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Artifact 6

Emily MacKinnon

EDU 214 – 2001


Karen White is a Kindergarten teacher who has recently converted to Jehovah's Witness.

Because of this, Karen informed her students and their parents that there were things she could

no longer do – such as decorating for holidays or planning Christmas gift exchanges – as her

newfound faith did not permit that. She was also unable to sing "Happy Birthday" or say the

Pledge of Allegiance. After parents complained, the school's principal, Bill Ward,

"recommended her dismissal based on her ineffectively meeting the needs of her students."

In Skoros v. City of New York, 2006, Andrea Skoros attempted to get some sort of

nativity scene put up on the school's holiday display, because they had a menorah put up there.

Her argument was that if they put up symbols representative of a Jewish holiday, why could they

not do so for Christmas? The court ruled in favor of the school, outlining one of their reasons for

the displays as being "to promote the goal of fostering understanding and respect for the rights of

all individuals regarding their beliefs, values and customs" (Findlaw's United States...). Based on

the decision of the court in this case, I do not think that a dismissal of Karen White is a fair or

justified response. White's refusal to put things up to celebrate the holidays were just as much an

exercise in respecting others' beliefs as putting up a display that showed off many different


Another case is that of Florey v. Sioux Falls School District, 1979. In this case, father of

Kindergartener Justin Florey was unhappy about the content of his son's Christmas assembly,

and began investigating how it compared with the Establishment Clause with a few other

parents. Florey took it to court, and the court in turn responded with, "[W]e find no constitutional

requirement which makes it necessary for government to be hostile to religion and to throw its

weight against efforts to widen the effective scope of religious influence" (FLOREY v.

SIOUX...). It is the same case here, perhaps even on a lesser scale. In this case, White has simply

decided not to put up the celebration of any holiday, whether religious or not, whereas in the

other case, the court made that ruling with a quiz set to song about the baby Jesus Himself. In

light of Florey v. Sioux Falls School District, 1979, Karen White should not be dismissed.

On the other side, in Peloza v. Capistrano Unified School District, 1994, John Peloza

refused to teach evolution as part of the curriculum on the grounds that it disagreed with his

belief and he could not teach it as truth, and he challenged the school district in trying to force

him to teach it, as well as in barring him from discussing his religious beliefs with students. The

courts sided with the school district, in light of the Establishment Clause and the school's

requirements regarding curriculum content. Based on this, Karen White should not refrain from

the activities that she chose to refrain from, especially if it was in her school contract to perform

such duties for her students.

And finally, in the case of Guyer v. School Board of Alachua County, 1994, a school was

petitioned by parent Robert Guyer that the school take down the images of witches and

Halloween-related decorations, because he disagreed with them. He also requested that teachers

be barred from dressing up, and even went so far as to keep his kids home from school on the

day of Halloween. The court ruled that "the public elementary school's Halloween festivities

does not violate the establishment clauses of the Florida and U.S. constitutions" (GUYER v.

SCHOOL...). Karen White's refusal to put up a display, while possibly not breaking the

Establishment Clause, should not be accepted. One man's discomfort with the celebration or

recognition of a holiday was not enough for the court to require the displays taken down. In this

case, White should be required to put up displays, even though her discomfort is noted.

While I do not agree with Karen White's decision to remove herself from the activities

that she did, I do not believe that it warranted her dismissal based on the results of Florey v.

Sioux Falls School District. Her choices were not affecting what she taught, and the things that

she chose not to provide for her students were not even things that could be considered part of

the curriculum – they could even be categorized as extracurricular activities.



PELOZA v. CAPISTRANO UNIFIED SCHOOL DISTRICT . (n.d.). Retrieved June 29, 2017,


FindLaw's United States Second Circuit case and opinions. (n.d.). Retrieved June 29, 2017, from

FLOREY v. SIOUX FALLS SCH. DIST. 49-5 | 464 F.Supp. 911 (1979). (1979, February 13).

Retrieved June 29, 2017, from


GUYER v. SCHOOL BD. OF ALACHUA COUNTY | 634 So.2d 806 (1994). (1994, April 07).

Retrieved June 30, 2017, from