CultNEWS101 News: 7/28/2026

Updates

Correction to yesterday's newsletter:

The study link: Experiences and Perspectives on Mental Health Support Among Survivors of High-Control Environments

Lalich Center on Cults and Coercion

Legislative & Legal

Korea Herald: Prosecutors file new charges against Shincheonji leader's alleged plot to sway party primaries

South Korean prosecutors filed additional charges on Monday against Lee Man-hee, the 95-year-old founder of the Shincheonji Church of Jesus, for allegedly orchestrating a massive political infiltration campaign. A joint investigation claims Lee directed followers to join the conservative People Power Party between 2021 and 2024 to sway primary elections and leadership races illegally

Lee, currently detained following his arrest last month, is officially charged with pressuring followers and interfering in party affairs.

Three former senior church officials, including a former second-in-command, are also detained, while four others were charged without custody. Investigators estimate that over 56,000 Shincheonji members joined the party ahead of the 2021 presidential primary, the 2023 leadership contest, and the 2024 parliamentary nominations.

Notably, investigators found that a former church official provided a roster of these newly registered voters to a campaign aide for Yoon Suk Yeol, who subsequently won the 2021 primary and the presidency. No charges were filed in connection with this specific exchange.

Shincheonji, widely characterized as a cult by mainstream Christian denominations, previously drew intense national backlash in 2020 after a major COVID-19 outbreak was linked to its congregation, which resulted in Lee's prior conviction for embezzlement.

Sociological Perspectives: "Australia's 'Cults Crisis'? Some Recent Developments in the 'Cult Scene' 2000–2025," detailing the shift in academic discourse and the media's framing of new religious movements versus high-control groups.

The Resurgence of the "Cult" Narrative

Doherty examines the dramatic return of "cults" to the forefront of the Australian cultural imagination. After a period of relative quiet, fringe religious groups have once again become headline news, driven by an explosion of true-crime podcasts, television exposés, and online activism. This heightened public concern has achieved significant political traction, most notably sparking the ongoing parliamentary inquiry into fringe groups in the State of Victoria.

The Drivers of the "Crisis"

Using a contextual constructionist framework, Doherty argues that the perception of a national "cults crisis" is a socially constructed phenomenon. He identifies the primary driver of this resurgence as a new, highly effective generation of media-savvy anti-cult activists. Unlike past decades, this movement is heavily led by Second Generation Adults (SGAs)—individuals who were born and raised in these groups. By partnering with journalists and leveraging digital platforms, these survivors have successfully centralized their narratives and shifted public perception.

Rhetoric vs. Reality

Crucially, Doherty does not dismiss the reality of survivor trauma or deny that some high-control groups engage in documented criminality and abuse. However, he argues that framing the current landscape as a sweeping, unprecedented "crisis" is an unhelpful exaggeration akin to a moral panic. He cautions against the recent trend of importing domestic violence terminology—specifically "coercive control"—into cultic studies, viewing it as a modern repackaging of historically flawed "brainwashing" rhetoric.

Conclusion

Ultimately, the paper concludes that the Australian "cult problem" is cyclical, often reflecting broader societal anxieties rather than a sudden, objective increase in dangerous organizations. Doherty advocates for a nuanced, sociological approach that investigates legitimate criminal behavior without succumbing to media sensationalism or broadly stigmatizing minority religious movements.

Freedom For Faith: Victorian Inquiry into Cults

Here is a summary of the article from Freedom for Faith:

In their response to the Victorian Government’s inquiry into cults and coercive control, the Christian legal think tank Freedom for Faith outlines significant concerns about potential threats to religious liberty in Australia. While commending the effort to protect individuals from genuine harm, the organization warns that poorly defined terms like "coercion" and "harm" could inadvertently stigmatize or criminalize mainstream, high-commitment religious practices and conservative theology.

Freedom for Faith has actively engaged in the inquiry by coordinating a joint submission from Victorian church leaders and testifying before the Committee. Their primary argument centers on the necessity of distinguishing voluntary religious devotion from actual abuse. The organization identifies several key threats to religious freedom:

• Expanding "Cult" Definitions: They argue that broadening the term risks misclassifying mainstream groups that simply hold exclusive truth claims or structured communal lives.

• Misusing "Coercive Control": The group asserts that applying this concept to standard religious teachings—such as sacrifice or salvation—conflates voluntary participation with genuine manipulation.

• Mislabeling Behaviors: Common religious practices, such as offering a sense of belonging or promoting spiritual transformation, are at risk of being unfairly scrutinized as "cultic tactics."

• Media Narratives: The organization warns that sensationalized media increasingly and unfairly frame evangelical Christianity as inherently coercive.

Ultimately, Freedom for Faith reminds the government of its obligations under international human rights law (ICCPR) to protect the freedom of belief. They urge the Committee to focus on policing existing criminal offenses rather than legislating against sincerely held religious beliefs or voluntary moral discipline.

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CultNEWS101 News: 7/7/2026

Culture & Media

Videos

Biography: David Koresh and the Raid That Shook America

"Followers from around the world travel to Mount Carmel to hear the preaching of David Koresh, a local Texas working-class kid turned prophet of God and leader of the religious group The Branch Davidians. But as Koresh's teachings become more and more apocalyptic, members of the group question his motives, in this full documentary, 'Waco: Madman or Messiah.'"

Updates

Amnesty International: China: Detention of church leaders signals intensifying attacks on religious freedom

"...The Early Rain Covenant Church said on Monday it was raided by armed police midway through its Sunday service in the south-western city of Jiangyou, Sichuan province.

