Wisconsin Legislature Passes Parental Bill of Rights; Governor Promises Veto

On Tuesday, the Wisconsin Senate gave final legislative passage to AB 510 (full text), known as the Parental Bill of Rights. The bill gives 16 different rights to parents and guardians of school children.  Among these are the right to determine a child's religion; the right to determine the names and pronouns used for the child at school; the right to notice when a controversial subject will be taught or discussed in the child's classroom; and the right to opt the child out of a class or instructional materials based on religion or personal conviction. The Wisconsin ACLU criticized the bill, saying in part:

This bill disguises classroom censorship as parental rights, enabling politicians to require the forced outing, misgendering, and deadnaming of trans and nonbinary students. It also inhibits educational instruction on race, gender, sexual orientation, and other important topics that impact all of us.

According to a report on the bill by The Center Square, Governor Tony Evers has said he will veto the bill.

Former Editor of Yiddish Children's Magazine Sues Rabbinical Courts and Others Under RICO and Sherman Act

Suit was filed last month in a New York federal bankruptcy court against several rabbinical courts, rabbis, and other defendants charging Sherman Act and RICO violations. Plaintiff was the co-owner of a Yiddish language children's magazine who claims his former partner conspired with others to destroy his business. (Full text of 93-page complaint in In re Paneth v. Reiner, (ED NY Bkrptcy, filed 1/17/2024)). Shtetl has published a lengthy summary of the complaint, saying in part:

... Paneth claims that investor David Reiner used money and influence to sway leading Haredi rabbinical courts to coerce Paneth into a rabbinic arbitration process over disputes relating to the operation and management of Kindlein magazine.

... Ultimately, the complaint says, the rabbinical courts and Reiner collectively violated the Sherman Antitrust Act by colluding to put Paneth out of business and thereby eliminate Reiner’s only competition. They also sought to deprive Paneth of any employment opportunities and to ostracize him from the Hasidic world, the complaint says.

European Court Says Ban on Halal and Kosher Slaughter Does Not Violate Human Rights Convention

 In Affaire Executife van de Moslims van Belgie et Autres c. Belgique, (ECHR, Feb. 13, 2024) [full opinion available only in French], the European Court of Human Rights, in a Chamber Judgment, held that Belgium had not violated Article 9 (freedom of religion) or Article 14 (prohibition of discrimination) of the European Convention on Human Rights when two regions in the country eliminated the exemption permitting ritual slaughter of animals without stunning. The decrees had the effect of prohibiting Halal and kosher slaughter of animals in the two regions. An English language press release from the Court describes the Court's opinion, in part, as follows:

The Court found that there had been an interference with the applicants’ freedom of religion and that this was prescribed by legislation, namely the Flemish and Walloon decrees. 

As to whether the interference pursued a legitimate aim, the Court observed that this was the first time that it had had to rule on the question whether the protection of animal welfare could be linked to one of the aims referred to in Article 9 of the Convention.

Article 9 of the Convention did not contain an explicit reference to the protection of animal welfare in the exhaustive list of legitimate aims that might justify an interference with the freedom to manifest one’s religion.

However, the Court considered that the protection of public morals, to which Article 9 of the Convention referred, could not be understood as being intended solely to protect human dignity in the sphere of inter-personal relations. The Convention was not indifferent to the living environment of individuals covered by its protection and in particular to animals, whose protection had already been considered by the Court. Accordingly, the Convention could not be interpreted as promoting the absolute upholding of the rights and freedoms it enshrined without regard to animal suffering. 

Emphasising that the concept of “morals” was inherently evolutive, the Court did not see any reason to contradict the CJEU and the Constitutional Court, which had both found that the protection of animal welfare was an ethical value to which contemporary democratic societies attached growing importance....

The Court noted that both decrees were based on a scientific consensus that prior stunning was the optimum means of reducing the animal’s suffering at the time of slaughter. It saw no serious reason to call this finding into question.

The Court further observed that the Flemish and Walloon legislatures had sought a proportionate alternative to the obligation of prior stunning, as the decrees provided that, if the animals were slaughtered according to special methods required by religious rites, the stunning process used would be reversible, without causing the animal’s death....

