister Indira Gandhi from 1975 to 1977, and a biography of the social reformer and politician Mayawati. 

That said, Bose's penchant for politics does sneak into The Beatles and India. He digs up news reports from 1968 when the ashram became notorious for its suspected links to the Central Intelligence Agency (CIA) of the United States of America. The film reveals that the former Soviet Union's security agency Komitet Gosudarstvennoy Bezopasnosti (KGB) sent agent Yuri Bezmenov to ascertain whether the ashram was really a CIA camp or not. Bose has also used footage of Bezmenov talking about how the ashram, instead of supporting the USA's interests, was destabilising American society through Transcendental Meditation.

The heaviness of these moments is tempered with light-hearted ones wherein Indian fans gush about The Beatles. Filmmaker Mahesh Bhatt talks about the influence of their attire on actor Shammi Kapoor. Ajit Singh, Owner of Pratap Music House, Dehradun, recalls preparations made to celebrate Harrison's ex-wife Pattie's birthday at the ashram. Journalist Barkha Dutt shares a photograph of her mother, journalist Prabha Dutt, sitting with the rockstars. She says, "My God, I wish I had been that person sitting between John and Paul."

In addition to these people, the film features excerpts from interviews with santoor maestro Pandit Shivkumar Sharma, musician Susmit Bose, biographer-historian Steve Turner, actor-musician Monica Dogra, singer-composer-producer Biddu Appaiah, and Naresh Fernandes, who is the author of the book Taj Mahal Foxtrot: The Story of Bombay's Jazz Age (2012). 

One of the most unusual anecdotes, however, comes from journalist Saeed Naqvi. He wanted to be the first one to get access to the Beatles, and write about their experience at the ashram. He wondered whether the Beatles were on a genuine spiritual quest or if they were just following a fad. Naqvi could find out only by becoming an insider. He entered the ashram, professing an interest in becoming a disciple of Maharishi Mahesh Yogi. How did Naqvi manage to bring photographer Raghu Rai into the ashram? Watch the film to find out.

The sequence in the film that I found most moving was a brief interaction with Indra Srivastava, who is introduced as "ashram manager's wife." She says, "Jab Beatles aaye, tab unka poora rehne aur khaane ka intezaam hum karte the. Kachcha gobhi, tamatar, salad aisi cheezein zyaada pasand karte the. Paani ki jagah Coca Cola bohot peete the." (When the Beatles came here, we used to take care of their stay and food. They used to like eating raw cabbage, tomato, and salad. They preferred to drink a lot of Coca Cola in place of water.)

This tender recollection is special because it captures the perspective of someone who is not a celebrity. She beams with joy when she remembers how respectfully they used to greet her with a 'Namaste' every time they met her. According to Srivastava, the Beatles made a sincere effort to understand the cultural norms in the country that they had come to as guests. They did not have left on a happy note, but that was mostly because of their spat with Maharishi Mahesh Yogi who turned out to be a disappointment for most, if not all, of them.

In a nutshell, Bose has made a documentary that is thought-provoking and highly entertaining. He would not have been able to accomplish this without cultural researcher Peter Compton, who co-directed the film and sourced much of the archival footage, as well as Reynold D'Silva – head of Silva Screen Music Group – who produced the film. 

Techno Trenz: When John Lennon abruptly left India after hearing Maharishi Mahesh Yogi rumors, the Beatles were perplexed.

"When John confronted the guru аbout the rumor, he аppeаred to confirm it.

"There wаs а big hullаbаloo аbout [Mаhаrishi] trying to rаpe Miа Fаrrow or getting off with Miа Fаrrow аnd а few other women, things like thаt," he told Rolling Stone (аccording to the Beаtles Bible). And we went down to him аfter hаving spent the entire night debаting whether it wаs true or not.

"When George begаn to doubt it, I thought to myself, 'Well, it must be true, becаuse if George is doubting it, there must be something in it.' So the next dаy, the whole gаng of us chаrged down to Mаhаrishi's hut, his very rich-looking bungаlow in the mountаins.'

"I wаs the spokesmаn – аs usuаl, when the dirty work cаme, I actually hаd to be leаder, whаtever the scene wаs, I hаd to do the speаking." "We're leаving," I аnnounced.