Spokespersons for the church said more than 30 members were taken away for interrogation, and two leaders remain detained. A church messaging account shared photographs and videos that show congregants surrounded by SWAT (Special Weapons and Tactical Unit) officers.

Founded in 2005, the Early Rain Covenant Church is one of the largest and most prominent “house churches” in China. In December 2018, authorities carried out a large-scale crackdown on the church, detaining more than 100 members. The church’s founding pastor Wang Yi was later convicted of “inciting subversion of state power” and “illegal business operations” and sentenced to nine years’ imprisonment in December 2019.

Tricked into Trance: How Cults Misuse Meditation and Hypnosis for Mind Control and Exploitation of Followers

"Tricked into Trance: How Cults Misuse Meditation and Hypnosis for Mind Control and Exploitation of Followers" argues that high-control groups weaponize altered states of consciousness to bypass followers' critical thinking. While these states can promote healing in healthy contexts, the article posits that cults use them to implement sophisticated psychological manipulation.

The author explains that intense meditation quiets the brain’s Default Mode Network (DMN)—which governs ego, skepticism, and boundaries—leaving the subconscious highly vulnerable. By inducing this state, leaders can plant ideologies, demand obedience, and foster dependency without resistance.

The process is often accelerated through forced, intensive breathing exercises. This practice—hyperventilation followed by breath retention—alters blood chemistry, constricts cerebral blood vessels, and forces the brain into theta- and delta-wave states. Physiologically, this starves the "security guard" of the critical mind, rendering the participant unable to analyze or question incoming information.

Consequently, followers transition from an intense, euphoric experience into a state of profound suggestibility. Manipulators exploit this by framing the resulting feelings of peace as a product of the leader's "grace." This shifts a natural physiological response into a perceived supernatural blessing, transforming feelings of gratitude into absolute, unquestioning obligation toward the organization and its leadership. Ultimately, the article warns that individuals may appear fully functional on the outside while their internal values, reality, and life choices are being systematically dictated by the cult's indoctrination process.

Five takeaways: Star investigation into alleged Southern Arizona 'cult'

An Arizona Daily Star investigation has brought significant scrutiny to the Global Community Communications Alliance (GCCA), a religious group based near Tumacacori, Arizona. Often described by former members as a "cult," the organization faces allegations of high-control tactics and exploitation.

The investigation highlights five key takeaways regarding the group's operations:

1. Forced Labor Allegations: Former members have filed lawsuits claiming they were subjected to long, unpaid workdays as a condition of membership. Allegations suggest that children within the community were also expected to perform manual labor, with schooling being minimal and focused primarily on indoctrination.

2. Highly Profitable Hospice: The GCCA operates Soulistic Hospice, which has become a significant financial engine for the group. Between 2021 and 2024, the hospice generated roughly $12 million in annual revenue, primarily through Medicare.

3. Large Financial Transfers: From 2010 to 2024, the hospice transferred nearly `$35 million in grants to the GCCA. This resulted in an approximate 34% profit margin, a figure significantly higher than the national average for hospices, which often operate with much narrower or negative margins.

4. Defensive Response: The GCCA has formally denied all allegations of wrongdoing. In a written statement, the group maintained that membership is a voluntary commitment made after a six-month trial period, asserting that members willingly contribute their labor to sustain the community.

5. Closed Campus Environment: Legal filings characterize the GCCA as a high-control, closed-campus religious group. These reports reinforce the testimonies of former members who describe a life defined by strict adherence to the group's mission at the expense of personal autonomy.

AI Research Disclosure: To bring you the most relevant stories, parts of this newsletter utilize artificial intelligence (AI) tools to search the web, source articles, and assist with content curation. This content is for informational purposes only; we recommend verifying critical facts independently.

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

Please forward articles you think we should add to cultintervention@gmail.com.

CultNEWS101 Articles: 9/3/2025

Premanand Maharaj, India,  Guru Wars, Legal,  Zizians, Singularism, Religious Freedom

LatestLY: Jagadguru Rambhadracharya Makes Open Challenge to Premanand Maharaj, Says 'Speak Even One Word of Sanskrit or Explain the Meaning of Sanskrit Shlokas That I Have Said' 

Spiritual leader Jagadguru Rambhadracharya has challenged Premanand Maharaj over his knowledge of Sanskrit. In an interview that went viral on social media, Jagadguru Rambhadracharya also said he does not consider Premanand Maharaj a miraculous saint. A viral clip shows Rambhadracharya giving Premanand Maharaj an open challenge and saying that if he is really miraculous, then he should come in front of him and speak in Sanskrit. When asked about Premanand Maharaj, Jagadguru Rambhadracharya told journalist Shubhankar Mishra, "There is no miracle. If there is any miracle, then I challenge Premanand Maharaj to speak even one word of Sanskrit in front of me or explain the meaning of the Sanskrit shlokas that I have said. Today I am openly saying that he is like my child. It is a miracle that he knows the scriptures. He is living on dialysis." As the video moves further, Jagadguru Rambhadracharya says that he considers Premanand Maharaj like his child. "I am neither calling him a scholar nor a miracle worker. Such popularity lasts only for a few days. However, saying that this is a miracle is not acceptable to me. Sing bhajans and read and write," Jagadguru Rambhadracharya added.

AP: Prosecutors seek death penalty against cult member linked to Chatham County raid, border agent's death

"The Justice Department said Thursday it will seek the death penalty against a member of the cultlike Zizians group accused of killing a U.S. Border Patrol agent in Vermont in the latest Trump administration push for more federal executions.