Church of England Faces Controversy Over Insincere Conversions to Gain Asylum

 The Telegraph reports on the controversy in Britain over whether the Church of England has been misled into converting Muslim migrants whose only motivation is to claim asylum on the basis of a threat of persecution if they return to their home countries as Christians. The paper reported in part:

The Rt Revd Dr Guli Francis-Dehqani, the Bishop of Chelmsford, conceded it was “very difficult” to look into the hearts of converts and be 100 per cent certain that they were genuine.

She acknowledged there had been a “small number” of alleged abuses but said the clergy “do the best they can” and it was “ultimately” the job of immigration tribunals and the Home Office to assess and vet the validity of asylum claims.

Her comments come after robust denials by the Church of England of claims by senior MPs and whistleblowers that clergy have been routinely supporting “bogus” asylum claims and enabled a “conveyor belt” of thousands of asylum seekers to convert.

As reported by Law & Religion UK, questions about this issue were raised in Parliament last week, which in turn led the Archbishop of Canterbury last week to issue a statement (full text) in response, saying in part:

For refugees and those seeking asylum, we simply follow the teaching of the Bible which is to care for the stranger.

It is the job of the Government to protect our borders and of the courts to judge asylum cases. The Church is called to love mercy and do justice....

Recent Articles and Books of Interest

From SSRN:

• Andrew Coan, Dobbs v. Brown, (J. Am. Con. Hist., Forthcoming Vol. 2 (Winter 2024)).
• Kent Greenfield, Using the First Amendment to Save Race-Conscious College Admissions, (Forthcoming, 4 American Journal of Law and Equality __ (2024)).
• Chad G. Marzen, Insurance Law and Religious Belief, (February 5, 2024).
• Rabiat Akande, An Imperial History of Race-Religion in International Law, (American Journal of International Law. 2024;118(1):1-40).
• Clark D. Cunningham & Ute Römer-Barron, Four Reasons the Supreme Court Should Reconsider Its Article III Standing Doctrine, (Forthcoming, Ohio State Law Journal Online, v. 85, 2024).
• Elias Neibart, M.A. v. Rockland County Department of Health, 53 F.4th 29 (2d Cir. 2022), (Harvard Law Review, Vol. 137, No. 3, p. 1050, 2024).
• Liz Tobin-Tyler, The Past and Future of Parental Rights: Politics, Power, Pluralism, and Public Health, (Virginia Journal of Social Policy and the Law, Vol. 30, No. 3, 2023).
• Mihir Rajamane & Vibha Swaminathan, Navigating Reservations for Transgender Persons Under the Indian Constitution, (in TransForming Rights: How Law shapes Transgender Lives, Community and Identity in India (Forthcoming)).
• Toheeb Alimi, Islamic Finance: an Overview, (January 12, 2024).

From SmartCILP:

• Louis Lopez, The Supreme Court's 2021–22 Term in Review, 37 A.B.A. Journal of Labor & Employment Law 1-24 (2023).
• Kenji Yoshino, Rights of First Refusal, 137 Harvard Law Review 244-289 (2023).
• Ronna Greff Schneider, School Matters, 92 University of Cincinnati Law Review 1-11 (2023).
• Erwin Chemerinsky, Education, the First Amendment and the Constitution,92 University of Cincinnati Law Review 12-30 (2023).

Recent and Forthcoming Books:

• John Witte, Jr. & Rafael Domingo, The Oxford Handbook of Christianity and Law, (Oxford University Press, Dec. 2023).
• Maurice Samuels, Alfred Dreyfus: The Man at the Center of the Affair, (Yale University Press, Feb. 2024).
• Russell Sandberg, Rethinking Law and Religion, (Edward Elgar Publishing, June 2024).

