7th Circuit: Bus Driver Gave No Religious Reasons for Rejecting Covid Vaccine

In Snyder v. Chicago Transit Authority, (7th Cir., June 30, 2026), the U.S. 7th Circuit Court of Appeals upheld the firing of a Chicago Transit Authority bus driver for refusing to comply with CTA's Covid vaccine mandate after his request for a religious exemption was denied. The court said in part:

... Snyder submitted a request for a religious exemption. He explained that he practiced “the laws of cleanliness” and adhered to dietary rules outlined in the biblical books of Leviticus and Deuteronomy. He explained that the Bible instructed him to “refrain from the ingestion of unclean animals,” including “pork or derivatives, such as gelatin which are in most vaccines.” He also attached a letter from his minister explaining that vaccines were “inconsistent” with their beliefs, though individuals had discretion to choose which vaccines and immunizations they received.  

... Snyder also cited concerns about the presence of heavy metals in most vaccinations, potential long-term risks, and the rush with which the vaccine was approved....

But even accepting the religious significance of Snyder’s belief that Biblical laws prohibited him from ingesting certain ingredients, the court wrote, Snyder did not connect this belief to any content in the COVID vaccine that he was religiously obligated to avoid.... The court thus concluded that there was no evidence from which a reasonable jury could find that his grounds for objecting to the vaccine were religious in nature....

Supreme Court Denies Review in Case of Attorney Held in Contempt for Disclosing Information About Abusive Priest

On Monday, the U.S. Supreme Court denied review in Trahant v. Roman Catholic Church, (Docket No. 25-1260, certiorari denied, 6/29/2026). (Order List.). In the case, the U.S. 5th Circuit Court of Appeals in a January 2026 opinion (full text of opinion) upheld a finding of contempt and a $400,000 sanction imposed on an attorney representing victims of clergy sexual abuse. The 5th Circuit explained in part:

Richard Trahant received confidential information regarding sexual abuse allegations against a New Orleans priest while serving as state court counsel for several alleged victims of sexual abuse who were also members of the Official Committee of Unsecured Creditors.  Despite a protective order prohibiting the disclosure of confidential information revealed during discovery, Trahant contacted the principal of a local high school to confirm that the priest remained the high school’s chaplain.  Trahant then sent an email to a journalist listing the priest’s name in the subject line, identifying where the priest was employed, and advising the journalist to “[k]eep this guy on your radar.”  The bankruptcy court held Trahant in contempt for violating the protective order and sanctioned him for his conduct.  The district court affirmed....

Notwithstanding the fact that the record fully supported the bankruptcy court’s finding that Trahant violated the protective order, Trahant maintains that he “acted in the utmost good faith at all times” and that the sanctions are “disproportionate” to the alleged conduct.  To support this argument, Trahant points to his “legal, moral, and ethical obligation . . . to keep [the priest] away from children.”  He also points to his belief that the $400,000 sanction is “not causally related to any actual damage or prejudice to any party.”  These arguments are without merit.

The Guardian has additional information on the case.

1st Circuit: University's Rejection of Property Sale to Church Was Not Religious Discrimination

In Calvary Chapel Belfast v. University of Maine System, (1st Cir., June 30, 2026), the U.S. 1st Circuit Court of Appeals affirmed the district court's refusal to stop the sale by the University of Maine of the Frederick Hutchinson Center property to a bidder that was competing with Calvary Chapel Belfast to obtain the property.  Originally, the University selected Calvary Chapel to negotiate a purchase agreement. However, according to the court:

In the days following the public announcement, numerous area residents as well as University alumni, donors, students, faculty, and staff criticized the University's selection of a religious entity, and Calvary in particular, as the winning bidder.  One online commentor, for example, referred to the decision as "disappointing," with another writing, "[t]hese evangelists from [Calvary] are just another religious cult that believes in magical thinking."...