Teresa Youngblut, 21, of Seattle, is among a group of radical computer scientists focused on veganism, gender identity and artificial intelligence who have been linked to six killings in three states. She rented a house in rural Chatham County raided in February by FBI agents.

She's accused of fatally shooting agent David Maland on Jan. 20, the same day President Donald Trump was inaugurated and signed a sweeping executive order lifting the moratorium on federal executions.

Youngblut initially was charged with using a deadly weapon against law enforcement and discharging a firearm during an assault with a deadly weapon. But the Trump administration signaled early on that more serious charges were coming, and a new indictment released Thursday charged her with murder of a federal law enforcement agent, assaulting other agents with a deadly weapon and related firearms offenses.

"We will not stand for such attacks on the men and women who protect our communities and borders," Acting Assistant Attorney General Matthew Galeotti said in a press release."

KJZZ: Singularism, a religion that uses psychedelic drugs, is testing Utah's religious freedom law

"Last year, Utah lawmakers passed the Religious Freedom Restoration Act, which gives people more power to challenge the government if it interferes with their religious beliefs.

Religious freedom is, in many ways, the backbone of the major religion in Utah — the Church of Jesus Christ of Latter-day Saints — and the Republican-sponsored measure passed easily.

But that law is being put to the test in the courts by an unexpected group — a very small religion that's been targeted by law enforcement for using psychedelic drugs as part of its practices. The religion is called Singularism.

In 2023, police carried out a warrant at its Provo headquarters, seizing its sacramental psilocybin and, later, hitting its founder with criminal charges. Singularism founder Bridger Jensen is suing, and citing this religious freedom law as his argument."

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CultNEWS101 Articles: 12/3/2024 (Scientology, Millah Abraham, Malaysia, Legal, Misinformation )

Scientology, Millah Abraham, Malaysia, Legal, Misinformation 

ENDEVR Documentary: The Dark Side of the Scientology Cult

"It is one of the world's most secretive and controversial cults… brought to light by one of Hollywood's biggest stars, Tom Cruise. Since its creation in 1953, Scientology has won millions of disciples, up to 40,000 in France alone, according to its leaders.

Scientologists follow the teachings of a former bestselling Science Fiction author, L. Ron Hubbard. They believe in reincarnation and undergo extraordinary practices to gain enlightenment. Scientology is also an institution plagued by headline-grabbing scandals when former members go public about their experiences with the sect. While it is recognized as a religion in some countries, others consider it a dangerous cult.

How does this organization, often convicted of fraud, manage to recruit and retain followers? What are its beliefs? Who was L. Ron Hubbard, its charismatic proto-messiah? How did Scientology become a recognized religion in the United States? And what influence does it have in France? Join experts and former high-ranking scientology members as they unmask one of the most powerful self-proclaimed religious organizations on the planet… the church of scientology."

Free Malaysia Today: 8 suspected Millah Abraham cult followers arrested in Melaka

"Three married couples and two men were detained during a midnight raid on a house here on suspicion of being followers of the deviant Millah Abraham sect.

Melaka education, higher education and religious affairs committee chairman Rahmad Mariman said the suspects, aged between 28 and 71, were retired civil servants, private sector workers, self-employed and housewives.

"The authorities received a public complaint about the spread and practice of the Millah Abraham teachings, which have been declared deviant and contrary to Islamic teachings in Melaka through a fatwa.

"A raid was carried out by 70 Melaka Islamic religious department staff and police officers to inspect and search the house believed to be occupied by Millah Abraham followers," he said in a statement here today."

Study: Misinformation exploits outrage to spread online.

Misinformation evokes much more outrage than trustworthy news sources do, outrage facilitates the spread of misinformation, and people are much more willing to share outrage-evoking misinformation without even reading it first.

Don't spread misinformation! But how would you know?

Science: Misinformation exploits outrage to spread online

Misinformation evokes much more outrage than trustworthy news sources do, outrage facilitates the spread of misinformation, and people are much more willing to share outrage-evoking misinformation without even reading it first.

News, Education, Intervention, Recovery

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Intervention101.com to help families and friends understand and effectively respond to the complexity of a loved one's cult involvement.

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Thanks

Top rights court upholds Swiss ban on UFO group's posters

AFP News

13 July 2012

Members of the Raelian movement take part at a ceremony in front of the bronze statue of Giordano Bruno in downtown Rome in 2004. More than a decade after Swiss police barred a UFO religious group from putting up posters depicting aliens, Europe's top rights court ruled Friday the sect's free speech had not been violated.

Raelian movement founder Claude Vorilhon, also known as Rael, answers questions during a press conference in 2004. More than a decade after Swiss police barred a UFO religious group from putting up posters depicting aliens, Europe's top rights court ruled Friday the sect's free speech had not been violated.

More than a decade after Swiss police barred a UFO religious group from putting up posters depicting aliens, Europe's top rights court ruled Friday the sect's free speech had not been violated. Police in the Swiss canton of Neuchatel in 2001 banned the Raelian group, which claims aliens created life on earth, from putting up the posters.

The local ban came after other authorities in Switzerland had allowed the posters. Neuchatel officials said the posters presented a public order threat because Raelians promote human cloning and "geniocracy," a system where leaders are picked according to their intelligence.

