## Facts

- New Jersey public high schools offered an elective course titled “The Science of Creative Intelligence—Transcendental Meditation” (SCI/TM) during the 1975–76 school year.
- The course used materials associated with Maharishi Mahesh Yogi and was taught by instructors trained by organizations promoting SCI/TM.
- Students were required to attend a “puja” ceremony off school premises before beginning meditation instruction.
- The puja involved a ritual with Sanskrit chanting, offerings (e.g., flowers and fruit), and invocation honoring “Guru Dev,” after which students received personal mantras for meditation.
- Course materials presented a comprehensive worldview asserting that “pure creative intelligence” is the basis of life and that TM practice enables higher states of consciousness and fuller human potential.
- Parents, taxpayers, and related organizations sued, alleging the course’s public-school implementation and public support violated the Establishment Clause.

## Issues

1. Whether SCI/TM, including the puja and mantra instruction, constitutes “religion” for First Amendment purposes.
2. Whether offering and supporting SCI/TM in public schools violates the Establishment Clause under the purpose/effect/entanglement framework.

## Decision

- The Third Circuit affirmed the district court’s partial summary judgment for plaintiffs and the injunction barring public-school teaching of SCI/TM with public support.
- The court upheld the determination that SCI/TM (including puja and mantra instruction) was religious in nature.
- The court agreed that the public-school program failed Establishment Clause requirements because it advanced religion and created impermissible church–state involvement.
- A concurrence explained that “religion” under the First Amendment is not limited to traditional theism and set out functional criteria for identifying religion.

## Legal Principles

- A program may be “religious” for Establishment Clause purposes even if presented as scientific or therapeutic; courts examine substance, including teachings and practices.
- Establishment Clause analysis applies to public-school curricula and asks whether the program has a secular purpose, whether its primary effect advances or inhibits religion, and whether it produces excessive entanglement between government and religion.
- In assessing whether a belief system is “religion,” relevant considerations include (nonexclusive): whether it addresses ultimate concerns, whether it is comprehensive as a worldview, and whether it includes formal external signs such as rituals, ceremonies, prescribed practices, clergy-like roles, or authoritative texts.

## Conclusion

The Third Circuit held that SCI/TM as implemented in public high schools was religious in nature and that public sponsorship of the course violated the Establishment Clause, warranting injunctive relief against its continued offering with public support.


Malnak v. Yogi, 592 F.2d 197 (3d Cir. 1979)