Calvary asserts an intentional discrimination claim, arguing that the University violated the Equal Protection Clause by carrying out the facially neutral public procurement process in a discriminatory way. ... Specifically, Calvary argues that the court created a "novel rule" when it required Calvary "to make a direct 'showing connecting the animus in the community to the government action' to raise an inference of discriminatory intent."  ...

The court recognized that widespread religious animus in the community can, in certain circumstances, support an inference that a government official acted with discriminatory intent by essentially adopting the community's view even if the official did not personally share that view.... But the presence of community opposition does not, without more, imply a conclusion of intentional discrimination by the decisionmaker.... And here the court found scant evidentiary support for the alleged irregularities -- "the more" -- urged by Calvary....

Michigan Catholic Charities Sues State Officials Over Ouster as Provider of Women's Substance Abuse Services

Last week, Catholic Charities serving the Lansing, Michigan area filed suit against the director of Michigan's Department of Health and Human Services, Michigan's Attorney General and other Michigan officials as well as Mid-State Health Network that administers the Department's Medicaid and federal Substance Use Block Grant funds. Catholic Charities, through Cristo Rey Counseling Center, offers federally funded services for women with substance use disorders. The complaint (full text) in Catholic Charities of Ingham, Eaton & Clinton Counties v. Hertel, (WD MI, filed 6/26/2026), alleges that Mid-State discontinued Cristo Rey as a provider under the program after questioning the Counseling Center's requirement that its staff not discuss or make referrals for abortions, contraception, gender identity, or adoption placements with same-sex couples. It alleges that Michigan state Attorney General Dana Nessel is providing legal guidance to the Department of Health and Human Services, and that "Nessel harbors ... hostility toward Catholic and other religious organizations that hold sincere religious beliefs about abortion and contraception...." The complaint alleges that discontinuing Cristo Rey as a provider violates its 1st and 14th Amendment rights as well as federal statutory provisions. ADF issued a press release announcing the filing of the lawsuit.

2nd Circuit Reaffirms Permissibility of NY Repeal of Religious Exemptions from School Vaccination Requirements

In Miller v. McDonald, (2d Cir., June 30, 2026), the U.S. 2nd Circuit Court of Appeals reaffirmed its earlier decision that New York's repeal of its religious belief exemption from required school immunizations, while keeping medical exemptions, does not violate either Amish parents' free exercise rights or their parental rights to control their children's religious upbringing.  Last year, the Supreme Court had remanded the case to the Second Circuit for reconsideration in light of Mahmoud v. Taylor. In reaffirming its earlier decision, the Second Circuit said in part:

New York Public Health Law § 2164 is neutral on its face.  It does not target or affirmatively prohibit religious practices....  Moreover, the act of repealing the religious exemption did not “in and of itself transmute” this otherwise neutral law into one “that targets religious beliefs.”...

Nor does the legislative history reveal an anti-religious bias....

... [T]he motives of a small number of legislators cannot be attributed to the legislative body as a whole.

Plaintiffs contend that exempting students for medical reasons treats comparable secular conduct more favorably than religious beliefs....

Repealing the religious exemption decreases “to the greatest extent medically possible” the number of unvaccinated students and thus the risk of disease; maintaining the medical exemption allows “the small proportion of students” who medically “cannot be vaccinated” to avoid the health consequences that “taking a particular vaccine would inflict.” ... Exempting religious objectors, however, detracts from that interest.  Religious exemptions increase “the risk of transmission of vaccine-preventable diseases among vaccinated and unvaccinated students alike.”...

New York passed § 2164 in response to the 2018 to 2019 measles outbreak.  Legislators felt particularly concerned about the concentration of unvaccinated children with religious exemptions in the same schools....

Plaintiffs’ remaining argument is that, even if § 2164 is neutral and generally applicable, it burdens the parental free-exercise right recognized in Wisconsin v. Yoder, 406 U.S. 205 (1972), and clarified in Mahmoud v. Taylor.  We conclude that it does not....