Additionally, a Swiss court found the Raelians had "theoretically" advocated paedophilia and incest, the European Court of Human Rights said in a statement Friday. The group had also been the subject of criminal complaints about sexual practices involving children, the court said. Swiss high courts affirmed the ban and Europe's top rights court in January 2011 upheld the decision. The Raelians then appealed the Strasbourg-based court's decision, ultimately winning an appeal for the Grand Chamber to hear the case. The 17-member chamber ruled Friday, nine to eight, that the Raelians' freedom of expression was not violated. "Authorities had not overstepped the broad margin of appreciation given to them in view of the non-political dimension of the poster campaign," the court said. At a November hearing, a lawyer for the Raelians argued that cloning is not illegal. He said the religious movement had repeatedly condemned all acts of paedophilia and said it was contradictory to ban a poster when neither the sect nor the website were barred. The court also noted the ban only applied to putting posters on public property, "allowing the association to use other means of expression." The Geneva-based sect, which claims tens of thousands of members worldwide, was founded in 1976 by Claude Vorilhon, known as "Rael". According to its constitution, the group aims to make the first contacts and establish good relations with extraterrestrials. The poster in question was about one-metre (three feet) tall and across the top in big letters were the words: "The Message from Extraterrestrials", according to the court. Underneath was the Raelians' web address, a French phone number and the phrase: "Science at last replaces religion." The middle of the poster showed alien faces and a pyramid, together with a flying saucer and the Earth.

https://sg.news.yahoo.com/top-rights-court-upholds-swiss-ban-ufo-groups-170347355.html

CultNEWS101 Articles: 5/10/2024 (Geelong Revival Centre, Clergy Sexual Abuse, Transcendental Meditation, Legal, Religious Freedom)

Geelong Revival Centre, Clergy Sexual Abuse, Transcendental Meditation, Legal, Religious Freedom

Geelong Advertiser: Geelong Revival Centre church leader Noel Hollins receiving medical treatment as leadership change looms

"Leadership changes loom at a shadowy, ultra-conservative Geelong church as former members hit out at the contradictory behaviour of its long-serving pastor.

A controversial Pentecostal Geelong church described by some as a "cult" is facing a forced leadership change, with its 93-year-old founder and long-term leader gravely ill, according to multiple sources."

RNS: Why faith-based groups are prone to sexual abuse and how they can get ahead of it

As Sexual Assault Awareness Month comes to a close, there are a few steps experts say every faith group can take to improve safeguarding protocols.

" .. With more victims coming forward and more research done on abuse within religious contexts, the evidence has shown that when sexual abuse happens in a place designated not only safe, but holy, it's a unique form of betrayal — and when the perpetrator is a clergy member or spiritual leader, the abuse can be seen as God-endorsed.

As the scope of this crisis has been revealed, houses of worship and religious institutions — from Southern Baptists to Orthodox Jews to American atheists — have looked to shore up their safeguarding protocols and protect their constituents against abuse.

But rather than scrambling to respond in the wake of a crisis, faith groups need to adopt policies tailored to their setting and connected to their mission, says Kathleen McChesney, who was the first executive director of the Office of Child Protection for the U.S. Conference of Catholic Bishops."

LifeSite: Christian student gets $150k judgement in lawsuit stating she was forced to participate in Hindu rituals at Chicago school

"A high school student recently obtained a judgment in the amount of $150,000 that was entered in her favor and against the Chicago school system, which forced her to participate in Hindu practices, amounting to idolatry in violation of her Christian beliefs.

The Board of Education of Chicago, the University of Chicago, and the David Lynch Foundation were sued by Mariyah Green, a former student at Bogan High School, for mandating student participation in Hindu rituals, despite conflicting religious beliefs. She was granted a $150,000 judgement on October 23 by the clerk of the United States District Court for the Northern District of Illinois.

Bogan students were required to participate in a program titled "Quiet Time," which consisted of two 15-minute periods each day dedicated to the practice of "transcendental meditation" (TM), which was popularized by Hindu guru Maharishi Mahesh Yogi and involves concepts used in Hinduism, such as mantras.

Green, a 2020 high school graduate, told LifeSiteNews in a phone interview that in addition to the 15-minute periods of "meditation" each day, the school sponsored a three-day class to teach students "the way that they want you to meditate."

During the 2018-2019 school year, Green attended the first day of this three-day lesson, which she described as "very uncomfortable." Students came into a "completely dark" classroom with "curtains closed [and] candles around the picture of [a] man," which had been placed on a table in front of them.  

"I was actually scared for a moment, like, what is going on? Why are the lights off? Why do the candles light the man? Of course, the picture kind of threw me off because it wasn't [anything] that I had ever seen."

Additionally, Green and her peers were instructed to "repeat a mantra" that they were told to keep "to yourself." After the first day, Green told LifeSiteNews that she was able to opt out of future participation in the three-day lessons by avoiding going to the class, but not the 15-minute periods each day.

Aside from teachers casually asking when she would be returning to the class, she didn't receive backlash for opting out of the lessons. She described them as "nice people, but it was against my religion."

On the other hand, the "very mandatory" 15-minute slots designated for TM were linked to student grades, leaving Green feeling obligated to participate so she wouldn't lose the academic standards required for her to play basketball at the school. During these times, Green said she "didn't do it their way" and "didn't keep the mantra in my head," instead closing her eyes so it "looked like I was meditating" to receive the participation credit."

" ... Over the past few years, multiple lawsuits have been filed against DLF accusing the organization of being aware of TM's link to Hinduism and enforcing the practice of worshipping idols rather than allowing students to read or rest during the 15-minute 'quiet time."'"

LifeSite: Student reportedly forced into Hindu rituals at Chicago school granted class action status

"A former Chicago public school student alleges that her school coerced her into Transcendental Meditation and Hindu practices, including a ritual invoking pagan gods, as part of a program run by the David Lynch Foundation.

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 that 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."

" ... 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.'"

News, Education, Intervention, Recovery

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Intervention101.com to help families and friends understand and effectively respond to the complexity of a loved one's cult involvement.