Expressed Hostility to Religious Belief of Vaccine Exemption Applicant Did Not Violate 1st Amendment

 In Hancock v. Oregon Health and Science University, (D OR, Feb. 8, 2024), an Oregon federal district court dismissed without prejudice a claim by a lecturer at the University that her 1st Amendment rights were violated in the process of denying her claim of a religious exemption from the University's Covid vaccine mandate.  Plaintiff claimed that various of the defendants:

... expressed overt hostility to the religious beliefs of Plaintiff by declaring Plaintiff's religious beliefs 'personal moral choices and/or conscientious objection rather than a tenet of a religious faith,' merely her 'right to have religious freedom or conscientiously object to the vaccine' rather than a sincerely held religious belief and 'concerns over vaccine safety or content' not a sincerely held religious belief but rather a 'religious argument' and 'inconsistent with proven facts.'

The court held that mere expression of hostility toward plaintiff's religious beliefs does not create tangible harm that can be remedied, and so plaintiff lacks standing. It went on to hold that even if plaintiff had standing, she did not adequately allege that defendants substantially burdened her religious beliefs. The court said in part:

At best, the Court identifies only two allegations that could plausibly be related to coercion: (1) "Defendant OHSU's request for additional information was meant to belittle and shame Plaintiff for her religious beliefs and convince her she did not possess the religious beliefs she possessed"; and (2) "Board Defendant's [sic] placed pressure on Plaintiff to conform to the prevailing approved religion by proclaiming which religious beliefs were worthy of religious exceptions and which were not."...

... [N]either allegation addresses what effect this alleged pressure had on plaintiff.

Finally, the court concluded that defendants are entitled to qualified immunity. 

Canadian Court Upholds Denial of Tax Exemption for Island Owned by Shinto Organization

In Matsuri Foundation of Canada v. British Columbia (Assessor of Area #01 - Capital), (BC Sup. Ct., February 2, 2024), the Supreme Court of the Canadian province of British Columbia upheld the denial of a property tax exemption sought by the Matsuri Foundation of Canada.  The court summarized its decision as follows:

Matsuri sought, and the Board denied, a property tax exemption for the lands and improvements that comprise Knapp Island, British Columbia, as a “place of public worship” pursuant to s. 15(1)(d) of the Taxation (Rural Area) Act, R.S.B.C. 1996, c. 448 [Rural Area Taxation Act].

Knapp Island is a 31-acre island located just off Vancouver Island’s Saanich Peninsula near Swartz Bay. Matsuri is a registered Canadian charity with the purpose of the advancement of the Shinto religion. Matsuri owns Knapp Island.

With respect to the 2022 taxation year, the [Property Assessment Appeal] Board found that the “place of public worship” exemption was not applicable to Knapp Island because Matsuri had not established that the public were invited to, and had access to, Knapp Island, and that its principal use was therefore not for public worship. The Board found that to the extent that Knapp Island was used for worship, that worship was private, and not public.

Matsuri accepts the Board’s factual finding on this issue. However, Matsuri argues that the Board should nevertheless have found that Knapp Island was entitled to an exemption on fairness and equity grounds, when compared to other similar properties in British Columbia.

The Assessor argues that the Board’s decision should be upheld, and that the evidence does not support a tax exemption on equity grounds.

I find that the Board’s analysis fully addressed the equity issue in this case, and properly denied the requested exemption, and I would therefore dismiss the appeal.

CTV News reports on the decision.

British Employment Tribunal Holds That Anti-Zionist Views Are a Protected Philosophical Belief

In Miller v. University of Bristol, (Bristol Empl. Trib., Feb. 5, 2024), a British Employment Tribunal held that anti-Zionist views held by a Professor of Political Sociology at the University of Bristol qualify as a philosophical belief that is protected under Equality Act 2010, Sec. 4 and 10. In a 108-page, 495 paragraph opinion, the Tribunal describes the professor's claims:

He contends that since at least March 2019 he was subject to an organised campaign by groups and individuals opposed to his anti-Zionist views, which was aimed at securing his dismissal. Further, he alleges that the respondent failed to investigate or support him in respect of this campaign and instead subjected him to discriminatory and unfair misconduct proceedings which culminated eventually in his summary dismissal.

In reaching its conclusion that the professor's beliefs were protected, the court applied the criteria from an Employment Appeals Tribunal decision, Grainger Plc v. Nicholson, one of which is that the belief "must be worthy of respect in a democratic society, be not incompatible with human dignity and not conflict with the fundamental rights of others."

