No. 24-297

In the
Supreme Court of the United States

TAMER MAHMOUD, et al.,

v.

THOMAS W. TAYLOR, et al.,

Petitioners,

Respondents.

On Writ Of CertiOrari tO the United StateS
COUrt Of appealS fOr the fOUrth CirCUit

BRIEF OF AMICUS CURIAE CALIFORNIA
PARENTS FOR THE EQUALIZATION OF
EDUCATIONAL MATERIALS IN
SUPPORT OF NEITHER PARTY

Glenn Katon

Counsel of Record

MIrador law
6601 Owens Drive, Suite 238
Pleasanton, CA 94588
(925) 460-8484
glenn@miradorlaw.com

Counsel for Amicus Curiae

120324

A

(800) 274-3321 • (800) 359-6859

TABLE OF CONTENTS

TABLE OF CONTENTS .............................................. i

TABLE OF AUTHORITIES ....................................... ii

INTEREST OF AMICUS CURIAE ............................ 1

SUMMARY OF ARGUMENT .................................... 3

ARGUMENT ............................................................... 5

I.  Schools and the Free Exercise Clause ............. 5

II.  A  Test

for  Free  Exercise  Claims

Challenging School Curricula .......................... 6

1.  The  Negation  of  Religious  Beliefs  or

Practices ...................................................... 7

2.  Targeted Hostility ....................................... 8

3.  Lack of Neutrality ....................................... 9

4.  Coercion ..................................................... 10

CONCLUSION .......................................................... 14

i

TABLE OF AUTHORITIES

Page(s)

Cases

Bauchman v. West High Sch.,

132 F.3d 542 (10th Cir. 1997) ............................... 12

Brandon v. Kinter,

938 F.3d 21 (2d Cir. 2019) ....................................... 8

Cal. Parents for the Equalization of
Educ. Materials v. Torlakson,
267 F. Supp. 3d 1218 (N.D. Cal. 2017) ................... 7

California Parents for Equalization of
Educational Materials v. Noonan,
600 F. Supp. 2d 1088 (E.D. Cal. 2009) .................... 2

California Parents for the Equalization of
Educational Materials v. Torlakson,
973 F.3d 1010 (9th Cir. 2020) ............. 1, 7, 8, 12, 13

Church of Lukumi Babalu Aye v.

City of Hialeah,
508 U.S. 520 (1993)...................................... 9, 10, 11

Espinoza v. Mont. Dep’t of Revenue,

591 U.S. 464 (2020)............................................ 8, 11

Goldman v. Weinberger,

475 U.S. 503 (1986)................................................ 11

Illinois ex rel. McCollum v. Bd. of Educ.,

333 U.S. 203 (1948).................................................. 8

Lynch v. Donnelly,

465 U.S. 668 (1984).................................................. 8

Lyng v. Nw. Indian Cemetery Protective Ass’n,

485 U.S. 439 (1988)................................................ 12

ii

Mahmoud v. McKnight,

102 F.4th 191 (4th Cir. 2024) ........................ 1, 9, 12

Mahmoud v. McKnight,

688 F. Supp. 3d 265 (D. Md. 2023) .......................... 1

Masterpiece Cakeshop, Ltd. v.
Colo. Civ. Rights Comm’n,
584 U.S. 617 (2017)........................................ 8, 9, 10

Oliver v. Arnold,

19 F.4th 843 (5th Cir. 2021) .................................... 7

Sch. Dist. of Abington Twp. v. Schempp,

374 U.S. 203 (1963).................................................. 5

Trinity Lutheran Church of Columbia, Inc. v.

Comer,
582 U.S. 449 (2017)............................................ 8, 11

Williams v. Hansen,

5 F.4th 1129 (10th Cir. 2021) .................................. 8

Constitutional Provisions

U.S. Const. amend. I ........................................... 2, 8, 9

Statutes, Rules and Regulations

Supreme Court Rule 37 .............................................. 1

Other Authorities

Kiri  Blakeley,  Seventh  grader  ‘had  to  say  God
wasn’t  real’  in  classroom  assignment  at  her
Texas school, Daily Mail, Oct. 28, 2015 .................. 7

Brief  of  Amici  Curiae,  Cal.  Parents  for  the
Equalization of Educ. Materials v. Torlakson,
(No. 20-1137) 141 S. Ct. 2583 (2021) ...................... 2

Brief of Respondents in Opposition, Mahmoud v.