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How after-school clubs became a new battleground in the Satanic Temple's push to preserve separation of church and state

The Conversation
July 21, 2023


Author: Charles J. Russo, 
Joseph Panzer Chair in Education and Research Professor of Law, University of Dayton

Disclosure statement

Charles J. Russo does not work for, consult, own shares in or receive funding from any company or organisation that would benefit from this article, and has disclosed no relevant affiliations beyond their academic appointment.

As the start of the school year rapidly approaches, controversy can’t be far behind. But not all hot-button topics in education are about what goes on in class.

Over the past few years, conflict has trailed attempts to establish After School Satan Clubs sponsored by the Satanic Temple, which the U.S. government recognizes as a religious group.

Organizers have tried to form clubs in California, Colorado, Illinois, New York, Ohio, Pennsylvania and Virginia. Organizers in Broome County, New York, also formed a summer Satan Club that meets at a local library.

Though there are estimates that only a handful of Satan Clubs are up and running, the groups raise significant questions about freedom of speech in K-12 public schools, particularly around religious issues – topics I teach and write about frequently as a faculty member specializing in education law.

More ‘science’ than ‘Satan"

Members of the Satanic Temple, which was founded in 2013, do not profess beliefs about supernatural beings. The group emphasizes “the seven tenets,” which celebrate ideas like rationality, compassion and bodily autonomy.

What often draws attention, though, are the temple’s political and legal activities. The group has a history of filing suits to try to gain the same rights afforded to Christian groups, in an attempt to highlight and critique religion’s role in American society.

Because organizers of Satan Clubs object to introducing religion into public education, they try to offer an alternative at schools hosting faith-based extracurricular groups. The Satanic Temple promotes clubs that focus on science, critical thinking, free inquiry and community projects, emphasizing that “no proselytization or religious instruction takes place” in meetings.

Litigation around Satan Clubs arose in 2023 when a school board in Pennsylvania refused to allow a club to meet in an elementary school. In May, a federal trial court ruled that the school board could not ban the club, since it allowed other types of clubs. By allowing groups to use school facilities, the court explained, officials had created a public forum. Therefore, excluding any group because of its views would constitute discrimination, violating organizers’ First Amendment rights to freedom of speech.

Equal access

The principle that all student-organized extracurricular groups have equal access to educational facilities was established in 1981 with Widmar v. Vincent, a dispute from a public university in Kansas City, Missouri. The Supreme Court determined that once campus officials had created a forum for the free exchange of ideas by student groups, they could not prevent a faith-based club from meeting solely due to the religious content of its speech.

That requirement was extended to secondary schools under the Equal Access Act, which Congress adopted in 1984. The act applies to public secondary schools where educators create “limited open fora,” meaning non-instructional time when clubs run by students, not school staff, are allowed to meet. Officials cannot deny clubs opportunities to gather due to “the religious, political, philosophical, or other content of the speech at such meetings.”

The Equal Access Act specifies that voluntary, student-initiated clubs cannot “materially or substantially interfere” with educational activities. Further, groups cannot be sponsored by school officials, and educators may only be present if they do not participate directly. Finally, the act forbids people who are not affiliated with the school, such as local residents or parents, from directing, conducting, controlling or regularly attending club activities.

The Supreme Court upheld and extended the Equal Access Act’s logic in two major cases. In 1990’s Board of Education of Westside Community Schools v. Mergens, for example, the justices reasoned that because allowing a religious club in a public school in Nebraska did not endorse religion, it had to be permitted. Afterward, federal courts in California, Indiana, Florida and Kentucky expanded the act’s reach to GSA Clubs, formerly known as Gay-Straight Alliances – clarifying that “viewpoint discrimination” was impermissible against other nonreligious clubs.

In the recent dispute from Pennsylvania, the Satan Club’s organizers relied on Good News Club v. Milford Central School, a 2001 case from New York. The dispute arose when a school board refused to permit the Good News Club – a non-school-sponsored, faith-based group that has several thousand branches in the U.S. – to meet after class with participants’ parental consent. Yet officials allowed the Boy Scouts, Girl Scouts and 4-H Club to meet and talk about similar topics from secular points of view in an elementary school, so the Supreme Court decided that its refusal constituted unlawful viewpoint discrimination. Given students’ ages, parents or other adults are allowed to be involved in elementary school activities.

Expose children to new ideas?

Following the Equal Access Act, some boards banned all non-curriculum-related clubs in attempts to avoid controversy. Perhaps the Pennsylvania board will go this route as well.

In an increasingly intellectually diverse world, though, children are bound to encounter ideas with which they disagree – and I would argue each encounter can sharpen their critical thinking. As a federal trial court judge in Missouri once observed, provocative speech “is most in need of the protections of the First Amendment. … The First Amendment was designed for this very purpose.”



https://theconversation.com/how-after-school-clubs-became-a-new-battleground-in-the-satanic-temples-push-to-preserve-separation-of-church-and-state-209579

DEFINING RELIGION IN THE COURT

Mark Movsesian
First Things
June 2023

Here is a snapshot that captures an increasingly important issue in law and religion in the United States: In August 2021, four parents sued a school district outside Philadelphia for violating the free exercise rights of their children. In response to the Covid-19 pandemic, the district had required all students to wear masks and refused to allow religious exemptions. The parents—from four separate households—argued that covering the face violated their religions, and that the district’s requirement therefore violated the First Amendment.