Section 2164 does not regulate what children are taught, does not require them to affirm any belief, does not expose them to state-selected instruction contrary to their parents’ faith, and does not enlist school officials to displace parental religious formation.  It imposes a health-and-safety condition on in-person school attendance to reduce the spread of communicable disease....  The burden may be serious, but it is not the kind of state interference with a child’s religious development that triggered strict scrutiny in Yoder or Mahmoud....

Mahmoud asks whether a burden is “of the same character” as the burden in Yoder, not whether it is more or less serious....  A greater burden in degree is not necessarily the same burden in kind....

Supreme Court Grants Review on Ripeness for RLUIPA Zoning Claims

The Supreme Court yesterday granted review in Grand v. University Heights, (Docket No. 25-965, certiorari granted 6/30/2026) (Order List). In the case, the 6th Circuit Court of Appeals (full text of 6th Circuit opinion) held that plaintiff's claims under the Religious Land Use and Institutionalized Persons Act as well as the 1st and 14th Amendments are not ripe for review.  Plaintiff, an Orthodox Jew, held weekly prayer sessions in his home for himself and his neighbors. After the city raised zoning objections, plaintiff had applied for a special use permit necessary in order to operate a "house of worship" in the area that was zoned U-1. Just before a second hearing on his application, plaintiff withdrew the application. After that hearing, the city took no further action on the application. Some 18 months later, plaintiff filed suit against the city. Affirming the district court's dismissal of the case, the 6th Circuit said in part:

... [N]either the Planning Commission nor the City Council nor the Board of Zoning Appeals has ever determined whether UHCO § 1274.01 applies to the kinds of gatherings he has in mind.  And because Grand withdrew his application, the zoning board has never issued a final decision—or for that matter any decision—about his eligibility for a special use permit.  The government body “charged with implementing the regulations,” in short, has not “reached a final decision regarding the application of the regulations to the property at issue.” ...  Grand’s claims thus never ripened into a dispute suitable for federal review.

Plaintiff's Petition for Certiorari lists as the Question Presented to the Supreme Court: 

Whether the First Amendment's established chilling-effect doctrine-- under which a credible government threat that deters the exercise of fundamental rights constitutes a complete and independently actionable constitutional injury-- is displaced by Williamson Cnty.'s land-use finality requirement when a plaintiff alleges that government threats both before and after a Planning Commission meeting chilled religious exercise, worship, and assembly.

The Court will hear arguments in the case in the Fall. ADF issued a press release announcing the Court's grant of review. [Thanks to Eugene Volokh via Religionlaw for the lead.]

Supreme Court Allows Schools to Exclude Transgender Females from Girls' and Women's Sports Teams

In West Virginia v. B.J.P., (Sup. Ct., June 20, 2026), the U.S. Supreme Court held that states may exclude transgender females from girls' and women's athletic teams without violating either Title IX or the 14th Amendment's Equal Protection Clause. The Court's opinion, written by Justice Kavanaugh, and joined by Chief Justice Roberts, and Justices Thomas, Alito, Gorsuch and Barrett said in part:

Notably, B. P. J. does not seriously contest that the term “sex” in Title IX, the Javits Amendment, and the regulations means biological sex.  Moreover, B. P. J. agrees ... that Title IX permits schools to maintain separate female and male teams and to prohibit most biological males from playing on women’s and girls’ teams.  B. P. J. disagrees with West Virginia and the United States only about whether schools must make an exception to that general rule for biological males who identify as female and have taken puberty blockers or hormones.

But the texts of Title IX, the Javits Amendment, and the Title IX regulations do not say (or even hint) that schools must allow certain biological males to participate in women’s and girls’ sports....

Some percentage of biological males who identify as male possess physical and athletic capabilities that fall within (or below) the range of typical female physical and athletic capabilities. But the plaintiffs acknowledge that States may still exclude those biological males from women’s and girls’ sports, given the general physical differences between males and females.