Taylor (No. 24-297) (Dec. 18, 2024) ........................ 1

iii

Petition  for  Writ  of  Certiorari,  Mahmoud  v.

Taylor (No. 24-297) (Sept. 12, 2024) ....................... 1

Petition  for  Writ  of  Certiorari,  Cal.  Parents  for
the  Equalization  of  Educ.  Materials  v.
Torlakson, 141 S. Ct. 2583 (No. 20-1137) ............... 9

Reply of Petitioners, Mahmoud v. Taylor (No. 24-

297) (Dec. 27, 2024) ................................................. 1

Bruce Schreiner & Gilma Avalos, Florida school
apologizes after students stomp on ‘Jesus’, NBC
News, Mar. 27, 2013 ................................................ 7

The  Supreme  Court  2019  Term:  Leading  Case:
Espinoza  v.  Montana  Department  of  Revenue,
134 Harv. L. Rev. 470 (2020) ................................... 6

iv

INTEREST OF AMICUS CURIAE1

California  Parents  for  the  Equalization  of
Educational  Materials  (CAPEEM)  is  a  nonprofit,
nonpartisan  organization  that  is  at  the  forefront  of
advocating  for  religious  freedom  and  the  equal
treatment  of  Hindu  public  school  students.  For  two
decades,  CAPEEM  has  tried  to  eradicate  the
disparaging  treatment  of  Hinduism  in  California’s
statewide  public school  curriculum.  That  curriculum
upends  Hindu  beliefs  by  using  secular  theories  to
present  the  religion  as  nothing  more  than  a  social
construct in statewide textbooks, California’s History-
Social  Science  Content  Standards,  and  the  state’s
History-Social Science Framework.

CAPEEM’s  most  recent  case,  California
Parents for the Equalization of Educational Materials
v. Torlakson, 973 F.3d 1010 (9th Cir. 2020), has been
cited throughout the current proceedings.2 The Circuit
Court  and  the  parties  cite  Torlakson  for  different,

1  Pursuant  to  Supreme  Court  Rule  37.6,  counsel  for  amicus
certifies that no party’s counsel authored this brief in whole or in
part;  no  party  or  party’s  counsel  contributed  money  that  was
intended to fund the preparation or submission of the brief; and
no  person  other  than  amicus,  its  members,  or  its  counsel
contributed  money
intended  to  fund  the  preparation  or
submission of the brief.

2 See Mahmoud v. McKnight, 102 F.4th 191, 210 (4th Cir. 2024);
Mahmoud v. McKnight, 688 F. Supp. 3d 265, 290 (D. Md. 2023);
Petition for Writ of Certiorari, at 31, Mahmoud v. Taylor (No. 24-
297) (Sept. 12, 2024); Brief of Respondents in Opposition, at 12,
Mahmoud  v.  Taylor  (No.  24-297)  (Dec.  18,  2024);  Reply  of
Petitioners,  at  4,  Mahmoud  v.  Taylor  (No.  24-297)  (Dec.  27,
2024).

1

sometimes contradictory, propositions. CAPEEM also
litigated  California  Parents  for  Equalization  of
Educational  Materials  v.  Noonan,  600  F.  Supp.  2d
1088  (E.D.  Cal.  2009),  in  which  the  court  and  the
parties  tried  to  navigate  the  sometimes  overlapping
provisions  of  the  Constitution  that  apply  to  public
school  curricula.  CAPEEM’s  experience  litigating
violations of the rights of a religious group in schools
gives it an important perspective on the inadequacies
of existing law on the application of the Free Exercise
Clause to school curricula.

and

temples

religious

CAPEEM enjoys widespread support in Hindu
communities throughout the country. More than 150
Hindu
educational
organizations serving over half a million Hindus filed
an amicus brief in support of CAPEEM’s petition for
writ of certiorari in 2021, underscoring the importance
of this issue for Hindus. See Br. of Amici Curiae, Cal.
Parents  for  the  Equalization  of  Educ.  Materials  v.
Torlakson, (No. 20-1137) 141 S. Ct. 2583 (2021).