In one sense, Geerlings v. Tredyffrin/Easttown School District was nothing new. Several lawsuits across the country had claimed, with varying degrees of success, that anti-Covid measures violated the Free Exercise Clause. But the Pennsylvania lawsuit was atypical in one important respect. Unlike the plaintiffs in most cases, who based their objections to anti-Covid measures in the teachings and practices of traditional religious communities—churches and synagogues—the Geerlings parents raised objections that were rather idiosyncratic.

Two of the parents belonged to no religion but described themselves as “spiritual.” Of these two, one believed in “something else out there,” not “just us,” which convinced him that his daughter should not wear a mask; the other maintained that masks mocked “the gift of life.” Two parents were Christians with unusual beliefs. The first, a deacon in a local Presbyterian church that had itself required masks during the pandemic, stated that, in her view, masks dishonored God. The other, an Episcopalian whose parish likewise had required masks during the pandemic, maintained that masks violated the “temple” of the body. Both of these plaintiffs apparently stopped attending services when their churches began to require masks.

With some hesitation, the court concluded that none of these claims qualified as “religious” for First Amendment purposes. Even if the parents’ objections were sincere, Judge Mitchell Goldberg wrote, they were too idiosyncratic to merit constitutional protection. Goldberg conceded that a claimant need not belong to an organized religion or hold the same beliefs as others in order to raise a free exercise claim. But there were limits. The First Amendment did not require exemptions for plaintiffs who objected to legal requirements on the basis of personal intuitions that failed to correspond with the teachings of any religion.

Judge Goldberg’s hesitation was understandable. The Supreme Court has never settled on a definition of religion, and its decisions down the centuries point in different directions. Some of the Court’s rulings indicate that idiosyncratic personal convictions can qualify as religious; others suggest the opposite. Until recently, the question has been mostly academic. Although solitary seekers like Henry ­David Thoreau have always been with us, most Americans have tended to identify with specific religious traditions. Few have sought legal exemptions based on purely personal spiritual commitments.

That seems likely to change. A fast-growing percentage of Americans, the so-called “Nones,” now tell pollsters that they have no religious ­affiliation—roughly 30 percent of the population, up from only 6 percent a generation ago. Like the first two Geerlings plaintiffs, most Nones are what one might call unaffiliated believers, people who reject organized religion but believe in “something else out there” and follow their own spiritual paths. Moreover, many Americans retain formal religious affiliations but combine orthodox teachings with other commitments, like the Christian parents in Geerlings who objected to face coverings on ­spiritual grounds. Tara Isabella Burton refers to this group as “religious hybrids.” Together with unaffiliated believers, she estimates, they may amount to more than 50 percent of the American population.

Geerlings is not the only recent case in which unaffiliated believers and religious hybrids have sought religious exemptions—and it will not be the last. Simply put, there are a lot more Henry ­David Thoreaus than there used to be, and some of them seem quite litigious. The time is ripe for the Supreme Court to clarify the meaning of “religion” for free exercise purposes—specifically, to clarify whether it covers purely individualistic spiritual pursuits.

Of course, many American constitutional scholars argue that religion is too amorphous a concept to be defined at all, or that privileging religion at the expense of other deep personal commitments—making religion “special,” for constitutional ­purposes—is immoral. I lack space to address those arguments here. Suffice it to say that the Free Exercise Clause itself speaks of “religion,” not of “deep personal commitments,” and the Supreme Court has made clear that it continues to see religion as a distinct category meriting special constitutional protection. Avoiding a definition of religion for First Amendment purposes is not sustainable, and recent changes in American religion make the issue only more salient.

Little evidence exists of what the Framers meant by the word “religion” in the Free Exercise Clause. In 1791, when the Clause was adopted, “religion” could refer to conventional faith communities, especially Protestant ones, but also to non-institutional beliefs such as Deism. Nonetheless, the drafting history suggests that the Framers intended the Clause to cover communal rather than purely idiosyncratic phenomena. The Framers famously chose to protect the “free exercise of religion” rather than the “rights of conscience.” Although the Framers did not explain why they preferred the former phrase, “religion” connotes a community of believers, as Michael McConnell has observed, whereas “conscience” suggests individual judgment. The fact that the Framers chose a word with communal connotations over the more personal “conscience” suggests they had collective phenomena in mind.

Down the centuries, the Court has failed to offer consistent guidance. The handful of decisions that address the definition of religion point in different directions. In a couple of nineteenth-­century cases involving the LDS Church, the Court indicated that religion entailed a system of beliefs consistent with traditional Christianity. “Religion,” the Court said in Davis v. Beason (1890), “has reference to one’s views of his relations to his Creator, and to the obligations they impose of reverence for his being and character, and of obedience to his will.” The Court scoffed at the idea that the LDS Church could be a religion for constitutional purposes—notwithstanding that it held a belief in God—because it advocated polygamy, a practice condemned “by the general consent of the Christian world.” To call advocacy of polygamy “a tenet of religion,” the Court stated, would “offend the common sense of mankind.”

The Court has never repudiated these cases (though it would surely consider the LDS Church a religion today), yet subsequent decisions cast doubt on the idea that religion denotes traditional, organized religion, much less traditional Christianity. In two conscientious-objector cases from the Vietnam Era, the Court construed statutory language referring to “religious belief” to cover personal, non-theistic convictions. In United States v. Seeger (1965), the Court read language in the Draft Act exempting persons who objected to war on the basis of “religious belief” as covering a “belief in and devotion to goodness and virtue for their own sakes.” The test, the Court held, was “whether a given belief that is sincere and meaningful occupies a place in the life of its possessor parallel to that filled by the orthodox belief in God.”

