Censorship and the Public Schools

The First Amendment: Protecting Parents and Children from Caesar

Dr. Richard Baer, Ph.D.

Dr. Richard Baer, Ph.D., is director of the program in Agricultural and Environmental Ethics at Cornell University in Ithaca, New York. A long-time student of religious-ethical problems in education, Dr. Baer has written extensively on the negative impacts of public education on First Amendment freedoms.

© 1985
by the Catholic League for Religious and Civil Rights
1100 West Wells Street, Milwaukee, Wisconsin 53233

 

The stench of a burning book in its own way is as repulsive as the stench of burning flesh in the days of Joan of Arc or the Salem “witches.” Censorship destroys and consumes what is best in man: his reason and imagination.

Do you suppose that these words were spoken by Thomas Paine or James Madison or perhaps by the English libertarian philosopher John Stuart Mill? No, they were not. As a matter of fact, they were published less than a year ago by Cal Thomas, an associate of Jerry Falwell and communications director for the Moral Majority. They begin his 1983 monograph entitled Book Burning(1)

Thomas’s words are gripping and interest us particularly when we see them in the light of a second book on censorship which was pub­lished in 1983. Protecting the Right to Learn: A Citizen’s Guide is its title, and it was written by Barbara Parker and Stefanie Weiss for the activist group People for the American Way, the organization former TV producer Norman Lear founded in 1980 to counter the influence of the Moral Majority.(2)

Lest you take Cal Thomas’s statement as an anomaly or assume that I have quoted him out of context, let me express my evaluation of these two books as bluntly as possible: In spite of far-reaching disa­greements with Jerry Falwell and the Moral Majority, as a scholar I find that Cal Thomas’s Book Burning reflects a far more sophisticat­ed grasp of the philosophical and political issues in current public school censorship debates than does the People for the American Way volume by Parker and Weiss. Moreover, Thomas is fairer to opponents and their views than are Parker and Weiss and presents a position more compatible with a pluralistic and democratic republic than theirs.

Some differences between the two books are important but not fundamental. I shall touch on them, therefore, only briefly.

Throughout Protecting the Freedom to Learn, Parker and Weiss, by biased terminology and irresponsibly exaggerated cartoons, regu­larly attack their opponents as persons rather than limiting the argu­ment to disputed issues. I see little effort on their part to understand why the Moral Majority and other conservative groups are concerned about secular humanism in public schools. Instead, they claim that “the Far Right frequently condemns public schools and organizes censorship campaigns around the drummed-up fear of the ‘religion of secular humanism’” (emphasis added).(3) Let Their Eyes Be Opened, the Christian Broadcasting Network’s TV film on human­ism and its influence in the public schools, is “a slick production,” Mel and Norma Gabler’s textbook reviews “allow local censorship groups to rail against passages taken out of context.” And the people who are “making the most noise about the public schools are orga­nized, clever, and crafty.” Cal Thomas is “sharp-tongued,” and Phyl­lis Schlafly’s Eagle Forum is the “self-styled ‘alternative to women’s lib’”

To some extent we might excuse such language in an activist, how-to manual, but nonetheless it clearly does not encourage constructive dialogue. And Cal Thomas’s Book Burning is not totally free of biased language, of course. But overall, the feeling of his book is gen­erous and conciliatory compared with the People for the American Way publication.

This difference in feeling is particularly noticeable if we look at the cartoons Parker and Weiss use. In case after case, when com­pared with the specific statements Cal Thomas makes defending plu­ralism and practical compromises, these cartoons are tendentious, inaccurate, and irrelevant—based on errors and misconceptions about the Moral Majority’s position.

Compare, for instance, the cartoon which Parker and Weiss re­print in their section entitled “A Sampling of the Censors’ Victories.” A rather fat, smug, and pompous man (Jerry Falwell, I presume) is shown standing in front of a bare bookcase. He is holding a book with a cross on its cover—perhaps a Bible. The caption reads: “The Moral Majority Library.” That this caricature is irresponsible be­comes evident, however, as soon as we compare it to what Cal Thom­as actually says in Book Burning: “All we are asking for is balance. I would like to think that I could walk into a public library and find not only works by Gloria Steinem but also those of Phyllis Schlafly.”(5)

In their section “An Overview of Censorship” Parker and Weiss reprint a 1982 Bruce Beattie cartoon. The dialogue between the li­brarian and her assistant runs like this: “Ban this Book. It’s got a dirty word in it!” “What is it?” “Pluralism!”(6) But compare this with Thomas’s statement from Book Burning: “I want my children to learn about Jewish holidays and Muslim holidays and a lot of other things in school; this teaches them to respect the richness and diversity of religion and cultures.”(7) And later in the same volume, Thomas writes: “It would be absurd to expect every novel or short story or play to be compatible with the Christian world-view. Banning publi­cation or sale of a literary work would be not only unconstitutional, but also antithetical to the Christian concept of freedom.”(8) Public libraries, Thomas argues, “should contain a broad spectrum of books to appeal to the whole community. Libraries serve an open society and should be places of free and open inquiry.”(9)

Just below their statement that the Moral Majority, Phyllis Schlaf­ly, and others of the Far Right “spend considerable time, energy, and money encouraging censorship and attacking public education,” Parker and Weiss reprint a Berke Breathed Bloom County cartoon that shows a book burning. Holding a burning torch and a bullhorn, the leader of the event admonishes the crowd, “Keep it orderly, folks . . . I will not have an uncivilized book burning here!” In the second square he intones, “Okay . . . the Kurt Vonnegut pile on the left . . Steinbeck on the right and the demonic rock record pile in the middle!”(10) But when we look at this reference and the cartoon and compare them to what Cal Thomas writes, the contrast is jarring. In addition to the statements I have already pointed to, he states in Book Burning that “students should have contact with all varieties of literature at some point in their education. This includes writers like Kurt Vonnegut, Ernest Hemingway, and Scott Fitzgerald.”(11)

Disconcerting discrepancy

How can we explain this disconcerting discrepancy between the picture that People for the American Way presents of the Moral Majority on the issue of censorship and the actual statements of Cal Thomas in Book Burning? Could it be that Thomas’s views are sharp­ly at odds with those of the Moral Majority, for whom he works as communications director?

A superficial response would point to all the difficulty of mutual understanding among groups as different as the Moral Majority and People for the American Way. Or it might note that Jerry Falwell at times makes extreme statements, which do not square easily with his more considered views on particular issues.

My own judgment, however, is that Parker and Weiss—along with most liberal writers who have dealt with the problem of censorship in the public schools—have been unable to understand such people as Cal Thomas properly because they have not adequately grasped four basic structural dimensions of American public schools. Indeed, these features of public schools are so fundamental that we may not be able to resolve public school censorship disputes within our current public school system. As important as they are, these features of our public schools are seldom mentioned in censorship discussions.

CRITICAL STRUCTURAL FEATURES OF AMERICA’S PUBLIC SCHOOLS

1. America’s public school system is a government mo­nopoly with a captive student audience.

Although in theory people have the right to choose private schools for their children, in actuality, apart from Catholic parochial schools and other privately subsidized systems, only the affluent have the option of choosing for their children alternative private schools with values and practices more closely suited to their own basic beliefs. This means that most parents—apart from heroic and often impossi­ble sacrifice—simply have to send their children to public schools. The system is monopolistic in that only government schools are eligi­ble to receive tax monies for general support. We have what Profes­sor Stephen Arons of the University of Massachusetts describes in his book Compelling Belief as “a system of school finance that provides free choice for the rich and compulsory socialization for everyone else.”(12)

2. America’s public schools are government schools.

In a strict sense, public school teachers, administrators, and other employees are representatives or agents of the state. Thus the appro­priateness of the term “government school.” But the term is also suit­able for another reason. This is because the dichotomy of public-pri­vate in relation to schools is misleading. If we lump together all pri­vate elementary and secondary schools, they are about as accessible to the general public as are public schools. Specifically, taken as a class, they are as well integrated racially, socially, and economically as are public schools. Admittedly, this is in large part because of the splendid record of Catholic parochial schools, but the point is none­theless worth noting. It is a serious mistake to equate “public” with “government-sponsored” or “government-financed.” To be fully accurate, we should describe schools as “government schools” or as “non-government schools.”

3. It is a myth to think of America’s system of govern­ment schools as a network of local schools or to think of these schools as functioning in loco parentis, that is in the place of or on behalf of parents.

Over the years, America’s public, that is, government, schools have increasingly come to be run by state and federal government agen­cies rather than by local school boards. State boards of education have become more and more powerful in matters of curriculum, textbook selection, and the certification of teachers. And the federal government has increasingly required local schools to follow its mandates in non-curricular matters or else be cut off from substantial federal aid.

If education is learning about the great formative ideas of a cul­ture, if it is achieving competence in a variety of academic disci­plines, then it is totally misleading to think that local communities or parents control this process. Twenty-two states choose textbooks on a statewide basis. In New York State, it is basically the State Board of Regents that controls the high school curriculum. Schools of educa­tion exercise powerful influence over curriculum, and, to their dis­may, parents have learned that it is exceedingly difficult, frequently impossible, successfully to counteract state pressure to incorporate courses in sex education or in such fads as Values Clarification into the local school curriculum. The federally-funded National Institute of Education exercises great power over what kind of research on education will be undertaken, and increasingly state and federal courts determine what schools may and may not do in relation to a broad range of curricular and non-curricular matters.

4. America’s government monopoly school system can­not rightly be described as a “marketplace of ideas,” as is frequently done in public school censorship dis­putes.