CAPEEM  takes  no  position  on  the  ultimate
issues  in  this  case,  but  notes  that  lower  courts
currently lack sufficient guidance on free exercise law
on  school  curricula  to  adequately  protect  the  free
exercise  rights  of  students.  We  would  like  to  see  a
clear, simple test emerge from this case that will guide
schools in ensuring that their curricula are consistent
with
the  First
Amendment.

the  Free  Exercise  Clause  of

2

SUMMARY OF ARGUMENT

Millions  of  public  school  students  across  the
country  rely  on  state  boards  of  education  and  local
school  boards  to  protect  their  free  exercise  rights.
When state and local school boards fail to adequately
protect those rights, students and parents must go to
the courts. The problem right now is that there is not
a clear body of law to guide parents, students, school
boards,  and  lower  courts  when  confronting  free
exercise issues arising in schools.

CAPEEM’s  experience  litigating  the  religious
freedom of Hindu parents and students for nearly two
decades  has  informed  a  proposed  four-part  test  to
determine  if  school  policies  and  practices  violate  the
Free Exercise Clause:

(1) Does the curriculum material negate religious
beliefs or practices?

(2)  Does  the  curriculum  material  itself  or  the
process  through  which  it  was  adopted  reflect
targeted  hostility  toward  religion  or  a  particular
religion?

(3)  Does  the  curriculum  material  or  the  process
through  which  it  was  adopted  lack  neutrality
toward a particular religion?

(4) Is the curriculum material coercive?

This  test  draws  on  the  history  of  Supreme
Court  free  exercise  cases  to  propose  a  coherent
standard  for  school  curriculum  compliance  with  the
Free  Exercise  Clause.  The  prongs  of  the  test

3

recognizable most easily are neutrality and coercion,
with targeted hostility toward religion emphasized in
more recent decisions. The negation of religious beliefs
is  also  important  because  there  are  so  many  ways,
direct and indirect, that schools can negate students’
religious beliefs, including by teaching the purported
secular  origin  of  a  religion,  which  is  a  manner  of
instructing  students  that  their  religion  is  not  a  real
religion.  This  four-pronged  test  can  be  used  in  this
case and others to address free exercise challenges to
school curricula.

4

ARGUMENT

Americans regard the public schools as a most
vital  civic  institution  for  the  preservation  of  a
is
democratic  system  of  government.  It
therefore
the
understandable
constitutional  prohibitions  encounter  their
severest test when they are sought to be applied
in the school classroom.

that

Sch. Dist. of Abington Twp. v. Schempp, 374 U.S. 203,
230 (1963).

I.  Schools and the Free Exercise Clause

Given the centrality of religion in the history of
the world and the United States, school curricula will
invariably include instruction on how civilization and
this country have been influenced by different faiths
as a way to understand the world we live in. While any
subject taught in school can have significance within
the  context  of  religion,  whether  it  is  physics  and
Galileo, biology and the theory of evolution, or many
types of literature, schools are at their most coercive
when  they  teach  about  religion  itself.  Thus,  schools
must  be  fair  and  neutral  in  their  descriptions  of
religions  and  their  adherents.  See  Sch.  Dist.  of
Abington  Twp.  v.  Schempp,  374  U.S.  203,  305
(Goldberg,  J.,  concurring)  (“The  fullest  realization  of
true  religious  liberty  requires  that  government
neither engage in nor compel religious practices, that
it effect no favoritism among sects or between religion
and  nonreligion,  and  that  it  work  deterrence  of  no
religious belief.”) (emphasis added).

5

Notwithstanding  the  importance  of  schools’
adherence  to  free  exercise  principles  in  how  they
develop  curricula  and  teach  students,  vast confusion
persists in how the Free Exercise Clause is understood
in  that  context.  See  The  Supreme  Court  2019  Term:
Leading  Case:  Espinoza  v.  Montana  Department  of
Revenue,  134  Harv.  L.  Rev.  470,  470  (2020)  (“The
Religion  Clauses  of  the  Constitution  have  proven
difficult for the Supreme Court to untangle.”) The case
before  the  Court  provides  an  opportunity  to,  in  the
process of deciding Petitioners’ appeal, provide clarity.

II.  A Test for Free Exercise Claims
Challenging School Curricula

CAPEEM proposes the test explained below to
guide lower courts and school boards in determining
whether  school  curricula  infringe  on  students’  free
exercise  rights.  We  submit  that  this  test  properly
recognizes  the  flexibility  needed  by  school  boards  in
crafting their curricula, while also protecting the free
exercise  rights  of  students  and  parents  this  country
holds dearly.

(1) Does the curriculum material negate religious
beliefs or practices?

