Cultic Studies Review, Vol. 2, No. 2, 2003, Page 121
the Waldorf education will be necessary to ensure that no trespass occurs.
These ―prophylactic contacts‖ may well result in excessive and enduring
entanglement between church and state. See Lemon, 403 U.S. at 619.
As is the case with all similar analyses, it is clear that entanglement ―is a
question of kind and degree.‖ Lynch, 465 U.S. at 684. Here, PLANS has raised
a disputed issue of material fact concerning the degree of entanglement
between church and state generated by the Waldorf teaching method.
3. California Constitution
Article XVI, section 5 of the California Constitution provides that ―neither the
Legislature, nor any...school district,...shall ever...pay from any public fund
whatever, or grant anything to or in aid of any religious sect, church, creed,
or sectarian purpose.‖ Article IX, ¶8 of the California Constitution provides
that no ―sectarian or denominational doctrine [shall] be taught, or instruction
thereon be permitted, directly or indirectly, in any of the common schools of
this State.‖
As discussed above, PLANS has raised a genuine issue of material fact as to
whether Anthroposophy is so fundamental to Waldorf education as to be
inseparable from it, thereby making public funding of Waldorf education
methods a direct and substantial (if unintentional) endorsement of religion,
and fostering excessive entanglement between church and state. (Damrell,
1999, pp. 23-25)
As of May, 2003, the case was waiting to be calendared again by the U.S. District Court,
after a decision of the 9th Circuit Court of Appeals confirmed PLANS standing, i.e., the right
to sue on behalf of taxpayers.
References
Anthroposophical Society in America (1993). Toward a more human future: Anthroposophy
at work [Pamphlet, 33 pp.]. Chicago: Author.
AWSNA, (2003). Web site of the Association of Waldorf Schools of North America: Retrieved
May 4, 2003, from http://www.awsna.org/education-aboutwaled.html
Bloom, J. (1991). Questions and answers on Waldorf Education [Pamphlet]. San Francisco:
San Francisco Waldorf School.
Blue Oak Charter School (2000). Charter of the Blue Oak Charter School (Draft submitted to
school board 12/6/2000). Chico, CA: Author.
Britannica (2002). Retrieved December 1, 2002, from http://www.britannica.com
Charren, S. (1988). Physics IV: Quantum mechanics. Student lesson book, 12th grade,
Sacramento Waldorf School, Teacher, Mr. Demarzi. Photocopy in PLANS library.
Cusick, L. (1992). Waldorf parenting handbook: Useful information on child development
and education from anthroposophical sources. Fair Oaks, CA: Rudolf Steiner
College/St. George Publications.
Damrell, Jr., F. C. (1999). Memorandum and order. United States District Court, Eastern
District of California, No. CIV S 98-266 FCD PAN, Sept. 24, 1999. Retrieved May 4,
2003, from http://www.waldorfcritics.org/active/articles/Damrell_991024.pdf.
Dugan, D., &Daar, J. (1994, Spring). Are Rudolf Steiner’s Waldorf schools ‘non-sectarian’? Free Inquiry.
14:2, 44. Retrieved January 19, 2003, from
http://www.waldorfcritics.org/active/articles/Free_Inquiry.html.
Ercolano, L. (2001, Sept. 29). Discouraging reading. Message posted to Waldorf-critics
discussion list, retrieved January 12, 2003: http://www.topica.com/lists/waldorf-
critics/read/message.html?mid=1708387434..
the Waldorf education will be necessary to ensure that no trespass occurs.
These ―prophylactic contacts‖ may well result in excessive and enduring
entanglement between church and state. See Lemon, 403 U.S. at 619.
As is the case with all similar analyses, it is clear that entanglement ―is a
question of kind and degree.‖ Lynch, 465 U.S. at 684. Here, PLANS has raised
a disputed issue of material fact concerning the degree of entanglement
between church and state generated by the Waldorf teaching method.
3. California Constitution
Article XVI, section 5 of the California Constitution provides that ―neither the
Legislature, nor any...school district,...shall ever...pay from any public fund
whatever, or grant anything to or in aid of any religious sect, church, creed,
or sectarian purpose.‖ Article IX, ¶8 of the California Constitution provides
that no ―sectarian or denominational doctrine [shall] be taught, or instruction
thereon be permitted, directly or indirectly, in any of the common schools of
this State.‖
As discussed above, PLANS has raised a genuine issue of material fact as to
whether Anthroposophy is so fundamental to Waldorf education as to be
inseparable from it, thereby making public funding of Waldorf education
methods a direct and substantial (if unintentional) endorsement of religion,
and fostering excessive entanglement between church and state. (Damrell,
1999, pp. 23-25)
As of May, 2003, the case was waiting to be calendared again by the U.S. District Court,
after a decision of the 9th Circuit Court of Appeals confirmed PLANS standing, i.e., the right
to sue on behalf of taxpayers.
References
Anthroposophical Society in America (1993). Toward a more human future: Anthroposophy
at work [Pamphlet, 33 pp.]. Chicago: Author.
AWSNA, (2003). Web site of the Association of Waldorf Schools of North America: Retrieved
May 4, 2003, from http://www.awsna.org/education-aboutwaled.html
Bloom, J. (1991). Questions and answers on Waldorf Education [Pamphlet]. San Francisco:
San Francisco Waldorf School.
Blue Oak Charter School (2000). Charter of the Blue Oak Charter School (Draft submitted to
school board 12/6/2000). Chico, CA: Author.
Britannica (2002). Retrieved December 1, 2002, from http://www.britannica.com
Charren, S. (1988). Physics IV: Quantum mechanics. Student lesson book, 12th grade,
Sacramento Waldorf School, Teacher, Mr. Demarzi. Photocopy in PLANS library.
Cusick, L. (1992). Waldorf parenting handbook: Useful information on child development
and education from anthroposophical sources. Fair Oaks, CA: Rudolf Steiner
College/St. George Publications.
Damrell, Jr., F. C. (1999). Memorandum and order. United States District Court, Eastern
District of California, No. CIV S 98-266 FCD PAN, Sept. 24, 1999. Retrieved May 4,
2003, from http://www.waldorfcritics.org/active/articles/Damrell_991024.pdf.
Dugan, D., &Daar, J. (1994, Spring). Are Rudolf Steiner’s Waldorf schools ‘non-sectarian’? Free Inquiry.
14:2, 44. Retrieved January 19, 2003, from
http://www.waldorfcritics.org/active/articles/Free_Inquiry.html.
Ercolano, L. (2001, Sept. 29). Discouraging reading. Message posted to Waldorf-critics
discussion list, retrieved January 12, 2003: http://www.topica.com/lists/waldorf-
critics/read/message.html?mid=1708387434..
