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Karen White is a kindergarten teacher who recently converted her religion to become a
Jehovah’s Witness. Due to her new religion, Karen informed the students in her class and their
parents that she could no longer participate in holiday celebrations in her classroom. This meant
that she wouldn’t have holiday decorations in her classroom, there would be no Christmas gift
exchanges, she couldn’t sing “Happy Birthday”, and she couldn’t recite the Pledge of Allegiance.
Some of the parents complained to Principal Bill Ward about this information. The principal
sided with the parents and recommended that she be dismissed since she was not effectively
meeting the needs of her students. Karen is not alone in facing termination due to religious
beliefs and there have been numerous court cases with varying results.
disciplined for not reciting the Pledge of Allegiance while in school. Walter Gobitis was a new
convert to the Jehovah’s Witnesses and encouraged his two children not to recite the Pledge of
Allegiance while in school. The family lived in a predominantly Catholic city in Pennsylvania
and the Jehovah’s Witnesses were not viewed favorably. As a result of this the children were
bullied at school and the son even had a teacher force his hand out of his pocket to salute the
flag. Both students were eventually expelled and Mr. Gobitis was forced to enroll them into a
private school at his own cost. Mr. Gobitis took the case all the way up to the Supreme Court
where they eventually ruled in the school district’s favor saying that students should be required
to salute the flag while in school since it was a secular policy developed to create national unity.
In Karen White’s case this would mean that her refusal to recite the Pledge of Allegiance would
teacher who sued the Chicago Board of Education when she was fired. Joethelia was a
Jehovah’s witness who refused to recite the Pledge of Allegiance or even to teach the required
school curriculum because it was in conflict of her religious beliefs. Joethelia refused to teach
her students about certain parts of history that she believed to be too patriotic or anything that
dealt with celebrations such as President Lincoln’s birthday. The school she was working for
fired her as a result of this and she sued them. The Seventh Circuit Court of Appeals ruled in the
school district’s favor stating that although Joethelia had a right to religious beliefs, her beliefs
could not hinder her student’s education. Due to her religious beliefs she was choosing not to
cover certain parts of the school’s required curriculum and since she was on probation it was
justifiable not to renew her contract. In the case of Karen White, she is also refusing to celebrate
holidays and also to recite the Pledge of Allegiance which could affect her students.
In Russo v. Central School District No. 1, Susan Russo was a high school art teacher who
was dismissed by the school due to her refusal to salute the flag and to recite the Pledge of
Allegiance. The Pledge of Allegiance would occur during homeroom class where she was not
the only teacher in the classroom. When it was time for the pledge, Mrs. Russo would simply
stand and respectfully face the flag but remain silent, not causing any disruptions to the students.
Mrs. Russo did this due to personal beliefs and it wasn’t until April that parents complained to
the administration. Mrs. Russo was a probationary teacher and the next school year the school
district decided not to renew her contract. Mrs. Russo sued the school district in the Seventh
Circuit Court of Appeals where they eventually ruled in her favor. They mentioned the Tinker
test and how teachers did not lose their right to free speech when they walked into the school.
They also stated that Mrs. Russo was not attempting to push her beliefs onto her students and
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was not being disruptive to the classroom and thus the school district was wrong in not renewing
her contract. Karen White is also entitled to her religious beliefs and freedom of speech and
In West Virginia State Board of Education v. Barnette, the West Virginia Board of
Education made it a school requirement to salute the flag and to recite the Pledge of Allegiance
after the decision that was made in Minersville School District v. Gobitis. If a student refused to
recite the Pledge of Allegiance, then they would be expelled and not allowed to return to school
unless they complied with the rule. Marie and Gathie Barnette were Jehovah’s Witnesses and
were instructed by their parents not to recite the pledge or to salute the flag and were
consequently expelled. Their parents sued the school district in court and ultimately the
Supreme Court sided with the parents despite the precedent set in the Gobitis case. The Supreme
Court stated that forcing students to recite the pledge and to salute the flag violated the students’
first amendment rights. In order to overturn the decision in Minersville School District v.
Gobitis, the Supreme Court stated that it was in violation of the Free Speech Clause where the
Gobitis case had been a violation of the Free Exercise Clause. This case applies to Karen White
because again, she has the right to free speech even when at school and it is a violation of these
Ultimately, I believe that Karen White’s dismissal is not justifiable because it would
violate her first amendment rights. Minersville School District v. Gobitis argued that the Pledge
of Allegiance promoted national pride and it was okay to force student to recite it; however, just
three short years late West Virginia State Board of Education v. Barnette overturned this decision
and stated that it was a violation of student’s first amendment rights. West Virginia State Board
of Education v. Barnette has since been used in many court cases as the precedent when it comes
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to whether or not teachers and students are required to salute the flag or to recite the pledge. In
Palmer v. Board of Education, Mrs. Palmer was let go because she was purposely leaving out
required parts of the curriculum which the court ruled was harmful to the students’ education.
Karen White is not refusing to teach parts of the assigned curriculum, she is simply refusing to
celebrate holidays and to recite the pledge which are not part of the curriculum. In Russo v.
Central School District No. 1, Mrs. Russo refused to recite the pledge but she didn’t attempt to
push her beliefs onto her students and did not cause a disruption to the class by doing so. Karen
White simply alerted the parents of her students that she would not be participating in certain
celebrations or reciting the pledge and does not appear to be causing a scene and it is within her
first amendment rights to not be forced to salute the flag or to celebrate holidays. As long as
Karen White is respectful to her students, does not cause disruptions to the classroom, and does
not attempt to push her religious beliefs onto her students then her dismissal by the school
References
Palmer v. Board of Ed. of City of Chicago, 603 F.2d 1271 (7th Cir. 1979).
Russo v. Central Sch. Dist. No. 1, Towns of Rush, etc., NY, 469 F.2d 623 (2d Cir. 1972).
West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943).