(2)  Does  the  curriculum  material  itself  or  the
process  through  which  it  was  adopted  reflect
targeted  hostility  toward  religion  or  a  particular
religion?

6

(3)  Does  the  curriculum  material  or  the  process
through  which  it  was  adopted  lack  neutrality
toward a particular religion?

(4) Is the curriculum material coercive?

1.  The Negation of Religious Beliefs or Practices

The  first  prong  for  determining  whether  a
school’s curriculum violates the Free Exercise Clause
is the denial of a student’s or parent’s religious beliefs
or practices. Violations of religious beliefs can come in
either direct or indirect forms. Direct forms are such
as those described by Judge Ho in his concurrence in
a  denial  of  a  petition  for  rehearing  en  banc:  “Some
teachers  force  students  to  express  views  deeply
offensive  to  their  faith.  See,  e.g.,  Kiri  Blakeley,
Seventh  grader  'had  to  say  God  wasn't  real'  in
classroom assignment at her Texas school, Daily Mail,
Oct.  28,  2015;  Bruce  Schreiner  &  Gilma  Avalos,
Florida  school  apologizes  after  students  stomp  on
'Jesus', NBC News, Mar. 27, 2013.” Oliver v. Arnold,
19 F.4th 843, 844 (5th Cir. 2021) (Ho, J., concurring).

Indirect  forms  of  negation  include  teaching
secular theories about the origins of Hinduism with no
reference  to  the  belief  in  the  divine  and  attributing
human  authorship  to  the  Vedas  (Hindu  scriptures),
while  teaching  how  adherents  of  other  religions
believe  in  the  divine  origins  of  their  faiths  and
scriptures  without  providing  secular  explanations.
See  Cal.  Parents  for  the  Equalization  of  Educ.
Materials  v.  Torlakson,  267  F.  Supp.  3d  1218,  1223
(N.D. Cal. 2017), aff’d, 973 F.3d 1010 (9th Cir. 2020).

7

The  negation  of  religious  beliefs  or  practices
criterion that CAPEEM proposes does not rise to the
level  of  a  substantial  burden,  which  several  Circuit
Courts still require to maintain a free exercise claim.
See  Cal.  Parents  for  the  Equalization  of  Educ.
Materials v. Torlakson, 973 F.3d 1010, 1019 (9th Cir.
2020) (pleading substantial burden is required by this
court’s free exercise decisions); Williams v. Hansen, 5
F.4th 1129, 1133 (10th Cir. 2021); Brandon v. Kinter,
938 F.3d 21, 32 (2d Cir. 2019). The substantial burden
test is flatly inconsistent with this Court’s recent free
exercise cases involving forms of coercion that do not
directly  suppress  religious  practices.  See  Trinity
Lutheran Church of Columbia, Inc. v. Comer, 582 U.S.
449, 467 (2017) (The consequence  is,
in  all  likelihood,  a  few  extra  scraped  knees.  But  the
exclusion of Trinity Lutheran from a public benefit for
which  it is  otherwise  qualified,  solely  because  it  is a
church, is odious to our Constitution all the same, and
cannot  stand.);  Espinoza  v.  Mont.  Dep't  of  Revenue,
591 U.S. 464, 489 (2020); Masterpiece Cakeshop, Ltd.
v. Colo. Civ. Rights Comm'n, 584 U.S. 617, 640 (2017).

2.  Targeted Hostility

The  Free  Exercise  Clause  has  long  forbidden
government  hostility  toward  religion  or  a  particular
religion. The “Constitution . . . affirmatively mandates
accommodation, not merely tolerance, of all religions,
and forbids hostility toward any.” Lynch v. Donnelly,
465  U.S.  668,  673  (1984)  (emphasis  added);  see  also
Illinois ex rel. McCollum v. Bd. of Educ., 333 U.S. 203,
211-212  (1948)  (“overnmental  hostility  to  religion
or  religious  teachings  .  .  .  would  be  at  war  with  our
the  First
national

tradition  as  embodied

in

8

Amendment's  guaranty  of  the  free  exercise  of
religion.”).  More  recently,  this  Court  has  reiterated
that  strict  scrutiny  applies  when  official  action
demonstrates governmental hostility toward religion.
Masterpiece  Cakeshop,  584  U.S.  at  649  (“o
bureaucratic  judgment  condemning  a  sincerely  held
religious belief as “irrational” or “offensive” will ever
survive strict scrutiny under the First Amendment.”);
Church of Lukumi Babalu Aye v. City of Hialeah, 508
U.S.  520,  534  (1993)  (“The  Free  Exercise  Clause
protects  against  governmental  hostility  which  is
masked as well as overt.”)