When classical libertarian theorists have talked and written about censorship, they have for the most part had in mind a marketplace of ideas similar to the popular image of the economic market. One per­son is free to “sell” ideas by saying or printing what he wants. Others are free to “buy” these ideas (that is, hear or read them) or not, as they choose. In such a situation, censorship is a very serious matter, for it disrupts the marketplace. Ideas no longer flow freely, and the system breaks down. Most critics of fundamentalist “censors” have mistakenly assumed that the public schools are also a genuine mar­ketplace of ideas.

The actual situation in public schools, however, is that all text­books, library books, curricula, films, and other educational materials are pre-selected by teachers, state agencies, and schools of education. Thus in a real sense they are censored. (Publishers also have substan­tial influence in this process). One could use the term “precensored,” but that is probably too weak. As every woman who accepts a proposal of marriage knows (or, at least should know), to say “yes” to one man is to say “no,” that is, to exclude, many others. Thus, although to censor, in one sense, is to rule out or forbid specific works from consideration (and thus is a negative action), whereas to select means to identify and include specific works for consideration (and thus is a positive action), in another sense, all acts of selection involve a kind of implicit censorship: One cannot say “yes” in such a situa­tion without also saying “no.” Inclusion necessarily involves exclu­sion. Of course, this is particularly true in a government monopoly school system with a captive student audience, a school system which in its entirety is a kind of closed forum and is not a genuine market­place of ideas.

Actually, the real problem in relation to elementary and secondary schools—that is, schools which typically serve minors—is not that such pre-selection or censorship takes place, but rather that it is gov­ernment rather than parents that controls the process. Even the great libertarian thinker John Stuart Mill argued in his On Liberty that it is proper for teachers to direct the schooling of minors, for full freedom is appropriate only for people “in the maturity of their faculties.” Freedom for minors has to be limited for their own good—to prevent them from harming themselves. Yet, these limits should not be arbi­trary or unnecessarily severe, for freedom is a precondition for per­sonal growth for youth as well as for adults.

The power of Mill’s analysis is apparent when we contrast it with the typical defense of freedom found in anti-censorship writings by educational professionals. In response to the question, “After study­ing censorship for several years, what do you fear most?”, Professor Edward B. Jenkinson of Indiana University responds:

I fear that students might lose the right to learn, the right to read, the right to explore ideas. . . . I certainly hope that my children will not have to grow up in a society in which they are denied the right to study any subject, to read any book they deem worth their attention, and to speak out on any topic they think worthy of dis­cussion.(13)

Jenkinson’s statement is eloquent, but even Mill would have ob­jected to it, for children simply are not mature enough to make all or most of their own decisions about what to read. I know of no public school, moreover, that even remotely intends to grant them such freedom.

In states such as Texas and California, teachers must select text­books from approved lists, at least if their classes are to receive free textbooks from the state. But even where such state approval is not required, textbooks are typically chosen by the teacher and not by the pupil. Hence they are already censored by the time the pupil sees them. Again, in this instance the image of the marketplace of ideas is not relevant. Students do not stand in front of the newsstand and pick out their own texts and library books.

In school libraries, furthermore, with few exceptions, the librarians choose the books to purchase, not the students. In very few schools, if any, do the students have major responsibility for book selection, and most educators would argue that they should not have such responsi­bility, for the great majority of students are not yet mature enough to recognize what is educationally valuable.

Structural features

The importance of these four structural features of public schools should be underlined. To begin with, a government monopoly school system with a captive student audience—a system which in signifi­cant curricular matters is no longer locally controlled, and which, especially at the pre-college levels, is no genuine marketplace of ideas—will almost always be experienced as coercive and oppressive by various dissenting minorities. Such a system will inevitably be at odds with some of their fundamental beliefs and values. John Stuart Mill makes this point forcefully when he writes in the aforemen­tioned essay:

That the whole or any large part of the education of the people should be in State hands, I go so far as anyone in deprecating. . . . A general State education is a mere contrivance for molding peo­ple to be exactly like one another; and as the mold in which it casts them is that which pleases the predominant power in the govern­ment, whether this be a monarch, a priesthood, an aristocracy, or the majority of the existing generation, in proportion as it is effi­cient and successful, it establishes a despotism over the mind, lead­ing by natural tendency to one over the body.(14) (Emphasis added).

It is odd, to say the least, that most liberal humanistic educators and groups such as People for the American Way and the American Civil Liberties Union (which sometimes draw heavily on the think­ing of Mill) are singularly silent about this passage when they discuss censorship problems and questions of family choice in education. Indeed, because such fundamental ideas are ignored, much of what is written by PAW and the ACLU and many of their actions in rela­tion to public school censorship disputes is unfair, misleading, or ir­relevant. For instance, why is it that when blacks or women press for removing racial slurs or sexual stereotyping from textbooks the liber­al press typically does not call them censors, whereas when Catholic or Evangelical Christian parents try to rid textbooks of what they be­lieve to be obscenities or object to statements critical of Christian values, this pejorative term is used? Is there “good” and “bad” cen­sorship depending on one’s particular beliefs and world view?

Compared with changes that major textbook publishers demand of prospective authors in the attempt to rid books of sexist and racist language, the activities of conservative textbook critics have been only mildly successful. McGraw Hill’s Guidelines (their euphemism for “You’d better write it our way or else!”) for Equal Treatment of the Sexes’s(15) puts powerful pressure on authors—whatever their own scholarly judgments about the issues may be—to portray men and women in a stereotypical unisex manner, irrespective of what social reality in America actually is. The fact that perhaps 80% of all Amer­icans oppose women being drafted for military combat, or that a great many thoughtful Americans—including prominent psycholo­gists—believe that men and women as groups differ psychologically and intellectually as well as physically, and that these differences are caused by hereditary as well as environmental factors: all such facts apparently are to be hidden from unsuspecting school children.

The arrogance of such publishers’ guidelines is hard to describe. As much as anything, they leave an aftertaste not unlike that of various fascist and Marxist attempts to purify language along ideological lines. They reflect a degree of confidence about what is and what is not good for society in the matter of defining maleness and female­ness that is depressingly similar to the certainty of post-World War II planners whose highway and urban renewal projects weakened the social fabric and destroyed the aesthetic integrity of so many Ameri­can cities. And they become almost amusing when ideology runs roughshod over meaning, as in McGraw Hill’s recommendation that the presumably sexist statement “The average American drinks his coffee black” be replaced by “The average American drinks black coffee.”(16)

But why do the ACLU and People for the American Way have so little to say about censorship of this sort? Why do they focus on cen­sorship by conservatives and virtually ignore these even more suc­cessful efforts by liberals to censor textbooks? In contrast to conserva­tive protest, much of which has been that of outsiders objecting to establishment policies, liberals in this case have been able to persuade publishers to use their established economic power to pressure au­thors either to comply or else not to get their manuscripts published.

As Cornell Professor Kenneth Strike argues, “it is hypocritical and question begging to hold that people who attempt to influence the curriculum in ways consistent with their views of what is education­ally worthwhile are censors because they are in a position where they can influence decisions only by protesting them. Powerlessness can­not define censorship.”(17)

Professor Allan Glatthorn of the University of Pennsylvania Grad­uate School of Education writes that:

We are locked in a struggle over the fundamental principles of freedom and liberty. It is not simply the struggle to defend our professional freedom to choose books. It is the larger struggle to ensure that the public school classroom remains a forum for free inquiry. If angry parents can turn the public school into a closed system for inculcating their narrow vision, then surely we are all in trouble.

Glatthorn hopes that “new leaders will have the vision to realize that academic freedom is truly a non-negotiable demand.”(18)

Such comments, however, are not helpful. Public schools at the elementary and secondary levels have never been “a forum for free inquiry,” and it can only confuse the censorship debate so to describe them. And regarding academic freedom, Glatthorn himself recogniz­es earlier in the same article that “the classroom is not a newsstand, the English textbook is not a girlie magazine, the teenager is not the adult.”(19) Of course, Glatthorn is correct in saying this. To take an admittedly extreme case, I do not know of a single public school where a seventh grade teacher would be permitted to bring thirty copies of Hustler magazine to class for the day’s social studies lesson. Nor do I know of any public schools where teachers have an absolute right personally to choose textbooks, curricula, and library books. For a teacher even to want such freedom, when dealing with other peo­ple’s children, is presumptuous. Insisting on such a view of academic freedom would presumably mean that the teacher was convinced that his values were clearly superior to those of the parents or of soci­ety as a whole and furthermore that he was justified in using the coercive power of the state to enable him to disseminate his superior values.

Library Bill of Rights

Or, to turn to another aspect of the censorship problem, by failing to distinguish between school libraries that serve children and public libraries that serve adults, the Library Bill of Rights, put out by the American Library Council, espouses a policy most Americans would likely find unacceptable. It states that “materials should not be ex­cluded because of the origin, background, or views of those contrib­uting to their creation.” It also insists that “libraries should provide materials and information presenting all points of view on current and historical issues” (emphasis added).(20) I support these statements wholeheartedly in relation to public libraries, insofar as these li­braries serve adults. But to apply them directly to school libraries that serve a captive student clientele of children would, I think, be unacceptable to most Americans.

Take the case of sex education curricula which list books by sexolo­gist Wardell Pomeroy in their lists of recommended books for fur­ther study. Does the fact that this same author has an article in the November 1976 issue of Penthouse Forum magazine describing the positive value of incest have no bearing on whether or not his other books should be recommended for further reading?(21) Are Catholic parents to be labeled “censors” for objecting to a school library pur­chasing his books? Or, regarding the presentation of all points of view, does this include books for junior and senior high school stu­dents which recommend child pornography or sado-masochistic sex­ual practices? If we take the Library Bill of Rights at face value, then parents would have no legitimate reason to object to such choices. By not paying attention to the structural dimensions of the public school, the American Library Association appears to espouse a position which most Americans, in my judgment, will not and should not tol­erate.