And the Equal Protection Clause does not prohibit the States from applying that same principle to all biological males, including those who identify as female. In the distinctive sports context, in other words, the States may treat all biological males the same and treat all biological females the same, given the inherent physical differences between biological males and biological females.....

In so ruling, we emphasize one last point.  Most of the biological female and transgender student-athletes who are involved in transgender sports disputes around the country are teenagers or in their early twenties.  Those student athletes want to play sports. Their desire to compete warrants respect. No student-athlete on either side of the issue, whether a biological female or transgender, deserves to be ostracized or vilified.

Justice Thomas filed a concurring opinion, saying in part:

Men and boys with gender dysphoria are not women or girls, even if they believe that they are.  Sex is an immutable “biological” characteristic ...; it is binary; and “man” and “woman,” “boy” and “girl,” are the terms that correspond to adults and children of each sex.... To use language to obscure reality—to show “indifference regarding the truth”— is to lie to the public and cease to treat our fellow citizens “as equal[s].”...

Justice Gorsuch filed a concurring opinion, saying in part:

... Nothing in Title IX clearly and unambiguously alerts funding recipients that they are prohibited from restricting a school-sponsored sports team to biological women or girls....

Justice Sotomayor, joined by Justices Kagan and Jackson filed an opinion concurring only in the judgment, saying in part:

 ... West Virginia might be right that transgender girls retain some inherent athletic advantage over cisgender girls due to their sex identified at birth even after receiving the hormonal therapy B. P. J. identifies. All agree, moreover, that States do have some room to legislate around issues when there exists significant, and genuine, scientific debate. At this point, however, neither the District Court nor the Fourth Circuit has passed upon any of the available evidence or made the necessary factual findings about the state of the scientific debate....

Justice Jackson filed an opinion concurring in the judgment in part and dissenting in part, saying in part:

... [T]he majority is wrong to suggest that the term “sex” in Title IX “cannot plausibly be interpreted to refer to anything other than biological sex.”...  Title IX makes room for individuals to live in the gender they choose; it cares not just about sex assigned at birth but also about individuals’ ability to match (or not) their gender presentation to their gender identity.  Because West Virginia’s law forces B. P. J. to live—in this case, to play—as a boy though she is a girl, it might well run afoul of Title IX properly construed.

Reuters reports on the decision.

Cert. Denied Over Dissent of 3 Justices in Covid Vaccine Mandate Controversy

The U.S. Supreme Court yesterday denied review in Doe v. Hochul , (Docket No. 24-1015, certiorari denied 6/29/2026) over a dissenting opinion by Justice Gorsuch, joined by Justices Thomas and Alito. At issue in the case was New York's refusal to grant state healthcare workers a religious exemption from the state's Covid vaccine mandate. Justice Gorsuch dissenting said in part:

... [T]he Court of Appeals did not assess the reasonableness of the plaintiffs’ requested accommodations.  In fact, the court took as given that the plaintiffs had “plausibly alleged a prima facie case of Title VII religious discrimination.” ... Still, the court held, the defendants had presented a successful “undue hardship” defense as a matter of law....  More specifically, the court reasoned that granting the plaintiffs’ requested religious accommodations would have imposed an “undue hardship” on their employers because it “would have required the [employers] to violate the state [vaccine] regulation” and “subjected the [employers] to financial penalties or a suspension or revocation of their operating licenses.”... 

Soon after it decided this case, the Second Circuit reiterated its understanding of Title VII’s undue hardship defense, holding that “an accommodation that would require an employer to violate” a state law necessarily “imposes an undue hardship”—and does so even when the state law is “unconstitutional as applied” to the plaintiff....

