## Facts

- Hawkins County, Tennessee adopted the Holt, Rinehart & Winston basic reading series for grades 1–8 as part of a countywide curriculum emphasizing critical reading and character education.
- Several evangelical Christian parents and their school-age children objected to the series, asserting it presented themes they viewed as contrary to their religious beliefs (including evolution, occult or magical elements, and religious relativism).
- Plaintiffs filed a 42 U.S.C. § 1983 action against the Hawkins County Board of Education and school officials; the Tennessee Commissioner of Education intervened as a defendant.
- The district court initially dismissed after finding the materials neutral as to religion, but the Sixth Circuit reversed and remanded for trial to develop the free-exercise claim.
- After trial on remand, the district court found a free-exercise burden based on plaintiffs’ belief that their faith required them not to be exposed to the content, enjoined enforcement against objecting students, and awarded damages for private-school costs.
- The Board and state officials appealed from the injunction and damages award.

## Issues

1. Whether requiring students to read and discuss assigned public-school textbooks containing ideas objectionable on religious grounds imposes a constitutionally cognizable burden on the free exercise of religion.
2. Whether parents have a constitutional right to demand exemptions from exposure to ideas in a public-school curriculum that conflict with their religious convictions.

## Decision

- The Sixth Circuit reversed the district court and remanded with instructions to dismiss the complaint.
- The court held that mere exposure to ideas in a neutral, generally applicable public-school curriculum—even if religiously offensive—does not, without more, burden free exercise.
- The court found no compulsion to affirm, deny, or modify religious belief, and no requirement to engage in religiously prohibited conduct.
- The court rejected a parental-rights theory that would confer a constitutional veto over neutral curriculum content or require the school to provide alternative materials upon objection.

## Legal Principles

- A Free Exercise claim requires more than exposure to objectionable ideas; the Constitution is implicated where the state compels affirmation of belief, coerces participation in religiously forbidden conduct, or penalizes religious exercise.
- A requirement to read and discuss assigned materials, without compelled assent or punishment for dissent, does not constitute unconstitutional coercion.
- Public schools may implement a uniform curriculum designed to teach literacy and civic competence; parental interests in childrearing do not create a right to excise portions of a neutral curriculum on religious grounds.
- Different facts—such as discipline for disputing assigned ideas or compelled participation beyond reading and discussion—could present coercion sufficient to trigger Free Exercise scrutiny.

## Conclusion

The Sixth Circuit held that a public school’s mandatory use of a neutral reading curriculum does not violate the Free Exercise Clause merely because it exposes students to ideas parents find religiously objectionable, and it declined to recognize a constitutional right for parents to obtain curricular exemptions on that basis.


Mozert v. Hawkins Cnty. Bd. of Educ., 827 F.2d 1058 (6th Cir. 1987)