Failure to recognize that public schools are no genuine market­place of ideas but are instead a state monopoly with a captive student clientele is one of the chief reasons dialogue over the public school censorship issue has become so difficult and at times nearly impossi­ble. Steven Pico, one of the plaintiffs in the Pico v. Island Trees cen­sorship case, writes in the Foreword to Protecting the Freedom to Learn that “responding to the hypocrisy of censorship in a free soci­ety is not an easy or comfortable task.”(22) His basic argument, he says, is

that a pluralistic democracy is founded in the trust that people choose best for themselves when given a variety of alternatives. No citizen or group has the right to use its private absolutist standards of right and wrong to prescribe what ideas should be available to a free people.(23)

But Pico shows absolutely no awareness of the structural features of the public school censorship problem, particularly the fact that gov­ernment elementary and secondary schools are not genuine market­places of ideas but are rather largely-closed forums serving students, at least some of whom are present because no other choice is eco­nomically feasible for their parents. If taken at face value, his words lend support to those who argue for the disestablishment of the entire public school system rather than to those who engage in the dubious enterprise of tagging opponents with the labels “censors” and “book burners.”

QUESTIONABLE ASSUMPTIONS ABOUT EDUCATION AND RELIGION

An adequate analysis of censorship disputes in government schools demands a grasp of these structural features of the school system. But it is also necessary to understand that defense of the present system of government schools typically depends on a number of doubtful assumptions about what constitutes good education and about the relation of values and religion to education.

1. The first assumption: It is legitimate to require a child to be exposed to a multiplicity of values rather than to only a few.

This presumably democratic procedure, among other things, is supposed to make the child more tolerant of other people’s points of view. Advocates of this position emphasize the importance of open­ing the minds of young children to new ideas and to new values. But why is such a procedure considered good? Actually, we just as often want students to make up their minds, to hold onto certain truths firmly. I do not want my students to keep an open mind about whether Paris is the capital of France rather than, say, of Italy. They have nothing to gain by doing so. Nor do I want them to be open-minded about whether justice and equality are worthy goals for soci­ety. That one of these propositions is a question of fact and the other a matter of value is not crucially important, unless we make the prior philosophical judgment that facts can be known to be true or false but values are merely matters of opinion. In both cases I intend to teach my students the truth of these propositions and to urge them to adjust their lives accordingly. Of course, it is good to keep an open mind on questions that are still open questions. But life will be far simpler and more productive for those who make up their minds about certain issues. To deliberately choose to live in bewilderment and perplexity when reasonable answers are available is no great virtue, and, if persisted in, such a stance makes a meaningful and pro­ductive life impossible.

Obviously, what constitute open and closed questions is dependent on our basic world view. But even so, there is no sure way to sort out the one from the other, and we will do well not to overemphasize the certainty of our knowledge claims. And, clearly, we should not dis­courage the child from asking questions or expressing doubts. If, after telling a student that the earth is round, I get the response, “But it looks flat to me!”, I will give reasons for my statement. Likewise, if a child questions the importance of justice, tolerance, and equality, I will try to help the child understand why these values are important to a democratic society. But I do not want the child to go away think­ing that what she believes about the shape of the earth or the appro­priateness of justice, tolerance, and equality is just a matter of per­sonal preference.

The position that the child should be exposed to a multiplicity of values furthermore presupposes that, for the sake of what is viewed as a good cause, the state has the right to violate the parents’ wishes for the child’s moral and religious development. This position also prejudges the very difficult psychological question of how much exposure to diversity of values is good for the moral development of the child.

In the important 1969 case, Tinker v. Des Moines School District, the Supreme Court, defending the students’ freedom of speech, de­clared that “in our system, state-operated schools may not be en­claves of totalitarianism.”(24) Students, the court emphasized, “may not be regarded as closed-circuit recipients of only that which the state chooses to communicate.”(25) But, insofar as the justices did not address the question of the monopoly nature of the school system, their analysis is misleading. For dissenting minorities, the term “only” (“only that which the state chooses to communicate”) may not be of critical concern. Such minorities rather worry that many educators tend to treat students as “closed-circuit recipients” of everything (sex education, Values Clarification, humanistic values) “the state wishes to communicate.” If so, is not this also a form of totalitarianism? As Kenneth Strike asks, “Why should the state have the right to compel parents to submit their children to a curriculum which may lead the child to defect from the parents’ values?”(26)

The desire to expose the child to a multiplicity of values is fre­quently based on a philosophy of ethical subjectivism and the belief in a radical split between facts and values. Since we cannot know which values are true and which are false or which are better or worse, why not expose the child to many values and let her make up her own mind? The censor then is seen as the one who hinders this process. Since the truth about values cannot be known in any case, no one should be so arrogant as to think he knows that a particular value, or obscene expression, or disputed English text will be harmful to a child. If all value judgments are personal and subjective, then par­ents who object to the will of the majority as interpreted by the edu­cational bureaucracy are simply being capricious and arbitrary. They are pitting their own subjective preferences against those of the democratically established authority. They deserve to be called “censors” in the pejorative sense of the term.

People who take this position hold that only facts can be shown to be true or false and that values are matters of personal feeling and opinion. All values, they believe, are subjective and relative. Some­times the term “situation ethics” is used to describe such a philoso­phy, but the term “subjectivism” is more appropriate. Philosopher Bertrand Russell was a subjectivist in ethics. The Logical Positivists went even further, taking a totally non-cognitivist position in ethics. They believed that if something could not be verified empirically, that is, by sense experience, it should be considered neither true nor false. It is non-sense—that is, cognitively meaningless.

Ethical subjectivism is widely adhered to today in academic cir­cles, even though most professional philosophers do not accept the position. They realize that radical subjectivism paralyzes ethical dis­cussion. Ironically, however, a great many students and faculty still hold to a subjectivist position with unquestioned allegiance. When students try to end a discussion with the comment, “But that’s just your value judgment,” they apparently intend to say: “Since you are just expressing your feelings, that is, your own personal opinion, your point has no general relevance for others.” When a student says, “Don’t press your values on me,” he, in effect, is saying: “Hold off! I have to make up my own mind and decide for myself what is right and wrong or good and bad.”

Odd comments

To understand how odd such comments are, try to imagine how strange it would sound if I said: “Oh, that’s just a fact judgment,” or if I said, “Don’t press your facts on me. I have to make up my own mind whether water is made up of hydrogen and oxygen or not.”

In a world where we cannot know which values are better and which are worse, it may make sense to expose students to many dif­ferent values, so that they will likely find some which appeal to them and which they can accept. Clearly, however, we would not apply this same tactic in teaching chemistry or geography, for in these dis­ciplines we believe there are right and wrong, or, at least, better and worse answers.

But perhaps ethics is not as totally different from natural science and social studies as is often assumed. Both science and ethics typi­cally start with certain basic assumptions about the nature of the world, the functioning of the human mind, and so forth. Both ways of thinking assume the law of non-contradiction and depend for their success on the prior commitment of practitioners to truth telling. Neither can make any progress at all if it starts with initial skepticism and doubt.

What constitutes knowledge in ethics is both similar to and differ­ent from what constitutes knowledge in a natural science, but the differences are less striking than many assume to be the case. Chris­tian and Jewish ethicists characteristically believe that their founda­tional beliefs are directly related to God’s self-revelation in history, but the extension and application of these beliefs that constitute the professional task of the theological ethicist depend on a disciplined use of reason that is not dissimilar to that typical of other academic disciplines.

Also, it is important to remember that we can believe in the exist­ence of objective values or even moral absolutes without at the same time insisting that we have an absolutely certain knowledge of what these values or absolutes are or of how they should be applied in every situation.

At first glance, ethical subjectivism sounds like a tolerant philoso­phy, one appropriate for a democratic society. No one will try to tell others what is good or right for them. Each individual will have to decide on her own individual values. But the presumed appropriate­ness of ethical subjectivism for a democratic society is misleading. To be specific, if all values are subjective and matters of personal feel­ing, then this must also include the values of justice, of tolerance of people who hold dissenting views, of freedom and equality, even of democracy itself. Presumably, at another time or another place, peo­ple might decide they felt better about being unjust, tyrannical, in­tolerant, and so forth. But as Americans, we believe that these values rest on a surer foundation. We believe they are fundamentally true, and that we possess certain inalienable rights, quite apart from what individuals happen to think about these issues at any given moment in history.

Many teachers and professors of education do not seem to be aware that on the metaethical level—that is, the level of discourse which deals with the nature of ethics as such—they are simply indoc­trinating their students in the position that all value judgments are subjective and relative. Thus, for instance, in How Porcupines Make Love: Notes on a Response-Centered Curriculum, Alan C. Purves writes: “an individual [student] will respect the responses of others as being as valid for them as his is for him. He will recognize his differ­ences from other people.” Correspondingly, “the teacher must en­courage the student to tolerate responses that differ from his.”(27) But surely this position is open to question. In a democracy, we should teach students to be tolerant of persons who hold differing views. But why should students or teachers be any more tolerant of a wrong answer to a question about morality—say the morality of murder, rape, racism, or treachery—than they should about a wrong answer to a science or geography question, unless, that is, they have already decided in favor of the metaethical position that all values are subjec­tive and not matters of truth or falsity?

