In Separation of Hinduism from Our Schools v. Chicago Public Schools, (ND IL, May 21, 2021), plaintiffs challenged Chicago Public Schools' "Quiet Time" program which was led by a Transcendental Meditation instructor. They claim that the sessions contained elements of Hinduism in them. The court dismissed claims of some of the plaintiffs for lack of standing, and dismissed claims against the private foundation and the University of Chicago which helped implement the program. One of the plaintiffs, a former student who was required to participate in the program, was found to have standing to bring Establishment and Free Exercise clause claims as well as a claim under the Illinois Religious Freedom Restoration Act against the Chicago public schools. His father also had standing on 1st Amendment claims arising before his son's 18th birthday. The court said in part:
[E]ven if the Williamses were seeking only nominal damages, they would have standing to sue. In a case decided after the parties' briefs were submitted, the Supreme Court held that "a request for nominal damages satisfies the redressability element of standing where a plaintiff's claim is based on a completed violation of a legal right." Uzuegbunam v. Preczewski, 141 S. Ct. 792, 802 (2021).