... [I]t seems to me that state law cannot control whether an employer faces an “undue hardship” for purposes of federal antidiscrimination laws, just like it cannot conclusively resolve what constitutes a “reasonable accommodation”.... To hold otherwise would appear to leave States free to strip individuals of the protections guaranteed by so many federal civil rights statutes....

Supreme Court Grants Review on Standing of Parents to Challenge Notification About Children Receiving Gender-Affirming Care

The U.S. Supreme Court yesterday granted review in International Partners for Ethical Care, Inc. v. Ferguson, (Docket No. 25-840, certiorari granted 6/29/2026). (Order List.). At issue in the case is whether parents whose children have gender dysphoria and might run away from home in the future have standing to challenge a group of Washington laws that exempt youth shelters from notifying parents that their children are in the shelter when the child is seeking gender-affirming care. Instead, the shelter is to notify the Department of Children, Youth and Families (DCYF).  DCYF must then contact the parents and offer to make referrals for behavioral health services and family reconciliation services.

In a July 2025 decision (full text), the 9th Circuit held that parents had not alleged sufficient current or future injury to grant standing. The 9th Circuit subsequently denied en banc review over the dissents of three judges. The petition for certiorari frames the Question Presented as:

Whether parents have standing to challenge a law or policy that deliberately displaces their decision making role as to “gender transitions” of their children, and in so doing creates present and likely future impediments to their ability to parent their children as they deem best for them.

Cert. Petition Filed in Lipan Apache Efforts To Prevent Impairment of Religious Ceremonial Site

A petition for certiorari (full text) was filed with the U.S. Supreme Court last week in Perez v. City of San Antonio, (Sup. Ct., cert. filed 6/26/2026). In the case, the U.S. 5th Circuit Court of Appeals in a 2-1 decision affirmed a trial court's refusal to enjoin San Antonio's development plan for a city park.  Plaintiffs are members of the Lipan-Apache Native American Church. Certain of their religious ceremonies can take place only at a particular river bend in the park and require the presence of cormorants in the trees there. The development plan will remove trees and modify bird habitats. (See prior posting. and 5th Circuit's amended opinion.) The petition for review sets out the Questions Presented as:

1. Whether the Religion Clauses of the First Amendment permit courts, when deciding whether government action burdens religious exercise, to override a claimant’s sincere theological judgment of what the religious exercise requires. 

2.  Whether the government can satisfy its burden to prove that its action is the least religiously restrictive means available when, after notice that its action would burden religious exercise, the government admits that it failed to consider any workable alternatives prior to litigation.

First Liberty Institute issued a press release announcing the filing of the petition.

Michigan AG Releases Report on Sexual Abuse in Saginaw Catholic Diocese

On June 25, Michigan Attorney General Dana Nessel released a 258-page report titled Diocese of Saginaw: A Complete Accounting (full text). It is the sixth of what will be seven reports on allegations of sexual abuse or assault and other sexual misconduct by priests or deacons in each of Michigan's seven dioceses. Last week's report contains information on complaints against 37 Catholic priests and one deacon in the Saginaw diocese. The Attorney General says:

To date, eleven cases have been brought by the Department of Attorney General for all seven dioceses.  Nine have resolved with convictions.  Of these eleven cases, none of them related to priests ministering in the Diocese of Saginaw.

Bishop Robert Guss responded to the Report through a posting on the Diocese's website that says in part:

• For the 37 priests and one deacon, 30 are known or presumed to be dead. For the 8 who are living or presumed to be living, none are in active ministry.
• For the 37 priests and one deacon, other than a few entries, the conduct as alleged that may have violated Michigan criminal law all occurred before 2002, the year of the U.S. Bishops’ Charter.
• The vast majority of reported abuse cases in our diocese are very old, with most occurring in the 1970s and 1980s.

He also held a news conference and issued a letter responding to the Report and saying in part:

I want to express my deepest sorrows to those who have been victims of abuse by members of the clergy. Please accept my sincere apology for the pain and suffering you have experienced by those who were entrusted with your care. I'm deep]y saddened by it all. And, again, I apologize to you on behalf of the Church and our Diocese.