Not only does the subjectivist position fail to supply an adequate basis for a democratic and pluralistic society, but state coercion in basic value formation—as a means of furthering tolerance and de­mocracy—ought to strike us, at least, as odd. Moreover, if we cannot actually know which values are worthy of assent, then this logically includes the value claim that it is good to expose the child to more rather than fewer competing values.

2. The second assumption—shared also by the courts: It is possible to achieve a religion-neutral curriculum in the public schools and thus not violate basic First Amendment rights of students and their families.

Get Bible readings, prayers and Christmas carols out of the schools. Refer to Christmas as the “winter holiday,” and don’t even mention Easter. And by the alchemy of secularization, you will have schools that are either religion-free or religion-neutral.

But this is wishful thinking. It simply does not hold up under close analysis. All education involves assumptions about the nature of the good life and the good society, and these in turn entail specific edu­cational goals and practices. We might ask, for instance: What is the purpose of life? Is it, as many humanists believe, to fulfill oneself, to satisfy oneself, to seek the maximum personal happiness possible? That is one goal, to be sure, but it stands in direct contradiction to the goal of the Judeo-Christian heritage, which teaches that the purpose of life is to love God and serve one’s neighbor. Inasmuch as the hu­manist position deals with ultimate dimensions of human exist­ence—the meaning and goals of life—it is just as clearly metaphysi­cal or “religious” as Judaism and Christianity.

Educator and philosopher John Dewey clearly recognized this truth 50 years ago when he wrote in A Common Faith of his own humanistic philosophy: “Here are all the elements for a religious faith that shall not be confined to sect, class or race.” Dewey then concluded that “it remains to make it explicit and militant.”(28) It is easy to find his words prophetic. Today, when we look at the perva­sive humanistic assumptions of much of sex education, school coun­seling, and teaching methods such as Values Clarification, we can easily conclude that many public schools have put Christianity at a state-sponsored disadvantage.

Significantly, when the courts began to rid the public schools of religion, most humanist writers stopped referring to their own philos­ophy as “religious.” Moreover, they argued that their position was based on reason—and thus was fundamentally different from Chris­tian beliefs, which they held to be based on dogma and superstition.

But dropping the label “religious” appears suspiciously opportu­nistic, and when the humanist argues that his ethics are based on rea­son we should subject his claim to the kind of tough criticism that Nietzsche brought to the discipline of philosophical ethics. In section 335 of The Gay Science, in a few witty and compelling paragraphs, he gives the death blow to the Enlightenment quest to establish a rational basis for an objective morality. Nietzsche’s analysis should make us hesitant to accept the conclusions of humanist Sidney Hook. Hook argues that humanist ethics deserve to be taught in the public schools, because they are based on reason, whereas Christian ethics, grounded as they are in dogma and superstition, should be excluded from the public domain. But he quite fails to realize that terms like “science,” “reason,” and “rational,” rather than being purely objec­tive or descriptive, are almost always used in an evaluative or norma­tive sense.

A specifically Christian rebuttal of the position that public schools can achieve religious neutrality would hold that the attempt to di­vide life into the realm of the secular and the sacred (except in a pragmatic and political sense as a dimension of a working pluralistic culture) is theologically suspect. Because Christians should value the freedom of all people, including both those who hold one or another set of religious convictions and those who understand themselves and the world in secular terms, Christians can wholeheartedly support a political system which distinguishes between the sacred and the secu­lar, even though the distinction is theologically problematic for them. Such valuations and such support need not conflict with Christian affirmation of and commitment to Jesus Christ as Lord of all life, including the domain of education and the realm of the secular, for Biblical teaching stresses that commitment to Jesus Christ as Lord must always be an act of freedom and in no way coerced.

Certain curricular developments within government schools clear­ly show the “religious” nature of secular and humanistic education. In his book Psychology As Religion, Paul Vitz argues that such popu­lar psychologists as Abraham Maslow, Erich Fromm, Rollo May, and Carl Rogers have placed the individual self, rather than God, at the center of things. Individual self-fulfillment becomes the goal of life.(29)

Rogers’s influence can easily be detected in Values Clarification. Advertised as a noncoercive and neutral way to teach values in the public schools, Values Clarification in fact indoctrinates students in a very specific secular and humanistic understanding of the nature of humanity, ethics, and the goal of life. As in the selfist psychologies described by Vitz, Values Clarification simply assumes that the pur­pose of life is self-fulfillment and maximizing one’s own happiness. Further, it assumes that all values are subjective and relative and that we cannot know the truth or falsity of specific value statements. The method presupposes a radically non-Christian view of human free­dom: Quite ignoring any concept of sin or bondage of the will, Val­ues Clarification teaches that individuals are genuinely free to choose the good and to structure their own lives as they please. But such an assumption is by no means obviously true.(30)

That government schools are not religiously neutral can also be seen in most public school sex education curricula, which are domi­nated by secular and humanistic values. Sex is portrayed as largely, if not entirely, for one’s own personal pleasure. Such curricula, more­over, often take strong pro-homosexual and pro-abortion stands, and often reflect a barely-tolerant attitude toward the traditional values of premarital and marital fidelity. Authors avoid such terms as “normal” and “abnormal,” preferring to speak of “alternative sexual responses” and “alternative life-styles.” Bibliographies and recom­mended readings in such curricula largely ignore texts by Catholic or Evangelical Christian writers, listing mainly secular, atheistic, and humanistic authors.

It might be objected that it is always possible to remove offending elements such as Values Clarification and humanistic sex education from government school curricula. This could be done. But this would still not produce schools that were religiously neutral, for the heart of the problem lies not in these recent curricular supplements but rather in the fundamental assumptions, values, and goals of the entire curriculum. When math and science are emphasized in a school and theology and church history ignored, this pattern relates to assumptions about the purpose of schooling and the nature of the good life. Math and science prepare one to be economically compe­tent, to be successful in competing (the Latin root is the same) for the material goods and social status of this world. Bible, theology, music, poetry, and art are not considered helpful in preparing one for such competition, and they are not much emphasized in government schools. Computer courses will inevitably win out over classes on prayer or the devotional life in our present public schools. Physical education will take priority over spiritual formation. The concerns of the secular world will leave little room for religious concerns or things pertaining to the world to come.

Religiously neutral?

It is simply naive to consider such basic decisions religiously neu­tral. Law schools and medical colleges were not neutral towards blacks and women when they largely ignored them in the admissions process. They actively favored white males (it also helped if you were not a Jew or a Catholic) over any potential competitors. Simi­larly, when government schools favor one set of subject matter over another and deliberately de-emphasize and even exclude certain sub­jects from the curriculum, they are by no means neutral.

The original intent of the establishment clause of the First Amend­ment was to prohibit the federal government from favoring one denomination over others by establishing it as a national church. It was not to put all religions at a disadvantage in their competition with humanism, secularism, and atheism, which is precisely what has hap­pened in public schools over the past several decades.

Indeed, the historical data from the earliest years of the republic point to the government’s favoring of religion as such. Education in religion was a high priority in early American history. The North­west Ordinance of 1787, for instance, in dedicating federal property in the territory for schools, described the rationale of these schools in these terms: “Religion, morality, and knowledge being necessary to good government and the happiness of mankind, schools and the means of learning shall forever be encouraged.” In 1789, the same Congress that wrote the Constitution reaffirmed the ordinance. In the years immediately following the Revolution, 12 out of 13 states taxed their citizens to underwrite the preaching of the Gospel and the building of churches. Today, largely on the basis of court deci­sions that have little to do with the historical meaning of the First Amendment, the pendulum has swung to the opposite extreme, for what we see in public education today is, in effect, a strong sponsor­ship (some would say establishment) by the state of secular and hu­manistic values to the decided disadvantage of Christianity and the entire Judeo-Christian tradition. To consider this present condition as religiously neutral is simply to toy with words.

3. The third assumption: Religion is basically a personal and private affair.

The common liberal assumption is that Americans are free to be­lieve what they want about God, humanity, and society, but it is best that the expression of religious beliefs be confined to the privacy of one’s home or the sacred domain of the church building proper. In other words, don’t let your religion interfere with your duties to the state, and whatever you do, don’t violate other people’s sensitivities by praying in a public school. Personal evangelism is socially crude and embarrassing. Religion belongs inside the church and has no le­gitimate place at a business luncheon or a faculty meeting. Even bowing one’s head for silent prayer at a restaurant or in a university dining hall is no small cause for embarrassment.

The authors of Society, State, and Schools, one of the most impor­tant books written to date on the subject of Christians and the public schools, point out that the historical roots of this privatizing of reli­gion go back at least as far as Thomas Jefferson.

The distinction between public and private religion was at the heart of Jefferson’s thought. In his Enlightenment rationalism, public religion referred to what he assumed to be a universal mo­rality, while private religion described the sectarian beliefs of such groups as Presbyterians, Baptists, and Methodists. The sectarians, Jefferson concluded, were unenlightened individuals who did not comprehend the universal truths of religion.(31)

Jefferson believed that sectarian religion could disrupt society, if it were not kept private. At the same time, he was convinced that soci­ety had to be supported by a common “non-sectarian” morality and religion. But this “distinction between a public non-sectarian religion and a private sectarian religion was not as self-evident as it was self-serving,” the authors of Society, State, and Schools conclude, because it allowed Jefferson’s religion to “lay claim to the public life of the country.”(32) All other religious expressions, for him, belonged only in the private realm of individual conscience, family, or church.

The privatizing of religion is a curious phenomenon. It calls to mind certain Soviet attitudes toward religion. Soviet citizens have a good deal of religious freedom to believe and think what they want—in the privacy of their own heads, and, to a lesser extent, in specified, licensed churches. But the priest is forbidden to draw out the political and social implications of Christian theology, and all public demonstrations of religious belief are severely circumscribed. The penalties for overstepping these bounds are severe.