Seven years later, the Court reverted to a more conventional definition in Wisconsin v. Yoder (1972), a case involving the Amish. ­Unlike the Draft Act cases, which collapsed the distinction between the communal and the personal, ­Yoder insisted on a bright line. “Religion,” the Court indicated, denotes a commitment to a traditional faith community; merely personal convictions would not qualify. The Court offered Thoreau as a counterexample. Thoreau, the Court explained in dicta, had engaged in an “isolated” and “­subjective” quest—an alternative lifestyle all his own. By contrast, the Amish had a three-­hundred-year history as a tight-knit religious community; they lived according to strict and detailed rules enforced by a formal church structure. The Amish exercised a religion for constitutional purposes. Thoreau had not.

Nonetheless, in two cases following Yoder, the Court suggested that religion could indeed be a personal phenomenon—in some ­circumstances and within limits. In Thomas v. Review Board (1981), the Court held that a Jehovah’s Witness who worked at a steel factory could claim a religious exemption from making weapons, even though Jehovah’s ­Witnesses apparently did not consider making weapons to be a sin and another Jehovah’s Witness at the same factory did not object to making weapons. The Free Exercise Clause does not require that religious beliefs be “acceptable, logical, consistent, or comprehensible to others,” the Court explained, or “shared by all of the members of a religious sect.”

Several years later, in Frazee v. Illinois Department of Employment Security (1989), the Court ruled unanimously that the Free Exercise Clause protected a claimant who argued that he could not work on Sundays because he was a Christian—even though he did not belong to a church. “[M]embership in an organized religious denomination, especially one with a specific tenet forbidding . . . work on Sunday, would simplify the problem of identifying sincerely held religious beliefs,” the Court explained. But the Clause did not require a claimant to show that he was “responding to the commands of a particular religious organization.”

Thomas and Frazee are in tension with Yoder, but neither case disavows that earlier ruling, and neither suggests that religion can be an entirely idiosyncratic matter. The Thomas Court explained that some claims might be “so bizarre, so ­clearly non­religious in motivation,” as to fall outside the protection of the Free Exercise Clause. ­Thomas itself did not involve such a claim. The debate among ­Jehovah’s Witnesses about whether one could permissibly work on weapons was a typical “intrafaith” dispute, an apparently good-faith disagreement of the sort “not uncommon among followers of a particular creed.” Similarly, in Frazee, a person who considered himself a Christian claimed that he could not work on Sundays. Though not all Christians shared it, his Sabbatarianism was hardly a “bizarre or incredible” conviction in the context of Christianity. A more singular claim, the Court implied, one that departed more seriously from a religion’s conventional baseline, would receive different treatment.

As this quick survey demonstrates, the Court’s decisions on the definition of religion are muddled. According to the cases, religion entails a conventional belief in God—except when it does not. Religion entails a commitment to a traditional, organized faith community—except when it does not. Religion excludes purely individualistic spiritual convictions—except when it does not. And a court should not evaluate whether a particular belief is “bizarre” or is shared by others in the claimant’s religion—except when it should.

Until very recently, one could dismiss the tension between communal and individualistic religion as peripheral. Notwithstanding occasional litigation like the Draft Act cases, few Americans have ever sought exemptions from civil law on the basis of entirely personal spiritual commitments. Courts could avoid deciding whether the Free Exercise Clause protected idiosyncratic beliefs and practices. The issue almost never came up.

But the rise in unaffiliated believers and religious hybrids has begun to change things. A recent study by scholars Michael Heise and Gregory Sisk reveals that Nones brought about 6 percent of the religious-accommodations claims in federal court from the years 2006 to 2015. About 40 percent of those claims were “loosely religious or spiritual in nature but not associated with a recognized religious grouping.” The numbers are still small, but they will probably increase as unaffiliated believers and religious hybrids become more entrenched in American society. One could imagine all sorts of claims based on idiosyncratic spiritual commitments: a vegetarian diet in prison, for example, or the right to wear certain clothing or insignia in the military. Or, as in Geerlings, an exemption from public health laws.

It’s time for the Court to establish that religion, at its core, denotes communal beliefs and practices rather than idiosyncratic personal commitments. A communal definition makes sense for several reasons. First, the existence of a community captures something important about the social reality of religion. In lived experience, religion suggests a group of people linked with one another, through time, in worship. As sociologist Christian Smith writes, “religions are almost invariably social activities—communities of memory engaged in carrying on particular traditions.” Without a communal structure to give them meaning, religious practices such as prayer, fasting, and so on are incoherent, “simply the strange doings of odd people.”

Second, a focus on community accords with an important goal of religious freedom: the promotion of private associations that encourage cooperative projects and check state power. As Tocqueville explained, the despotic state desires nothing more than for individual citizens to feel isolated from and indifferent to others, so that it can divide and dominate them all. By encouraging people to identify with and look out for one another, private associations militate against self-centeredness and social isolation and help keep the state in check. Religious groups perform this function especially well. No associations have been better, historically, at promoting cooperative social projects and defying state oppression—as dictators down the centuries have learned.

Third, the existence of a religious community reduces the possibility of fraud. Everyone agrees that courts need not honor a religious claim that a litigant does not genuinely hold or raises merely as a pretext. But sincerity, which depends on a claimant’s subjective state of mind, is notoriously difficult for courts to evaluate. The existence of a religious community to which the claimant belongs can provide objective evidence of the claimant’s good faith. A continuous tradition of teaching and worship, and an organized body that enforces discipline, can go a long way toward demonstrating the claimant’s genuineness about his religious convictions.