The Abuse Survivors Coalition issued a statement saying in part:

The Bishop’s words ignored the systemic problem and minimized what occurred during the time period covered in the report. For example, Bishop Gruss apologized for the trust that has been broken by the “misconduct of a few.” But childhood sexual abuse by clergy is not “misconduct.” It is serious criminal behavior resulting in life-long damage to the victims. Moreover, the Bishop completely ignored the issue of highly placed Catholic officials who allowed identified abusers to remain in ministry and harm additional young lives.

Recent Articles of Interest

From SSRN:

• Ayaga Max Liambilah & Miracle Mudeyi, Thou Shalt Not Replace Humanity: A Commentary on Pope Leo XIV's Encyclical on AI and the Digital Age, (The Platform Magazine, Volume 125, June 2026 Issue).
• Alexander Yu. Monakhov, Religion as a Legal Argument: Three Legal Collisions Concerning Russia, Ukraine, and the Vatican, (June 03, 2026).
• Lynne Marie Kohm, C.S. Lewis’ Enduring and Unpretentious Lessons on Stepparent Child Custody - Part 1: “A Ticklish Job” — The Story Behind the Custody Crisis, (June 01, 2026).
• Mark Storslee, Free Exercise and Funding, (Notre Dame L. Rev. (forthcoming 2026)).
• Christopher C. Lund, Religious Liberty and the New Ten Commandments Cases, (Wayne State University Law School Research Paper (forthcoming)).
• Zachary D. Fasman & Samuel Estreicher, Institutional Liability for Campus Harassment of Jewish Students, (June 06, 2026).
• Daniel J. Hemel, Madisonian Nonprofit Law, (64 Harvard Journal on Legislation (forthcoming 2027)).

From SSRN (Islamic Law):

• Oruj Ismayilov, The Readable Cosmos: Science, Consciousness, and the Qurʼanic Concept of Āyāt, (May 23, 2026).
• Oruj Ismayilov, The Readability of Reality: Information, Consciousness, and the Metaphysics of Meaning, (June 05, 2026).
• Irfan Haroon, Islamic Banking in Pakistan: Shariah Compliance or Rebranded Riba? A Critical Analysis, June 02, 2026).
• Syafiq Izwan Ramlan, Reconceptualising Fiqh Muamalat Through Contemporary Theory Development Analysis (June 03, 2026).
• Irfan Haroon, Islamic Banking: Halal or Haram? The Accountant's Verdict and the Regulator's Confession: A Critical Legal and Financial Analysis, (June 02, 2026).
• Osama S. Qatrani, Justice, Mercy, and the Spirit of Law: Is Law a Tool of Punishment, Guidance, Accountability, Protection, or Revenge?, (June 05, 2026).

From SmartCILP and elsewhere:

• Nicole Stelle Garnett & John A. Meiser, Two Questions for School-Choice Funding After Carson, 24 First Amendment Law Review 157-194 (2026).
• Lori Freedman, Debra Stulberg & Elizabeth Reiner Platt, Not Here or There: How Catholic Hospital Abortion Bans Interact with State Bans, 28 Journal of Health Care Law & Policy 180-198 (2025).
• Itamar Rosensweig & Shua Mermelstein, Dignity, Equality, and the Duty of Assistance, 40 Touro Law Review 715-741 (2025).
• Kevin Tempe, Private Religious Schools and Disability Discrimination, 40 Touro Law Review 787-813 (2025).
• Aaron Tang & Ethan Hunt, "Original History" and the Free Exercise Case for Religious Charter Schools, 103 Washington University Law Review 639-704 (2026).
• Arvind Kurian Abraham, Remembering Gordon Wood: Religion and the Republic, (Balkinization blog, June 10, 2026).