The attitude of many liberals today toward religion, curiously, is rather like the common interpretation of how the Victorian age thought about sex. In general, best not to talk about religion, but if you do, it is far better to talk about Buddhism or Native American religion than about faith in Jesus Christ. In much the same manner, Victorians were extremely private about their own sex lives but felt fewer inhibitions about discussing the sex life of South Sea Islanders or New Guinea natives, and at a somewhat later date The National Geographic could show bare-breasted women and largely naked bodies—so long as they were not Americans or Europeans.

If the discussion appears to have strayed from the censorship issue, it is important to recall the basic argument: The question of censor­ship probably cannot be resolved within the present system of public schools, for this system is a government monopoly with a largely-captive student clientele, and it is no genuine marketplace of ideas. The problem becomes even more intractable when it is simply as­sumed that it is legitimate to require a child to be exposed to many values rather than to a few, that all value judgments are subjective, that a religiously neutral curriculum is possible, and that religion is basically a personal and private affair.

My own judgment is that the only way adequately to resolve the problem of censorship in government schools will be to change the structure—particularly the financial structure—of the entire system. A few minor adjustments here and there simply will not suffice. Indeed, Stephen Arons of the University of Massachusetts argues that “the present political and financial structure of American schooling is unconstitutional.” He contends that “most judges and legislators have not perceived the centrality of school socialization to the lives of families and the raising of children; neither have they acknowledged the relationship between the formation of world views in children and the expression of opinion protected by the First Amendment.”(33) Arons concludes that “if the First Amendment pro­tected only the communication and not the formation of ideas, totali­tarianism and freedom of expression could be characteristics of the same society.”(34)

Dean Herbert W. Titus of Christian Broadcasting Network Uni­versity also considers America’s public schools unconstitutional on First Amendment grounds. He argues that government schools are not consistent with a long and impressive history of U.S. Supreme Court rulings on freedom of the press and speech. “State legislatures and boards of education,” he writes, “have consistently adopted laws and regulations that require certain points of view to be taught to the exclusion of others.”(35) And such teaching takes place in a govern­ment monopoly system of schools. Many parents have no realistic economic choice but to submit their children to such government-ordered instruction.

Titus asks us to review this situation in light of such court pro­nouncements as the following from Police Department of Chicago v. Mosley, a case which dealt with picketing or demonstrating on a public way near a public school building: “. . . [Government] may not select which issues are worth discussing or debating in public fa­cilities. There is an ‘quality of status in the field of ideas,’ and gov­ernment must afford all points of view an equal opportunity to be heard.”(36)

We also read in Mosley “that, above all else, the First Amendment means that government has no power to restrict expression because of its message, its ideas, its subject matter, or its content. . . The essence of this forbidden censorship is content control.”(37)

Government as censor

If we were to examine government schools in light of such First Amendment court pronouncements, they would, to put it mildly, fare very badly. Government is totally in charge of curriculum and content in such schools, teachers are agents of government, and many students attend these schools only because of economic neces­sity. Viewed in light of the assumption in Tinker v. Des Moines that a public school classroom is a public forum available for free speech activities, and in light of the Court’s statement that “it can hardly be argued that either students or teachers shed their constitutional rights to freedom of speech or expression at the schoolhouse gate,”(38) the fol­lowing words from Mosley are particularly significant: “Necessarily, then, under the Equal Protection Clause, not to mention the First Amendment itself, government may not grant the use of a forum to people whose views it finds acceptable, but deny use to those wishing to express less favored or more controversial views.”(39)

Indeed, the irony of Tinker is that while it takes what in some ways is a very liberal view regarding students’ First Amendment freedom of speech rights, on the other hand it quite overlooks the far deeper government censorship involved in including and excluding ideas and values from the curriculum, deciding what subject matter will and will not be taught, and determining educational goals and processes. One could also argue that the certification of teachers, far from being simply a matter of ascertaining professional competence, is value-laden to the core and necessarily involves a degree of censor­ship. People with “wrong” ideas may find it difficult to be certified, especially in fields such as History and English. The Court in Mosley, although it clearly did not have schools qua schools in mind, well understood the censorship potential of the State’s power to license: “Similarly, because of their potential use as instruments for selective­ly suppressing some points of view, this Court has condemned licens­ing schemes that lodge broad discretion in a public official to permit speech-related activity.”(40) The full force of this opinion becomes evi­dent when we reflect on the fact that virtually no teacher is permit­ted to teach in a government school without prior government certi­fication. And not a few government bureaucrats insist that teachers in non-government schools should also be government-certified as well.

It might be objected that schooling for minors is not possible at all without teachers determining curriculum, setting goals, and general­ly supervising what will and will not be taught. This objection is sound. But rather than concluding from this that government schools should be excluded from First Amendment freedom of speech court rulings, it would be more consistent to hold that government should stop operating schools. It is easy for us as Americans to see the evil of a government-run newspaper such as Pravda, but, under less benign government than we have at present, the danger of government-op­erated schools could be just as great. Indeed, the very fact that most public school students are impressionable minors, makes government control of these schools even more serious in some respects than would be the introduction of official government newspapers.

A second objection to my application of First Amendment free­dom of speech court rulings to government schools might be that there is a compelling state interest in seeing that children are educat­ed. I freely grant this point. But, as the Supreme Court has repeated­ly stated in relation to First Amendment rights of citizens, compel­ling government interest in such cases should be met by the least burdensome means. Otherwise, the regulation or statute in question may be struck down because “less drastic means” are available.(41) In Shelton v. Tucker the Court held that “even though the governmen­tal purpose be legitimate and substantial, that purpose cannot be pur­sued by means that broadly stifle fundamental personal liberties when the end can be more narrowly achieved.”(42)

I see no problem in government requiring minimum levels of competence in reading, writing, and mathematics. Also, a strong case can be made for requiring basic knowledge of American history and of how American political institutions function. But as our non-gov­ernment schools clearly have established, this state interest can be met totally apart from government’s actually operating schools. Gov­ernment’s role, beyond defining such compelling state interest, should be limited to funding education.

As Titus points out, “the Supreme Court has held in a long line of cases that government cannot intrude upon the homeowner’s func­tion as editor of what he will hear at the door of his home.”(43) How ironic that these same individuals, if they are parents who cannot af­ford non-government schools of their own choice for their children, must by law submit their children to the curricula of government schools. They are permitted to protect themselves from the unwant­ed intrusion of ideas and values into their lives, but they may not protect their children! The particular irony of Tinker is that it boldly affirms students’ rights to freedom of expression in public schools (some would say to the detriment of school discipline) but almost to­tally fails to reach the far more fundamental issue of the way in which the entire system of government-operated schools threatens the First Amendment rights of families and their children to free­dom of speech.

PUBLIC SCHOOLS AND A FREE SOCIETY

If my previous analysis is correct, then radical change is needed in America’s system of schools if freedom of conscience and freedom in teaching and learning is to be fostered. It simply is not possible to preserve the First Amendment rights of various minorities in our current government monopoly system.

Parker and Weiss, in the “Introduction” to Protecting the Free­dom to Learn, speak of making it possible for children “to be able to go to public schools where they can learn how to think, not what to think.”(44) But such a distinction, when made in relation to censorship disputes, is naive, for, as we have seen, all education entails assump­tions about human beings and the world in which they live. And these inevitably impact on both the how and the what of education.

The 1948 United Nations Universal Declaration of Human Rights states that every person has a right to free education at the “elementary and fundamental stages.” But, even more significant for my argument here, it also maintains that “parents have a prior right to choose the kind of education that shall be given to their children” (emphasis added).(45) Obviously, America’s government monopoly school system is not compatible with such an emphasis on parental choice.

No government schools

In contrast to Parker and Weiss’s statement that “all parents have a responsibility to be aware of their children’s education experiences and to work with the [public] school system,”(46) my own judgment is that genuine freedom in teaching and learning will be possible only when government gets out of the business of operating schools alto­gether. I see no way the full integrity of the First Amendment can be preserved so long as government can control the certification of teachers and the curriculum of schools. The situation becomes intol­erable when government also holds an effective monopoly in the funding of education such that some students have no realistic eco­nomic choice but to attend government schools.

For obvious reasons, however, I am not sanguine about the possi­bility of such a drastic change taking place any time in the near fu­ture. Thus, from a pragmatic standpoint, reformers should not con­centrate on abolishing government schools but rather on disestablish­ing them by gradually withdrawing direct support from them and implementing a universal tuition voucher or entitlement system, roughly analogous to the GI bill instituted during World War II. Such a move would do away with the need for “censorship” and would allow a true pluralism. Parents who were dissatisfied with the curricula of public schools could afford to enroll their children else­where. They would no longer need to play the role of the critic and the protestor, or, from the perspective of many within the public school establishment, the censor.

Another possibility would be to provide funds directly to private schools, whether these were religious or secular. This pattern is used in Canada, Israel, and a variety of European nations, but in the Unit­ed States it is unlikely that it would be seen by the courts as compati­ble with the establishment clause of the First Amendment.

In a voucher system, government (local and/or state, with possible federal assistance) would provide tuition vouchers which parents could redeem for their children’s education at schools of the parents’ choice. Both government and non-government schools could accept vouchers. Ideally, the dollar value of vouchers would be inversely related to family income levels—thus permitting poor families to bid for high quality education—and adjustments would be made for local cost-of-living differences and for the differing costs of vocation­al and academic curricula. Appropriate prohibitions against discrimi­nation on the basis of race and national origin could and should also be built into the system.