The professor contended "that his anti-Zionism is not opposition to or antipathy towards Jews or Judaism," and apparently the University conceded that none of his actions or statements were antisemitic.

The court, in finding that the professor's beliefs are protected, said in part:

... [W]hile those in opposition to the claimant's views could logically and cogently argue that antisemitism is why Zionism exists in the first place, it is not for the tribunal to inquire into the validity of either belief.... 

The tribunal is aware that there are very strong opposing beliefs and opinions to those held and expressed by the claimant. However, ... the paramount guiding principle in assessing any belief is that it is not for the court or tribunal to inquire into its validity.

In a press release commenting on the court's decision, the University said in part:

 After a full investigation and careful deliberation, the University concluded that Dr Miller did not meet the standards of behaviour we expect from our staff in relation to comments he made in February 2021 about students and student societies linked to the University. As a result and considering our responsibilities to our students and the wider University community, his employment was terminated. 

Law & Religion UK has a lengthier discussion of the decision.

5th Circuit, 11-6, Denies En Banc Rehearing on Availability of Damages Under RLUIPA

In Landor v. Louisiana Department of Corrections and Public Safety, (5th Cir., Feb. 5, 2024), the U.S. 5th Circuit Court of Appeals, by a vote of 11-6, denied an en banc rehearing in a RLUIPA suit seeking damages from officials in their individual capacities. Judge Clement, joined by 8 other judges, filed an opinion concurring in the denial, saying in part:

Officials at the Raymond Laborde Correctional Center knowingly violated Damon Landor’s rights in a stark and egregious manner, literally throwing in the trash our opinion holding that Louisiana’s policy of cutting Rastafarians’ hair violated the Religious Land Use and Institutionalized Persons Act before pinning Landor down and shaving his head. Landor clearly suffered a grave legal wrong. The question is whether a damages remedy is available to him under RLUIPA. That is a question only the Supreme Court can answer.

Judge Ho, joined by Judge Elrod, filed a dissent to the denial. Judge Oldham, joined in whole or part by 5 other judges, also filed a dissenting opinion, saying in part:

The panel held RLUIPA does not allow prisoners to sue state prison officials in their individual capacities for money damages. With all due respect to my esteemed and learned colleagues, that result cannot be squared with Tanzin v. Tanvir, 592 U.S. 43 (2020). Tanzin held that individuals can sue for money damages under the Religious Freedom Restoration Act of 1993 (“RFRA”). The operative provisions of RFRA and RLUIPA are in haec verba, and both the Supreme Court and ours routinely interpret the statutes in parallel. Today, unfortunately for Landor, our court pits the statutes against one another. I respectfully dissent.

Montreal Archdiocese Sues for Exemption from End-of-Life Care Requirements

 In Canada, the Archdiocese of Montreal has filed suit in a Quebec trial court seeking an exemption from amendments to the province's Act Respecting End-of-Life Care which require all palliative care homes to provide "medical aid in dying." The Archdiocese operates a 12-bed palliative care home in Montreal. The full text of the complaint in Les Oeuvres de Charite de L'Archeveque Catholique Romain de Montreal v. Procureur General du Quebec, (Couer Superieure, filed Feb. 2, 2024) is available only in French. An English Language Press Release from the Archdiocese describes the lawsuit in part::

To our profound dismay, the amendment to the Act respecting end-of-life care and other legislative provisions, SQ 2023, c. 15 (the new Act), effective since December 7, 2023, has regretfully prohibited palliative care homes from excluding "medical aid in dying" from their services.  

A consequence of this new law is that actions we find morally unacceptable may now occur on our property.....  

In essence, the Appeal is simply seeking permission for palliative care homes, similar to health professionals, to "refuse to administer medical aid in dying based on their personal convictions and [to] refuse to participate in its administration for the same reason."  

We strongly believe that by mandating all palliative care homes to provide "medical aid in dying" without considering their mission, values, and the support of their community, the new law significantly undermines the exercise of the right to freedom of religion and conscience, as well as the right to the peaceful enjoyment and free disposal of one's property, guaranteed by the Canadian Charter and the Quebec Charter.   