Supreme Court Review Sought by Teacher Who Objects to School's Gender identity Policy

 A petition for certiorari (full text) was filed with the U.S. Supreme Court last week in Polk v. Montgomery County Public Schools, (Sup. Ct., cert. filed 6/26/2026). In the case, the U.S. 4th Circuit Court of Appeals upheld the denial of a preliminary injunction sought by a substitute teacher who objected on free speech and free exercise grounds to a Maryland school district's Guidelines for Student Gender Identity. (See prior posting.) The petition for review poses the Questions Presented as:

1. When public schools try to force teachers, over their religious objections, to use pronouns inconsistent with a student’s biological sex and to hide from parents information about their child’s gender expression at school, does Smith apply and foreclose heightened scrutiny under the Free Exercise Clause?  

2. Do public schools violate the Free Speech Clause when they compel objecting teachers to adhere to such a school policy?

ADF issued a press release announcing the filing of the petition.

President's Religious Liberty Commission Delivers Draft Report

On June 26, the President's Religious Liberty Commission delivered its draft report to the President. (Press Release).  The 224-page Report (full text) sets out numerous recommendations for various segments of society and government.  The Report's Executive Summary concludes in part:

... People often use the metaphor “wall of separation of church and state” to justify excluding religious Americans from equal participation in the public square. But the “wall of separation” phrase does not appear in the First Amendment or anywhere else in the Constitution. What the First Amendment does say about the relationship between religion and the government is that “Congress shall make no law respecting an establishment of religion or prohibiting the free exercise thereof.” In practical terms, that means that the government may not officially prefer one religion over another, take over the functions of a church, or coerce religious observance. 

Nothing in the First Amendment allows the government to create a “wall” between an individual’s personal faith and our nation’s public life. The idea that it does allow—or even require—a “wall of separation” only took off in the mid-twentieth century, when the Supreme Court began citing Thomas Jefferson’s 1802 letter to the Danbury Baptist Association, written 10 years after the First Amendment was ratified.

One belabored metaphor—often used out of context—cannot support the view that the aim of the First Amendment was to exile the practice of religion from public life. And no Founding document supports that conclusion either....

The concept of a “wall of separation between church and state” can wrongly imply that church and state are opposed to one another and must remain completely separate. In reality, however, church and state strengthen and support one another. Perhaps a better analogy is that religious liberty acts as a bridge between church and state. In other words, when people of faith exercise their religious liberty by living that faith—from praying to serving the poor to treating people with charity to upholding moral standards—they live more fulfilling lives, build vibrant families, bolster our communities, and ultimately, strengthen our nation. In this way, religious liberty isn’t simply an appendage of our society. It is the beating heart of our republic and the lifeblood of America’s success....

The Report is open for public comment for 15 days.

Texas Adopts Required Reading List for Schools, Including Biblical Stories and Verses for Gades 1-12

Yesterday, the Texas State Board of Education approved a required reading list for each grade from kindergarten through high school. The list includes Bible verses or stories for every grade except kindergarten.  Zeale reports:  

The Republican-controlled board voted 9-5 with one member absent to adopt the reading lists, which were required under a 2023 state law directing the board to specify required vocabulary and at least one literary work for each grade level. The adopted lists contain nearly 200 literary works spanning kindergarten through high school, including selections from the Bible alongside classic works by authors such as William Shakespeare, Jane Austen, Charles Dickens, and E.B. White.

The requirements will take effect beginning with the 2030-2031 school year....

The reading lists assign different Bible passages from specific translations, including the New International Reader’s Version, King James Version, and English Standard Version. 

According to the Houston Chronicle:

The book list makes Texas the only state in the country to issue its own literature requirements, rather than leaving the choices up to teachers or districts....

Though teachers may still select other books to supplement the list, many testified prior to the vote that the required list was already too long to be taught within a single school year.