Vouchers would probably create healthy competition for both government and non-government schools and thus lead to greater efficiency, but their prime justification would be related to freedom of conscience. Parents would no longer be forced to send their chil­dren to schools whose values and practices offended, even violated, their deepest religious beliefs or their deepest convictions regarding social and political values. Some parents, for instance, believe that the present school system is far too competitive; or that it emphasizes science and math too much and music, art, and literature too little; or that it does not sufficiently stress environmental values. Vouchers would for the first time permit these parents to exercise genuine choice in their children’s education. On the college and university level, all students would be able to afford real alternatives. They would be able to choose for themselves the kind of learning they wanted. They would not be forced, as at present, to attend govern­ment schools with curricula they did not appreciate or approve of.

Clearly vouchers could create problems of their own. Racist par­ents might attempt to manipulate the system to resegregate schools. Some have speculated that a voucher system could result in the least capable students being abandoned (the term “warehoused” has been used) to the public schools. In these areas (and with other problems that might arise) voucher supporters would have to make absolutely clear their commitment to equality, justice, and nonracist policies. Also, many private schools prefer to maintain a better racial balance than they now have but cannot afford sufficient scholarships to do it. And we must not forget that public schools have not been notably successful in achieving racial balance.

In contrast to speculation about such problems, however, the coer­cive nature of our public school monopoly is a present reality for dis­senting minorities. If Arons is correct, the unconstitutional nature of our present public school system is not a projection for the future. It is a real and very disturbing problem for many parents today. If gov­ernment can control the enculturation and basic value formation of children during 10 to 13 years of schooling, then how can the First Amendment’s guarantee of freedom of speech and religion be a fully meaningful concept? If People for Public Education is correct in its judgment that “only through a deep commitment to public educa­tion may we aspire to the full development of each child’s unique talents and may we provide equality of opportunity to all of our chil­dren,”(47) then, in my judgment, the future for religious and political minorities in America looks very bleak and genuine pluralism likely will not long survive.

Even if government schools are disestablished through the imple­mentation of a universal voucher system, the government schools which survive disestablishment—precisely because they are public and not private—must become more genuinely pluralist in curricu­lum, structure, and goals. Rather than trying to rid the schools of all religion and thus in effect giving a state-sponsored advantage to the “religion” of secular humanism and the philosophy of atheistic mate­rialism, government schools which survive disestablishment should permit differing values, world views, and religious beliefs to exist side by side. In such circumstances, widespread accommodation and compromise would be essential. No longer at a state-sponsored disad­vantage, Christian and Jewish beliefs and values would be substan­tially represented in the curriculum. In line with the Equal Access legislation signed into law during the summer of 1984 by President Reagan, Christian, Jewish, or Islamic religion clubs, along with secu­lar and humanistic groups, would be permitted in the schools as ex­tracurricular activities. Some classes might begin with prayer, others without prayer, and thus both those who pray and those who do not would have to respect each other’s beliefs and basic life commit­ments. At some school functions and banquets a prayer would be said before the meals, at others not. The emphasis placed on different subjects and value positions in the curriculum might be roughly pro­portionate to the size of different local constituencies and their de­gree of interest in these matters. Tolerance of people holding unpop­ular views and a willingness to live with messy compromises would be essential. Overall such a scheme would far sooner do justice to the spirit of the First Amendment than do the largely secular and hu­manistic curricula of present-day public schools.

For roughly 100 years Protestant-Christian-Unitarian values were given a privileged position in the public schools. This was not a good time for Jews, Catholics, or atheists. These groups found the public schools religiously oppressive, and some—in order to preserve their own integrity and freedom of conscience—sent their children to their own private schools, sometimes at great personal sacrifice. From perhaps 1930 to 1960, government schools in America involved a fair amount of compromise: there were some prayers, Bible read­ings, and Christmas carols, but also increasing evidence of secularism, scientism, and humanism. The mixture constantly changed and was never ideal for any single group. Jews, for instance, often were at a disadvantage, particularly in parts of the South.

The radical change in this situation of compromise came not from the emergence of Christian fundamentalist protest or the Moral Ma­jority but from the pressure of individuals such as Madelyn Murray O’Hair and groups such as the American Civil Liberties Union to get all religion out of the public schools. In their attempts to purify the schools, however, O’Hair and the ACLU failed to realize that what remained after Christian beliefs and practices were forced out would itself also be religious. Whereas Christianity dominated the public schools from their earliest years till perhaps 1930, from roughly 1960 to the present a secularizing humanism has come to play a very simi­lar role. Dewey’s prophetic words were coming true. Here was a new “religious faith.” It was indeed becoming “explicit and militant.”

Insofar as the ACLU and the courts have failed to realize the ines­capably religious nature of education, their activities have been largely misdirected and, in my judgment, have tended to undermine the very First Amendment freedoms they were ostensibly fighting to preserve. Indeed, most moderns tend to view education largely with­in the context of bureaucracy, efficiency, and value neutrality rather than as a deeply personal, spiritual, and religious matter, an experi­ence that demands freedom of a radical sort. That public education aspires to value neutrality, a focus on the “facts,” and a rejection of a specifically Christian world view, however, does not mean that it can escape making its own value judgments and committing itself to an alternative world view. It is not even possible just to focus on the “facts,” for as most philosophers of science well know_s all observation is theory-laden. What counts as a “fact” for specific persons or com­munities is inseparably dependent on their particular world views. Traditionally, Jewish and Christian theologians have made a similar point. The most important question may not be: Do you believe in God? but rather: Which God do you believe in? From a Christian perspective, if God is not served, we will create our own idols!

A PLEA FOR FAIRNESS

Although in the long run, resolution of public school censorship disputes will require new thinking about the nature of schools, edu­cation, values, and religion, in the immediate future parties to such disputes must learn to treat each other with fairness and respect. Both accuracy and fairness, for instance, demand that the responsi­bility for public school censorship disputes not simply be laid on pro­testing parents. The claim is frequently made that censorship at­tempts are on the rise. In one sense this claim is accurate. But this may be entirely misleading. “Perhaps what is on the rise,” writes Kenneth Strike of Cornell University,

is a power shift from parents and the local community to educa­tional professionals who are able for the first time to successfully impose views of the curriculum which are at odds with local val­ues. It is not that parents are suddenly eager to impose their values on the school. They have done this all along. Rather, conflict arises from the fact that teachers are more willing and able to resist pa­rental wishes.(48)

In other words, it may be the teachers, not the parents who are claim-jumping.

Controversies become polarized

Typically, censorship controversies have quickly become polar­ized. The lack of formal education on the part of many protestors has made dialogue difficult at times. The “bills of particulars” Norma and Mel Gabler have submitted at state-sponsored textbook hearings in Texas not only have sometimes engaged in overkill by focusing on trivial details but also have reflected extremely conservative political and economic views many public school critics do not share.

Yet, contrary to the pronouncements of most educators and media writers, my experience is that the major responsibility for such polar­ization rests with school authorities (teachers, administrators, and boards) and not with protesters and groups of concerned parents. The media have also been less than fair in their treatment of censor­ship controversies. Often their reporting has quite obviously sided with school authorities.

Such was the case in the fall of 1974 in Kanawha County, West Virginia, when parents—mostly Protestant fundamentalists with lit­tle university education—objected to the textbooks chosen for the local school system. The media and almost all professional education organizations portrayed the protesters as anti-intellectual extremists who were in close touch with national right-wing pressure groups. They were portrayed as censors and bookburners who had little ap­preciation for the democratic and pluralistic traditions of America.

But as George Hillocks, Jr., of the University of Chicago, later demonstrated in an article in School Review, the situation in Kana­wha County was not so simple. His examination of the disputed texts clearly showed that many of the fundamentalist parents’ criticisms were justified. Texts routinely portrayed Christians and Christianity in an unfavorable light. “Sometimes,” writes Hillocks, “the depreca­tions of Christianity . . . are explicit. More often they are implicit, and therefore more dangerous: Sunday school depicted as a tedious bore, a minister characterized as self-righteous, photographs of churches in obvious states of decay and collapse.”(49) Books for older students presented mainly pessimistic and gloomy assessments of the human situation, directly contradicting the more hopeful and posi­tive views of parents and church. Hillock writes:

Intentional or not, the anthology certainly emphasizes a particular view of man and, in part, a modern existential view—that man has nothing beyond immediate existence. That view, in turn, is based upon the philosophical and scientific ideas that knowledge must be derived from evidence accessible to the senses and judged in terms of probabilities. Obviously, such concepts lead to rejection of the basic tenets of orthodox Christianity.(50)

Hillocks concludes his thoughtful analysis with the judgment that “there is little question that the reading selections and the study ma­terials [in the Kanawha County school system] have been generated from assumptions about human existence that are vastly different from those held by fundamentalist Christians.” He finds this particu­larly disquieting in light of the “monolithic system of public educa­tion prevalent in this country.”(51)

Not only have school authorities often made it well-nigh impossi­ble for protesting parents to gain a fair hearing, but they have also at times refused to provide parents with adequate information about school practices and have hindered or denied access to curricula and lesson plans. In some instances they have been rude and insulting to textbook critics.