Palliative care homes, given that they operate as community organizations and not public institutions, should retain the ability to define their own mission and the services they are willing to offer, as was the practice until recently....

Canadian Press reports on the lawsuit.

Satanic Temple Loses Challenge to Idaho Abortion Bans

In The Satanic Temple v. Labrador, (D ID, Jan. 31, 2024), an Idaho federal district court dismissed several challenges to Idaho's statutes criminalizing abortion filed by The Satanic Temple which has created its own Abortion Ritual.  The court describes plaintiff's claims:

The Satanic Temple (“TST”) filed the instant case arguing Defendants actions have: (1) effected a regulatory taking of the economic value of a pregnant woman’s womb in violation of the Fifth Amendment; (2) effectively made pregnant women into slaves in violation of the Thirteenth Amendment; (3) given unconstitutional preferences to rape victims in violation of the Fourteenth Amendment; and (4) violated Idaho’s religious freedom statutes.

After finding that TST lacks standing to bring the suit, the court goes on to also reject TST's first three claims on the merits and concludes that TST, which asked to file an amended complaint to substitute a free exercise claim for its claim under Idaho's Exercise of Religious Freedom Act, should do this by fining a new lawsuit rather than an amended complaint.

Idaho Attorney General Labrador issued a press release announcing the decision which he titled "Attorney General Labrador Defeats Satan." LifeNews reporting on the decision said that lawyers for TST plan an appeal to the 9th Circuit.

2nd Circuit: Delivering Inmate's Ramadan Meals Too Early Burdened His Free Exercise Rights

In Long v. Sugai, (2d Cir., Feb. 5, 2024), the U.S. 2nd Circuit Court of Appeals held that a Hawaii prison sergeant may have violated plaintiff inmate's free exercise rights by delivering his Ramadan meals 4 hours before sundown.  The court said in part:

The question in the case before us is not whether serving cold, unappetizing, and possibly unsafe food is cruel and unusual punishment.  Rather, it is whether serving such food unconstitutionally burdened Long’s free exercise of his religion....

... [B]y the time Long could eat his evening meal at about 7:30 p.m., the food was often inedible and potentially unsafe, and, if eaten, exacerbated his stomach ulcers.  We take judicial notice of the fact that some food cannot safely sit at room temperature for four hours....

... [D]elivery of Long’s evening meal at 3:30 p.m. during Ramadan substantially burdened his free exercise of religion.  The district court should have evaluated the four Turner factors to determine whether the burden was justified.  Because the court did not conduct that analysis, we remand to allow it to do so.  The district court also did not conduct a qualified immunity analysis.  If the court concludes, after conducting the Turner analysis, that the burden was not justified, our remand allows the court to conduct a qualified immunity analysis. ...

The court affirmed the district court's dismissal of free exercise claims against another sergeant.

Recent Articles of Interest

From SSRN:

• Ekaterina Ryzhkova, Arab Constitutionalism: Lessons from History, (October 11, 2023).
• Eric Ruben, Scientific Context, Suicide Prevention, and the Second Amendment After Bruen, (Minnesota Law Review, Forthcoming).
• Andrew Coan, Too Much, Too Quickly?, (Arizona Legal Studies Discussion Paper No. 24-04 (2024).
• Liz Tobin-Tyler, The Past and Future of Parental Rights: Politics, Power, Pluralism, and Public Health, (Virginia Journal of Social Policy and the Law, Vol. 30, No. 3, 2023).
• Deborah L. Brake, The New Gender Panic in Sport: Why State Laws Banning Transgender Athletes Are Unconstitutional, (ConLawNOW, Vol. 15, p. 33, 2024).
• Jeff Sovern, Is Discrimination Unfair?, (U of Maryland Legal Studies Research Paper No. 2024-02 (2024).
• Norman Ho, Confucian Legal Hypotheticals, (The Journal of Comparative Law, Vol. 18, No. 2 (2023)).
• Andrew Godwin & Rosemary Teele Langford, Corporations, Financial Services and Charities: Regulatory Complexity and Coherence, ((2023) 39 Australian Journal of Corporate Law 51).