Here are the Biblical verses and stories required (as amended): 1st Grade- Jonah and the Whale by Jonah 1:1-5, 10-17, 2:10; 2nd Grade- David and Goliath (excerpt from The Children's Book of Heroes) by William J. Bennett (editor); 3rd Grade- ROAR! – Daniel and the Lion's Den – Children's Adapted Version by CBN; 

4th Grade: The Necessity of Humility (Book of Luke, Chapter 14, Verses 7-11) by New International Reader's Version: New Testament; 5th Grade- Moses (Book of Exodus, Chapter 3: The Burning Bush and Book of Exodus, Chapter 14: The Parting of the Red Sea) by New International Reader's Version: Hebrew Bible/Old Testament; 6th Grade- Do Not Be Anxious (Book of Matthew, Chapter 6, Verses 25-34) by English Standard Version: New Testament; 

7th Grade- The Shepherd's Psalm (Book of Psalms, Chapter 23) by King James Version: Hebrew Bible/Old Testament; The Eight Beatitudes (Book of Matthew, Chapter 5, Verses 1-12) by King James Version: New Testament; 8th Grade- To Everything There is a Season (Book of Ecclesiastes, Chapter 3) by King James Version: Hebrew Bible/Old Testament; Book of Lamentations, Chapter 3 by Tanakh: Jewish Publication Society 1917.

English 1 (9th grade)-Parable of the Prodigal Son (Book of Luke, Chapter 15, Verses 11-32) by English Standard Translation: New Testament; English II (10th Grade)- The Book of Job (Book of Job, Chapters 1-7,11,14,19,28,38-42) by New International Reader's Version: Hebrew Bible/Old Testament; English III (11th Grade)- Adam and Eve (Book of Genesis, Chapters 2 and 3) by New International Reader's Version: Hebrew Bible/Old Testament; English IV (12th Grade): The Definition of Love (Book of 1 Corinthians, Chapter 13) by English Standard Version: New Testament.

A video of the full board meeting that adopted the reading requirements is available online. (Discussion of the proposal begins at 54:21). AP also reports on the Board's action.

Suit Charging Misrepresentation of Use of Tithed Funds Dismissed on Ecclesiastical Abstention Grounds

In Leach v. Gateway Church, (ED TX, June 23, 2026), a Texas federal district court dismissed on ecclesiastical abstention grounds a class action suit brought by donors to the church who claim that the church misrepresented the charities to which tithed funds would be distributed. The court said in part:

Plaintiffs allege that Defendants represented or promised that “15% of all tithe dollars would be distributed to global missions and Jewish ministry partners,” inducing Plaintiffs to give generously toward these ends.... Plaintiffs contend that Defendants made these representations through various mediums, including during sermons, in the “Members’ Handbook,” at conferences, and on Gateway’s website..... Plaintiffs assert that Defendants did not allocate these funds as they represented that they would.... Plaintiffs argue that Defendants’ reallocation of their tithe dollars from “global missions” and “Jewish ministries” to “secret organizations” or to other “charitable purposes,” ... was an improper transfer....

The claims at issue will implicitly require the Court to determine the meaning of Plaintiff’s references to “global missions,” “Jewish ministry partners,” “local, national, and international outreach efforts,” and other terms that implicate religious beliefs.... 

... [W]hile both parties acknowledge Plaintiffs’ claims are grounded in traditional civil law, resolving the claims would require the court to examine the management of Gateway’s donated funds, which will “necessarily implicate[] questions of faith, scripture, and religious doctrine.”...

Further, resolving Plaintiffs’ claims would require the Court to “evaluat[e] the truth of [a] sermon.”... Plaintiffs specifically alleged that two senior pastors promised to give the congregation their money back if they were dissatisfied with how the church used it.... These promises were purportedly made during sermons....

... [T]his analysis may have been different if Plaintiffs had alleged that Morris, Dulin, or any other Gateway leader reallocated their tithe dollars for personal gain....

Fort Worth Report reports on the decision.