Also, college and university professors of education have some­times been less than helpful. Their use of terms like “reign of hyster­ia,” “intellectual terrorists,” and “strident and sophisticated cam­paign of intolerance” in reference to censorship disputes seems exag­gerated, to say the least. Not infrequently, they have patronized pro­testing parents, as does Professor Kenneth Donelson of Arizona State University when he writes: “Obviously, a censor should be treated politely and fairly, and his objection considered fairly by a commit­tee.”(52) The remark seems well-intentioned, but if Donnelson had fol­lowed his own advice he would not have tagged protesting parents with the pejorative label “censor” in the first place, for its negative flavor so prejudges the entire encounter that rational discussion and fairness are virtually precluded. Cornell Professor Dorothy Nelkin uses the far more neutral terms “book watchers” and “textbook critics.”(53)

Admittedly, protesting parents sometimes have exercised poor judgment and bad taste in their use of language. Certain fundamen­talist Christians may themselves feel comfortable talking about the “the power of Satan” or using phrases like “the devil made me do it,” but for them to employ language of this sort in public debate in relation to their opponents is both naive and unjustifiable.

The question of fairness also comes into play in connection with what might be termed the “burden of proof” problem. When par­ents object to obscenities in English textbooks, teachers will often respond “But can you prove that these really will harm your chil­dren?” Obviously, such “proof” is not easy to come by, and, of course, the definition of “harm” is seldom clear. One would need to ask, among other things: What period of time are you considering—a few months or years, a lifetime, eternity? And other parents may be­lieve that using obscene language or being exposed to it unnecessari­ly—particularly at a young age—is wrong in principle. That is, they may prefer to view the issue in terms of basic rights and wrongs, not in terms of a utilitarian calculus of harm and benefit.

But why not shift the burden of proof? Would it not be just as le­gitimate to turn the question around and ask the teacher: “Can you prove that these obscenities will not harm my child?” Or, taking a principled approach, the parent could ask, “Can you prove that it is right for 11th or 12th graders to read materials of this sort?” Clearly, when the questions are put in this way, it is evident that neither side—teachers or parents—can prove the correctness of their posi­tion. Both views rest on basic assessments of human nature and on the acceptance of fundamental beliefs and values.

Indeed, we could easily marshal reasonable arguments in favor of the position espoused by the protesting parents. “When censors con­demn some literary works as morally corrupting, we often treat those claims with ridicule,” writes Robert C. Small, Jr., dean of Virginia Polytechnical Institute and State University. But it makes no sense, he continues, “to believe that literature can make people better but that it cannot make them worse. Either it has power or it does not. And if it does have power, then it is to be feared as well as ad­mired.”(54)

A DEEPER UNDERSTANDING OF WHAT CENSORSHIP IS AND IS NOT

One of the major spin-offs of the public school censorship debate could well be a more satisfactory understanding of what actually constitutes censorship. Such a deepening of understanding is not an uncommon result of the kind of basic value, or even paradigm, con­flict that we see in these current controversies.

The chief problem with the terms “censor” and “censorship” in our own contemporary society is that the pejorative emotional tone of the terms is clear, but exactly who or what is to be denoted by the terms is not at all clear. Most would agree that a government official who, through one means or another, denies citizens access to printed material, films, or television and radio broadcasting is a censor. Most Americans would also agree that some degree of censorship is neces­sary in wartime, and typically the courts have permitted communi­ties to censor certain forms of pornography. Parents and schools reg­ularly deny children access to particular ideas and experiences. Al­most all parents also must be understood as censors if we take the dic­tionary definition of “any person who supervises the manners or morality of others.” Indeed, most Americans would fault parents who made no attempt to guide their children in these respects. Or if we take the dictionary meaning of the censor as an “adverse critic or a faultfinder,” then it is clear that no one religious or political group in America has a monopoly on the term.

The deepest irony of current public school censorship controversies is that most of those who freely apply the term to others may them­selves be censors at a more profound and fundamental level. By giv­ing their support to a monopoly system of government schools, these people help maintain an institution which is inherently coercive with respect to dissenting minorities, an institution which routinely cen­sors (often by omission) subject matter and ideas which do not have government approval. Within such a system, as my analysis has made clear, it is precisely those who lack power to effect change through established mechanisms who often must protest, disagree, or “censor” in order to maintain their own integrity and not violate their own consciences.

To be sure, there are a few religious zealots and political ideolo­gists of both the Far Right and the Far Left who would like to use the public schools simply to promote their own doctrines. But my perception is that the great majority of Catholics and Protestant Fundamentalists do not want to use the public schools in this way. As we have seen, Cal Thomas does not believe the public schools should be used to preach the gospel. Rather what many so-called “censors” are, in effect, saying to the government school system and to local school establishments is: “Get off our backs! Stop forcing our children into the ideological mold that you deem best for them. Stop requir­ing them to read those books and adhere to that curriculum which you have chosen and to which you have given the stamp of approv­al.”

It is also my perception that many, if not most, of these so-called “censors” would, if given the option, gladly trade our present gov­ernment monopoly system of financing schools for a voucher system that would allow parents genuine choice regarding the kind of edu­cation their children received.

But it is precisely at this point that the National Education Associa­tion, People for the American Way, and the many other organiza­tions committed to our present system of government monopoly schools say in effect: “No! Vouchers would destroy public education. In a democracy, the majority knows what is educationally best for children, for all children, for your children. We support the govern­ment’s effective monopoly in schooling, the right of the majority to require your children to study state-prescribed curricula taught only by government-certified teachers in government-operated schools. But we are not censors. It is you who dare to object to the wisdom of the majority who are the censors and book burners!”

Obviously, this is not literally what supporters of our present sys­tem of public education ever would say. But, it is how dissenting ide­ological and religious minorities hear and experience the majority’s position.

Supporters of the present public school system, rather, would put forward the argument that public schools are necessary to prevent social and political fragmentation, to strengthen community values, to guarantee equality, non-discrimination, and justice. As already noted, they would argue that exposing the child to a multiplicity of values and experiences rather than a few narrow, bigoted, and paro­chial values and beliefs will strengthen pluralism and respect for people who hold to differing beliefs and world views.

But it is critically important to understand that at the structural level these defenders of one system of government-financed schools are quite willing to use the coercive power of the state to maintain a system of schools that fosters their vision of good education and the good life. This is to be a “guardian of morality” par excellence!

By contrast, most of those whom People for the American Way labels “censors” and “book burners” do not want to employ the pow­er of the state to force their vision of good education on others. They would be happy to witness the disestablishment of our present gov­ernment monopoly school system. They would support a voucher plan where parents could make their own choices about schools for their own children.

TWO FINAL QUESTIONS

Two important questions remain unanswered.

1. Will responsibility and authority for the education of and for the inculcation of beliefs and values in chil­dren rest primarily with the parents or with the state?

Historically, Americans have opted for the parents. Public schools have been understood to function in loco parentis, in the place of or on behalf of the parents. But recent trends suggest that the state is expanding its power over children at an increasing rate.

Admittedly, almost all Americans believe that the freedom of par­ents to make decisions about their children’s education should not be viewed as absolute. Children need to be protected from potential parental negligence and abuse, and furthermore the state has a compelling interest in making sure that its citizens become economically competent to function in a modern technological society (so that they will not become wards of the state dependent on public welfare) and also sufficiently knowledgeable to become effective citizens in a democratic society. These state needs can be met by requiring schools to offer instruction and maintain minimum standards in basic subject areas such as reading, writing, math, and civics in order to be eligible to receive vouchers.

Already in the initial establishment of government-operated schools in the first half of the 19th century, however, the state ex­panded its power over children beyond what might reasonably be defined as compelling state interest. And with the increasing central­ization of power in government schools—power to choose textbooks, determine curriculum, and set standards—the idea of local control of public schools and of the schools functioning in loco parentis has be­come a comforting but grossly inaccurate myth.

To be sure, parents make mistakes at times regarding the educa­tion of their children. Some of these mistakes will harm children. It would be good if such harm could be avoided. But to give excessive power to the state is to take a far greater risk, namely the risk of tyr­anny, state indoctrination, loss of freedom, and destruction of genu­ine pluralism.

We have already noted the emphasis in the 1948 United Nations Universal Declaration of Human Rights upon parental involvement in choosing the kind of education their children should have. The Second Vatican Council uses similar language when addressing the question of educational freedom: Civil authorities should see to it that children can be educated “according to the moral and religious convictions of each family.” Also, when choosing schools for their children, parents should be “genuinely free to follow their con­sciences.” Thus civil authorities should make sure that no school monopoly develops. “For such a monopoly would militate against the native rights of the human person, the development and spread of culture itself, the peaceful association of citizens, and the plural­ism which exists today in very many societies.”(55)

Considering the fundamental importance of true family choice in education, it may be that Christians and others concerned about the survival of genuine pluralism should seek a Constitutional Amend­ment that would formalize the kind of educational rights mentioned by these two important documents.

If the state’s monopoly in education were to be broken by disestab­lishing public schools and turning to a system of universal education tuition vouchers, parents would be free to choose for their children the education they considered most appropriate for preserving the religious beliefs and values of the family. My judgment is that parents, rather than educational professionals or bureaucrats functioning on behalf of the state, should be permitted to judge which values are best to impart to their own children. This does not mean that parents would do the actual teaching. They would in most cases need profes­sional assistance. But they would keep control of the process. Nor does it mean that professional teachers would not exercise their own judgment and practice their special skills. Sensitive parents would recognize teachers as professionals and would understand the folly of interfering too much in the teaching process. Rather, by choosing schools for their children that fit well with the parents’ values and that appeared capable of meeting the particular needs of their chil­dren, parents would, in effect, be entrusting their children to the teachers, administrators, and others who made up the staff of these schools.

Contracts between parents and schools would be made in an at­mosphere of freedom, for power would no longer reside mainly in the hands of the state and of the school as a representative of the state.

Just as in an earlier age Americans decided against the establish­ment of a single national church by the federal government (a prin­ciple later extended to the individual states), so today there is the possibility of choosing away from our system of government-estab­lished schools in favor of educational freedom. And the need for such a move becomes increasingly acute as local control of public schools increasingly gives way to centralized bureaucratic government con­trol and to control by the courts.