toward

reflected  hostility

for
In  this  case,  decided  on  a  motion
preliminary injunction, the Fourth Circuit found that
more factual development was needed to determine if
the board of education’s abrupt change in policy that
had  previously  allowed  opting  out  of  part  of  the
curriculum
religion.
Mahmoud v.  McKnight, 102 F.4th 191, 216  (4th Cir.
2024). In CAPEEM’s experience, describing Hinduism
as  a  negative  social  construct  built  on  an oppressive
“caste”  system  imposed  from  without  by  Aryan
invaders, rather than as a divinely inspired religion,
and  the  use  of  the  term  ‘Brahmanism’  which  has
historically  been  used  in  a  derogatory  manner,
constitute targeted hostility that should invoke strict
scrutiny. Petition for Writ of Certiorari,  Cal. Parents
for the Equalization of Educ. Materials v. Torlakson,
141 S. Ct. 2583 (No. 20-1137).

3.  Lack of Neutrality

Government neutrality with respect to religion
is  a  touchstone  of  the  Free  Exercise  Clause.  In  the

9

Masterpiece Cakeshop case, a baker refused to make a
wedding  cake  for  a  same-sex  couple  because  of  his
religious  objection  to  same-sex  marriage.  The
Colorado  Civil  Rights  Commission  found  that  he
violated the Colorado Anti-Discrimination Act, which
Colorado  state  courts  affirmed.  This  Court  reversed.
In addition to the hostility the Commission showed to
the  baker’s  religion,  as  discussed  above,  this  Court
held that he “was entitled to the neutral and respectful
consideration of his claims in all the circumstances of
the  case.”  Masterpiece  Cakeshop,  584  U.S.  at  634
(emphasis added); id., at 644 (Gorsuch, J., concurring)
(“the  Colorado  Civil  Rights  Commission  failed  to  act
neutrally toward ’s religious faith”).

Thus, the Court was deeply concerned with the
religious bigotry the Commission showed toward the
baker during its administrative review process. School
boards,  too,  have  an  administrative  process  for
adopting curricula. CAPEEM urges the Court to look
education’s
closely  at  Respondent  board
administrative process in this case and submits that
neutrality not just in content but in process be made
an  essential  part  of  any  test  the  Court  develops  for
analyzing  free  exercise  claims  in  connection  with
school curricula. The Free Exercise Clause bars even
“subtle  departures  from  neutrality”  on  matters  of
religion.” Lukumi Babalu Aye, 508 U.S. at 534.

of

4.  Coercion

A free exercise plaintiff must show coercion to
establish a claim. That coercion could be requiring the
plaintiff  to  do  something  their  religion  forbids,  or
forbidding  them  from  doing  something  their  religion

10

requires.  In  Lukumi  Babalu,  this  Court  held  it
unconstitutional for the City of Hialeah to criminalize
the  ritualistic  slaughter  of  animals  required  by  the
Santeria faith. 508 U.S. at 547 (“Legislators may not
devise  mechanisms,  overt  or  disguised,  designed  to
persecute or oppress a religion or its practices.”); see
also  Goldman  v.  Weinberger,  475  U.S.  503,  510  (Air
Force  officer  wearing  yarmulke  with  uniform
implicated  Free  Exercise  Clause  but  Air  Force
regulation prohibiting the wearing of headgear held to
“reasonably  and  evenhandedly  regulate  dress  in  the
interest  of
for
uniformity.”)

the  military's  perceived  need

More  recently,  the  Court  has  held  in  several
cases that a free exercise violation need not be based
on  interference  with  a  religious  practice,  such  as
animal slaughter or wearing a yarmulke. Coercion can
take  the  form  of  denying  a  church  playground
participation in a safety program that is available to
other  playgrounds  or  denying  a  scholarship  to  a
student who wants to use it for a religious school. See
Trinity  Lutheran,  582  U.S.  at  467  (playground);
Espinoza v. Mont. Dep't of Revenue, 591 U.S. 464, 478
(“The  Free  Exercise  Clause  protects  against  even
indirect  coercion,  and  a  State  punishes  the  free
exercise  of  religion  by  disqualifying  the  religious
from government aid as Montana did here.”) (cleaned
up).