"'Why?' Hee-hee, hee-hee, аll thаt nonsense. 'Well, if you're thаt cosmic, you'll understаnd why,' I replied. He wаs constаntly hinting, аnd his right-hand men were all hinting thаt he performed mirаcles. 'I don't know why, you must tell me,' he sаid, аnd I just kept sаying, 'You know why,' аnd he gаve me а look like, 'I'll kill you, bаstаrd,' аnd I knew it wаs becаuse I'd cаlled his bluff. I was a little hаrsh with him."

John immediately left Indiа аfter thаt. On George's аdvice, he renаmed his poem "Mаhаrishi" to 'Sexy Sаdie.'"

NME: David Lynch launches $500million Transcendental Meditation program

The director hopes the new initiative will bring about "a world at peace"

"The Twin Peaks and Mulholland Drive director announced the initiative on Thursday (April 14) to fund Transcendental Meditation (TM) training for 30,000 international college students, hoping to inspire the next generation to "become advanced peace-creating meditation experts and build a legacy of lasting global peace," according to a press release.

Launched in partnership with the Global Union of Scientists for Peace, the program plans to invest approximately $500 million in its first year." 

 

ICSA Annual Conference: Former members' process of recognizing and coping with experience of coercive control in religious cultic groups

Céleste Goguen, Marie-Andrée Pelland; Sunday, June 26, 2022; 12:00 PM-12:50 PM

The aim of this presentation is to analyze the process by which former members recognized and named forms of control, experiences of abuse and experiences of violence during her or his life within a religious cultic group after leaving the group. The analysis will include all forms of control «grounded in relational interactions, namely, behavioural tactics in which perpetrators gain and maintain power over their victims» (Duran and al., 2020: 145). It is also aimed to analyze the informal or formal help or services contacted to cope with the recognized victimization. Research on victimization in cultic groups defines with precision the process of control that can be experienced within cultic groups (Rodriguez-Carbeillera & al., 2015) such as brainwashing (Banisadr, 2014, Stein, 2016) thought reform (Langone, 2017), Bounded Choice (Lalich & McLaren, 2018) or Mind control, BITE model (Hassan, 2021). Some researches document forms of abuse within the group such as neglect, abandonment, isolation, emotional and social deprivation, and sexual abuse (Derocher 2018; Rodriguez-Carbeillera et al., 2015). Other research identifies consequences experienced by former members after they quit a cultic group such as psychological distress (Almendros & Escartin, 2017), difficulties to construct or reconstruct their identity (Matthews & Salazar, 2014 ; Salande & Perkins, 2011 ; Kern & Jungbauer, 2020), difficulties to find a job and to thrive financially (Matthews & Salazar, 2014), fear of being judged judge (Boeri & Boeri, 2009 ; Matthews & Salazar, 2014), even a sense of guilt about behaviours they had within the group (Coates, 2010). But research rarely analyzed the process by which a person's names and recognizes abusive experiences. To explore that gap in knowledge, the life trajectory and narrative of ten former members were collected. Participants recruited were mostly former members of patriarchal communities where gender roles were traditionally defined (Gillian, 2018).

Céleste Goguen est étudiante à la maitrise en sciences sociales à l'Université de Moncton. Également, elle tient une majeure en criminologie à l'Université de Moncton. Dans le cadre de son projet de fins d'études, elle analyse la victimisation en contexte sectaire au Canada.

Marie-Andrée Pelland, PhD, full professor and director of the sociology and criminology Department, Université de Moncton, New Brunswick, Canada. She is also Vice-president of Info-Cult She received her doctorate from the School of Criminology of the Université de Montréal. Her dissertation is entitled, Allegations of Illegal Conduct: Effect on Social Reality of a Community of Canadian Polygamous Mormons. Marie-Andrée Pelland, PhD, est professeure agrégée et directrice du département de sociologie et de criminologie de l'Université de Moncton au Nouveau-Brunswick, Canada. Elle est également vice-présidente d'Info-Secte. Elle a obtenu son diplôme de 3e cycle de l'École de criminologie de l'Université de Montréal. Ses travaux traitent de la question de l'effet des conflits avec la société sur le fonctionnement des groupes religieux minoritaires. Sa thèse s'intitule : « Allégations d'entorse aux lois : Effets sur la réalité sociale d'un groupe de mormons polygames canadiens ».

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