2. How much freedom are the political majority and those in power willing to give to dissenting minori­ties, to people who hold different points of view from those of the majority?

Are we as a nation really committed to pluralism, to the preserva­tion of differences, or do we believe that government—acting on behalf of the political majority and through the bureaucratic struc­tures of the educational establishment—knows best how to educate and socialize children? And do we adequately appreciate the role of structural pluralism? Liberal educators often tend to see pluralism in terms of the individual student’s right to free expression and freedom to read and learn what he or she wants. But surely this is naive, for pluralism almost certainly will not survive if it is dependent on indi­viduals making isolated value choices. If we have learned anything from sociology, it is that values are related to communities and that, therefore, enabling structures are necessary if a tradition is to survive and flourish.

One argument made against educational vouchers is that such a system would lead to excessive fragmentation of society. Everyone would do his or her own thing. People would likely commit them­selves to all sorts of strange goals and values, and society would not be able to hold together. Significantly, this is roughly the same argu­ment that was presented more than 200 years ago against those who wanted no federally established church in America. Society would fall apart and become a collection of contentious fragments. People would be taught and would commit themselves to all sorts of strange beliefs. Yet we know that this did not happen. On the contrary, the establishment-prohibition has led to great freedom and creativity in American culture. We have become a truly open society, at least in comparison to most nations of the world.

Of course, one reason why the non-establishment of a national church did not lead to social fragmentation is precisely that govern­ment schools gradually came to provide the social glue that in earlier forms of society was provided by a common religious frame. One of the chief motivations for establishing a system of government schools was to counter what was felt to be the pernicious and potentially di­visive influence of the hordes of Roman Catholic immigrants enter­ing the United States during the first part of the 19th century. Public schools would teach these foreigners correct values and would initi­ate them into the American way.

Curiously, political liberals today who support a system of govern­ment schools because of their worry about social fragmentation should we disestablish this system, at the same time tend to favor bi­lingual education for Hispanics and others. And many conservatives who are open to or in favor of disestablishment and educational vouchers oppose bilingual school programs. Perhaps this suggests that the critical issue which demands closer scrutiny is not that of frag­mentation per se but rather the question of whether the state can be genuinely neutral about religion in government schools. Liberals by and large think it can and thus dismiss Catholic and Fundamentalist criticisms of public schools as misguided and as an outgrowth of right-wing political commitments. But, in actuality, both school sup­porters and school critics are, for the most part, concerned about po­tential social fragmentation.

The danger of excessive fragmentation of society would be low­ered by the establishment of minimum standards in the basic subject areas noted above. Furthermore, with the pervasive and extensive influence of television, movies, and the mass media in general, indi­viduals can isolate themselves from the ideas, beliefs, and values of the society as a whole only with considerable effort.

Are we Americans willing to let people think for themselves; to preserve their particular religious, social, and moral traditions; and to take charge of the education of their own children? Distressingly, many educators seem more intent on wanting to improve and reform society by controlling the schooling of other people’s children than they seem to be committed to basic freedom of speech and basic freedom in teaching and learning. The same people who criticize the fundamentalists for being censors and bookburners and who speak a great deal about academic freedom appear not to be willing to let people take charge of their own education and the education of their children. They want to maintain majority control of the schools even if this is experienced as coercive and oppressive by dissenting minori­ties. Their argument that racism would increase or that society would become too fragmented under a voucher system sounds suspiciously like a rationalization for their continued control of the public schools. On the other hand, voucher advocates must be sure that their own motives are honorable. Establishing a voucher system as a means of guaranteeing freedom of conscience and preserving genuine plural­ism is defensible. Attempting to preserve economically and racially segregated schools is not.

Education can be viewed primarily as a means of imparting tech­nical skills to children which will enable them to function effectively in a technological, control-oriented society. It can be seen as an op­portunity to reform society by influencing children. But it can also be understood mainly in terms of the freedom of the human spirit, in connection with the right of each tradition to survive and flourish, and in light of America’s historic commitments to religious liberty and freedom of conscience. Rather than glibly labeling protesting parents “censors,” we need to understand that we face far more seri­ous and fundamental issues. As a nation conceived in liberty under God, we must address in a new way what it means as a free people to educate our children.

REFERENCES

1. Cal Thomas, Book Burning, Westchester, Illinois: Crossway Books, 1983, p. 13.
2. Barbara Parker and Stefanie Weiss, Protecting the Freedom to Learn: A Citizen’s Guide, New York: People for the American Way, 1983.
3. Id. at p. 18.
4. Id. at pp. 22, 30, 56, 58.
5. Thomas, supra n. 1, p. 26.
6. Parker and Weiss, supra 2, p. 9.
7. Thomas, supra n. 1, p. 50.
8. Id. at p. 73.
9. Id. at p. 76.
10. Parker and Weiss, supra 2, p. 11.
11. Thomas, supra 1, p. 79.
12. Stephen Arons, Compelling Belief: The Culture of American Schooling, New York: McGraw-Hill, 1983, p. 211.
13. Edward B. Jenkinson, “Dirty Dictionaries, Obscene Nursery Rhymes, and Burned Books,” in Dealing with Censorship, James E. Davis, Urbana, Illinois: National Council of Teachers of English, 1979, p. 12.
14. John Stuart Mill, On Liberty, Quoted from Selected Writings of John Stuart Mill, ed. Maurice Cowling, New York: New American Li­brary, 1968, p. 220.
15. Guidelines for Equal Treatment of the Sexes in McGraw-Hill Book Company Publications, Alma Graham, New York: McGraw-Hill, 1974.
16. Id. at p. 12.
17. Kenneth A. Strike, Review of Dealing with Censorship, James E. Davis, Urbana, Illinois: National Council of Teachers of English, 1979, in Harvard Educational Review Vol. 50, no. 3 (August 1980), p. 435. Exact wording is taken from an unpublished draft of this review, p. 6.
18. Alan Glatthorn, “Censorship and the Classroom Teacher,” in Dealing with Censorship, 52.
19. Id. at p. 81.
20. Quoted in Parker and Weiss, supra 2, p. 111.
21. Wardell B. Pomeroy, “A New Look at Incest,” Penthouse Forum, 6, No. 2 (November 1976), pp. 8-13.
22. Parker and Weiss, supra 2, p. 5.
23. Id. at pp. 5-6.
24. 393 U.S. 503, 511 (1969).
25. Id.
26. Strike, supra 17, p. 436.
27. How Porcupines Make Love: Notes on a Response-Centered Curricu­lum, Alan C. Purves, New York: John Wiley, 1972, pp. 31, 37.
28. John Dewey, A Common Faith, New Haven: Yale University Press, 1934, p. 87.
29. Paul C. Vitz, Psychology as Religion: The Cult of Self-worship, Grand Rapids, Michigan: William B. Eerdmans, 1977.
30. Richard A. Baer, Jr., “Teaching Values in the Schools: Clarification or Indoctrination?”, Principal, 61, No. 3 (January 1982), pp. 17-21, 36. See especially references to other evaluations of Values Clarification in end notes. See also Richard A. Baer, Jr., “Parents, Schools and Values Clarification,” The Wall Street Journal, Vol. CXCIX, No. 70 (April 12, 1982), p. 22.
31. Rockne McCarthy, Donald Oppewal, Walfred Peterson, and Gordon Spykman, Society, State, and Schools: A Case for Structural and Confes­sional Pluralism, Grand Rapids, Michigan: William B. Eerdmans, 1981, pp. 82-83.
32. McCarthy, et al., supra 31, p. 83.
33. Arons, supra 12, p. 198.
34. Id. at p. 206.
35. Herbert W. Titus, “Education, Caesar’s or God’s: A Constitutional Question of Jurisdiction,” Journal of Christian Jurisprudence (Symposi­um: Church Family, State, and Education), 1982, p. 169.
36. 408 U.S. 92, 96 (1972).
37. Id. at pp. 95-96.
38. Tinker v. Des Moines, 393 U.S. 503, 506 (1969).
39. 408 U.S. 92, 96 (1972).
40. Id. at p. 97.
41. Shelton v. Tucker, 364 U.S. 479, 488 (1960); United States v. Robel, 389 U.S. 258, 268 (1967).
42. 364 U.S. 479, 488 (1960).
43. Titus, supra 35, p. 176.
44. Parker and Weiss, supra 2, p. 7.
45. The Universal Declaration of Human Rights: A Standard of Achieve­ment, United Nations Office of Public Information (U.N. Publ. No. 62.1.9), 1948, Article 26, pp. 37-38.
46. Parker and Weiss, supra 2, p. 19.
47. Id. at p. 112.
48. Strike, supra 17, p. 436.
49. George Hillocks, Jr., “Books and Bombs: Ideological Conflict and the Schools-a Case Study of the Kanawha County Book Protest,^– School Review, 68, No. 4 (August 1978), p. 642.
50. Id. at pp. 649-50.
51. Id. at p. 650.
52. Kenneth L. Donelson, “Censorship in the 1970s: Some Ways to Handle It When It Comes (And It Will),” in Dealing with Censorship, 165.
53. Dorothy Nelkin, Science Textbook Controversies and the Politics of Equal Time, Cambridge, Massachusetts: The MIT Press, 1977, chapter 4 and elsewhere.
54. Robert C. Small, Jr., “Censorship and English: Some Things We Don’t Seem to Think About Very Often (But Should),” in Dealing with Cen­sorship, 59.
55. The Documents of Vatican II, Walter M. Abbott, New York: Herder and Herder and Association Press, 1966, pp. 644, 645.