Fourth, the existence of a community helps ensure that religious commitments are not frivolous and fleeting, but serious and lasting. It is one thing for the state to accommodate a citizen’s profoundly held beliefs. To do so honors the citizen’s dignity and accords him respect. It is another thing to defer to commitments that may be temporary and superficial. Not all idiosyncratic commitments fit that description, of course, and beliefs can be religious even if novel. But the existence of an established religious community can screen out passing whims that the state need not honor.

Finally, making the definition of religion turn at least in part on the existence of a religious community reduces the potential for administrative disorder. Long ago, the Supreme Court warned that if personal spiritual convictions were sufficient to override legal obligations, “every citizen [would] become a law unto himself.” One should not overstate this concern, but the rise of the Nones makes it important today. Requiring a claimant to show that his or her objections are not merely personal but derive from the teachings of an organized body of believers can reduce the potential for conflict with state laws—especially in a society in which very large numbers claim to follow their own ­spiritual paths.

In short, the existence of a community is crucial to a plausible definition of religion. Nonetheless, categorically limiting legal protection to collective beliefs and practices would create two serious problems. First, excluding non-­institutional, idiosyncratic beliefs would contradict a long American tradition of honoring individual religious conscience. Unaffiliated believers like Thoreau and his spiritual descendants reflect something important about the way religion has historically been understood in America and the way it is understood today. Moreover, notwithstanding the problems of alienation, anomie, and unserious claims, honoring individual religious conscience promotes the important values of autonomy, dignity, and personal well-being. Categorically declining to protect individualistic claims would scant those important values and depart too far from our long tradition.

Second, limiting religion exclusively to communal beliefs and practices would create difficult line-drawing problems. Of course, civil courts lack competence to determine which religious expressions are correct in a metaphysical sense; that question is not at issue. For these purposes, courts would identify religion in an empirical sense—­describing things as they are. Even so, in many cases, courts might have a hard time identifying whether a community exists and what it teaches about a specific question. Most religions, ­especially if they have existed for a long time, have both majority and minority strains. Determining which expression among many qualifies as the “true” representative of a religious tradition can be difficult and may entangle courts in internal theological squabbles. These line-drawing problems will not always pose insurmountable obstacles. Law frequently relies on generalizations, and in many situations, courts should be able to fairly identify a religious community and its teachings as empirical matters. But the problems are significant enough to give one pause about categorically limiting free exercise protection to religious communities.

Thus, the proper constitutional definition of religion would be a flexible one with community at its core. The more a plaintiff can tie his beliefs and practices to those of an established religious community, the more his claims should qualify as religious for constitutional purposes. By contrast, the further a plaintiff diverges from a religious community, the more idiosyncratic his spiritual path, the less plausible his claim to practice a religion becomes.

Thomas and Frazee are suggestive in this regard. Thomas, recall, concerned what the Court characterized as a genuine “intrafaith” dispute among Jehovah’s Witnesses about the permissibility of making weapons. In the context of the religious tradition to which he belonged, Thomas’s objections were not novel and unique to him, but a matter of good-faith disagreement with his fellow believers. The Court was correct in recognizing his objections as religious.

Similarly, Frazee involved a claim by a person who called himself a Christian and maintained that he could not in good conscience work on Sundays. In the context of Christianity, this was hardly a “­bizarre” position, even if most American Christians no longer shared it, and even if the claimant did not formally belong to a church. Purely as a descriptive matter, refraining from work on Sundays is not an idiosyncratic position for someone who calls himself a Christian; it suggests neither fraud nor a lack of seriousness. Once again, given the faith tradition to which he claimed to subscribe, Frazee’s objections were properly characterized as religious.

The claims in Thomas and Frazee had plausible links to religious communities and did not implicate concerns about hyper-individualism, fraud, and lack of seriousness. The Court correctly concluded that the claims were religious. Contrast those claims with the claims in Geerlings, the recent Pennsylvania case involving the Covid mask mandate. The Christian plaintiffs in that case argued that medical masks dishonored God and violated the temple of the body. In the context of the Christian faiths to which the plaintiffs claimed to belong, and speaking only descriptively, those claims do indeed qualify as bizarre. They do not reflect genuine intrafaith disputes and do not cohere with historic beliefs and practices. Judge Goldberg was correctly skeptical that the claims qualified as religious.



Or consider the claim of the unaffiliated believers in Geerlings who sought religious exemptions because of personal views that masks mocked “the gift of life” and intuitions about a vague supernatural force beyond “just us.” Courts should be especially chary of such claims, which lack even a purported connection to a religious tradition. To treat such claims as religious for First Amendment purposes would contravene the common understanding that religion is a communal phenomenon and fail to advance the important associational benefits organized religion can confer. It would increase the potential for fraudulent and trivial claims and administrative disorder, in a country with millions and millions of unaffiliated believers, each of whom could make similar claims about the requirements of “something else out there.”

To be sure, the flexible approach I advocate here would not settle questions in the manner of a categorical rule. It would consider specific facts and depend a great deal on judgment; in any particular case, whether a claim qualifies as religious may be genuinely uncertain. Line-drawing problems will remain. Nonetheless, by placing the existence of a religious community at the core of the definition of religion, this approach would offer the benefits of tying religion to common understandings and avoiding at least some of the problems associated with defining religion in idiosyncratic terms, while remaining true to our cultural and legal traditions and minimizing the difficulties that a more categorical ­approach would entail.

Mark Movsesian is the Frederick A. Whitney Professor of Contract Law and Co-Director of the Center for Law and Religion at St. John’s University. A longer version of this essay, “The New Thoreaus,” appears in a forthcoming issue of the Loyola University Chicago Law Journal.

Defining Religion in the Court by Mark Movsesian | Articles | First Things