In this case, the plaintiffs have argued that the
school  board’s  inclusion  of  stories  in  the  district’s
curriculum  that  portray  gay,  transgender,  and  non-
binary  characters  without  notice  that  those  stories
would  be  included  and  an  opportunity  to  opt  out

11

violated  their  free  exercise  rights.  Mahmoud,  102
F.4th  at  201.  The  court  considered  the  parents’
argument  that  “exposure”  to  the  stories  constituted
sufficient  coercion  and  acknowledged  this  Court’s
precedent  that  the  Free  Exercise  Clause  “protects
against  indirect  coercion  or  penalties  on  the  free
exercise  of  religion.”  Id.  at  204  (citing  Lyng  v.  Nw.
Indian  Cemetery  Protective  Ass'n,  485  U.S.  439,  450
(1988)).  The  court  held  that  at  the  preliminary
injunction stage, the plaintiffs  did not show coercion
that  would  give  them  a  likelihood  of  success  on  the
merits  on  their  free  exercise  claim.  Mahmoud,  102
F.4th  at  216.  The  question  of  what  constitutes
“coercion” as part of  a free exercise claim can be the
lynchpin of that claim.

In  Bauchman  v.  West  High  School,  a  Jewish
high school student participated in a school choir and
objected that it performed Christian devotional music.
Bauchman v. West High Sch., 132 F.3d 542, 546 (10th
Cir. 1997). The choir teacher allowed her to opt out of
the  Christian  songs  and  assured  her  that  her  grade
would not be affected by her limited participation. Id.
at  557.  The court held that the school did not coerce
her  to  violate  her  religious  beliefs.  Id.  at  558.  In
California Parents for the Equalization of Educational
Materials  v.  Torlakson,  the  Ninth  Circuit  found  no
coercion  under  the  Free  Exercise  Clause  because
plaintiffs, who alleged students were being graded on
their  ability  to  affirm  material  they  found  offensive
about  their  religion, did  not  allege  “specific  religious
conduct that was affected by the Defendants’ actions.”
973  F.3d  at  1019  (emphasis  added)  (quoting  district
court decision with approval).

12

CAPEEM  submits  that  when  students  are
tested  on  material  relating  to  their  religion  that  is
part  of  the  school  curriculum,  and  their  grades  are
determined  by  how  well  they  demonstrate  their
understanding of that material, they are being coerced
to conform to the school’s portrayal of their religion. In
particular, the standard for what constitutes coercion
should be a low bar when it comes to teaching  about
religion.  For  example,  if  schools  tested  students  on
material about how Jews believe Moses was a prophet
who  was  given  the  Ten  Commandments  from  God,
written  on  stone  tablets,  and  that  later,  the  Roman
emperor  Constantine  “created”  Christianity,  without
mentioning that Christians believe Jesus was the son
of  God,  that  should  constitute  coercion  of  Christians
that  would  support  a  free  exercise  claim.  One  court
has erroneously held that requiring students to learn
their school’s secularized portrayal of their religion as
“truth” on which they are tested means nothing more
than students finding it offensive. See Torlakson, 973
F.3d  at  1020  (“Offensive    content  that
does not penalize, interfere with, or otherwise burden
religious  exercise  does  not  violate  Free  Exercise
rights.”).  It  is  coercion  to  require  students  to  adopt
that portrayal under penalty of lower grades.

CAPEEM further submits that schools be given
greater latitude when teaching on subjects other than
religion,  such  as  teaching  the  theory  of  evolution  as
part of biology class (as opposed to during a class on
world religions). When teaching an array of stories or
literature  designed  to  expose  students  to  ideas  or
experiences  that  are  not  taught  in  the  context  of
religion, there is little or no coercion by the school.

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CONCLUSION

This  case  provides  an  important  opportunity  for
the Court to clarify the law for free exercise challenges
to  school  curricula.  The  four-part  test  proposed  by
CAPEEM gives students, parents, school boards, and
lower  courts  with  the  guidance  they  need  to  protect
the  free  exercise  rights  we  cherish  as  a  country.
CAPEEM  urges  the  Court  to  consider  adopting  the
test proposed in this brief.

Respectfully submitted,

GLENN KATON
MIRADOR LAW
6601 Owens Drive, Suite 238
Pleasanton, CA 94588
(925) 460-8484
glenn@miradorlaw.com

Counsel for Amicus Curiae

March 10, 2025

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