From SSRN:

• Stephen L. Mikochik, Pope Francis and Civil Unions, 20 Ave Maria Law Review 96-104 (2022).
• J. Kirkland Miller & Maureen M. Milliron, Ownership of Property and Adverse Possession from the Catholic Perspective: You've Got to Have (Good) Faith!, 20 Ave Maria Law Review 125-159 (2022).
• Marc O. DeGirolami, The New Disestablishments, 33 George Mason University Civil Rights Law Journal 71-102 (2022).

New Jersey Man Pleads Guilty to Hate Crimes Against 5 Orthodox Jews

In a Feb. 1 press release, the U.S. Attorney's Office for the district of New Jersey announced that 29-year old Dion Marsh has pleaded guilty to violations of the Matthew Shepard and James Byrd Jr. Hate Crimes Prevention Act and to a count of carjacking for his assault on 5 men on April 8, 2022.  According to a statement by the U.S. Attorney:

This defendant violently attacked five men, driving a car into four of them, stabbing one of them in the chest, and attempting to kill them, simply because they were visibly identifiable as Orthodox Jews....

Sentencing is set for June 11.

Good News Clubs Sue for Access to Hawaii Schools

Suit was filed two weeks ago in a Hawaii federal district court against the Hawaii Department of Education and four school districts in which schools have denied permission for Good News Clubs to use various school facilities for after-school programs. The complaint (full text) in Child Evangelism Fellowship of Hawaii, Inc. v. Hawaii State Department of Education, (D HI, filed 1/23/2024), alleges that the denials violate plaintiff's free speech, free exercise, Establishment Clause and equal protection rights. Plaintiff has also filed a Motion for Preliminary Injunction accompanied by a Memorandum of Law supporting the Motion (full text). Liberty Counsel issued a press release announcing the filing of the lawsuit.

Questions of Fact Remain in Challenge to Application Process for Prison Chaplaincy Supervisor

 In Bridges v. Prince Georges County, Maryland, (D MD, Feb. 1, 2024), a Maryland federal district court refused to grant summary judgment for either plaintiff or the defendants in a suit by a Muslim chaplain alleging that his 1st Amendment rights were violated by the application process for a paid supervisory position at the county detention center.  At issue was a "Statement of Applicant's Christian Faith" that was part of the application form created by Prison Ministry of America (PMA) which, under contract with the county, was to provide a non-denominational chaplain supervisor for the jail.  After finding that plaintiff had standing and that PMA was a state actor during the hiring process, the court said in part:

Because a reasonable jury could find the Statement of Christian Faith to be “a religious test” ..., summary judgment cannot be granted in favor of Defendants on this count.  However, Defendants’ assertion that the Statement was optional creates a sufficient dispute of material fact as to render summary judgment inappropriate in Plaintiff’s favor, as well....

Regardless of whether the Statement of Christian Faith was mandatory or not, the inclusion of such a statement, especially given that it appeared on its face to be required, clearly employed a non-neutral policy as it specifically allowed for participation by Christians and no others.  This non-neutral practice, then, could be viewed by a reasonable jury as placing a burden on Plaintiff’s religious expression by denying him the ability to apply for a job that he otherwise would have been able to seek, due to his religion....  As such, a reasonable jury could find that this burdened Plaintiff’s freedom of expression and that the policy was not narrowly tailored to meet a compelling government interest, and thus summary judgment cannot be granted in favor of Defendants.  However, the question of whether the inclusion of the Statement of Christian Faith in the application burdened Plaintiff’s religious exercise, given Defendants’ assertion that the Statement of Christian Faith was not actually required, creates a genuine dispute of material fact, and, therefore, summary judgment cannot be granted in favor of Plaintiff, either.

European Court: Azerbaijan's Ban on Foreign Educated Imams Violates European Convention

In Babayev v. Azerbaijan, (ECHR, Feb. 1, 2024), the European Court of Human Rights held that Article 9 of the European Convention on Human Rights (freedom of thought, conscience and religion) is violated by Azerbaijan's law prohibiting citizens of the country who obtained their religious education abroad from conducting Islamic religious rites and rituals in Azerbaijan. In awarding petitioner, who had been sentenced to three years in prison for violating the law, damages of 6000 Euros, plus costs and expenses, the court said in part:

75.... The Court notes that there is no indication whatsoever that the Islamic religious rites and rituals that the applicant conducted contained any expressions or constituted any actions, such as, for example, seeking to spread, incite or justify hatred, discrimination or intolerance, or otherwise undermine the ideals and values of a democratic society....

76.... The Court is aware of the fundamental importance of secularism in Azerbaijani statehood and the respondent State’s attachment to religious tolerance. However, it cannot accept the Government’s argument that the applicant’s criminal conviction was necessary in a democratic society on account of the State’s fight against religious extremism and its protection of democratic values....

78.... [I]t is apparent that in so far as the restrictions did not regulate the content of the religious expression or the manner of its delivery, they were not fit to protect society from religious extremism or any other forms of intolerance...

Biden Speaks at National Prayer Breakfast

Yesterday, the National Prayer Breakfast, sponsored by the National Prayer Breakfast Foundation, was held in Statuary Hall in the Capitol building in Washington D.C. President Biden delivered remarks (full text) at the Breakfast, saying in part:

I also see the trauma, the death, and destruction in Israel and Gaza.  And I understand that the pain and passion felt by so many here in America and around the world.

We value and pray for the lives taken and for the families left behind, for all those who are living in dire circumstances — innocent men, women, and children held hostage or under bombardment or displaced, not knowing where their next meal will come from or if it will come at all.

Not only do we pray for peace, we are actively working for peace, security, dignity for the Israeli people and the Palestinian people.

Sponsorship of the National Prayer Breakfast-- which has been held annually since 1953-- has become more complicated, as explained in reporting on this year's event by Religion News Service:

The refashioned National Prayer Breakfast is a scaled-down version of an event that has drawn thousands to the Washington Hilton and was previously hosted by a group often known as “The Family,” but that called itself the International Foundation.

Since last year, there have been two events, one sponsored by the new National Prayer Breakfast Foundation, after years of controversy following the 2018 breakfast and accusations that the gathering of national and international political and religious leaders had become vulnerable to espionage.

The second event, dubbed the NPB Gathering, and held again this year at the Hilton, drew about 2,000 people from more than 125 countries, including heads of state, and featured a livestream of Biden’s remarks....

Muslim Employee Recovers $70,000 From Employer Who Refused Grooming Rule Accommodation

The EEOC announced on Wednesday that it has entered a consent decree in its lawsuit against Blackwell Security Services, Inc.  The EEOC's lawsuit charged that the company violated Title VII by failing to give an exemption from its no-beard policy to a Muslim employee who worked as a concierge in Chicago, even though granting the accommodation would have imposed no cost and not created an operating burden on Blackwell.  According to the EEOC:

To avoid losing his job, the employee complied and shaved his beard, causing him significant distress....

Under the consent decree resolving the lawsuit, Blackwell will pay $70,000 in compensation to the now-former employee. Blackwell will also provide training to relevant management employees on federal laws prohibiting religious discrimination and will report any additional complaints of religious discrimination to the EEOC for the decree’s duration.

Delaware School Enters Resolution Agreement with DOE Over Antisemitism Complaint

In a January 29 press release, the U.S. Department of Education Office for Civil Rights announced an agreement with the Red Clay, Delaware, Consolidated School District resolving a complaint about antisemitic harassment of a student. The press release sets out a number of incidents of harassment by fellow students. It then finds:

While the district responded to most harassing incidents the student experienced, these responses were often haphazard; were inconsistently enforced as well as inconsistently reflected in district documentation; did not consistently include effective or timely steps to mitigate the effects of the harassment on the student or other students; and did not appear to respond to escalating and repeated incidents.

OCR's findings are set out at greater length in its formal letter to the school district.

The school district has agreed (full text of Resolution Agreement) to reimburse the student's parents for past counseling, academic and therapeutic service costs from the incidents. It has agreed to widely publicize an anti-harassment statement; implement a student informational program; revise school policies; engage in training; audit complaints and incidents; and conduct an assessment of school climate.

JTA, reporting on the agreement, says:

The agreement marks the first time in nine months that the education department announced the closure of an antisemitism-related investigation filed under Title VI....