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The U.S. Court of Appeals for the First Circuit ruled that private religious schools receiving public funds must follow state laws prohibiting discrimination based on gender identity, sexual orientation, or religion.
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Saint Dominic Academy in Auburn and Bangor Christian Schools, run by Crosspoint Church, sought exemptions from the Maine Human Rights Act.
Source: Saint Dominic Academy and Bangor Christian Schools
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The schools argued that enforcing policies such as admitting openly gay or transgender students or requiring teachers to use preferred pronouns contradicted their religious beliefs.
Source: Saint Dominic Academy and Bangor Christian Schools
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The appeals court largely upheld a lower court’s decision denying the exemption requests.
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The appeals court asked the lower court to reconsider how the state’s rules around religious expression apply to religious schools.
Relevance: supporting · Type: background
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Maine allows students in towns without public schools at their grade level to attend approved private schools at the state’s expense.
Source: Maine Legislature
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Religious schools were excluded from Maine’s town tuitioning program from 1981 until 2022.
Source: Maine Legislature
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The U.S. Supreme Court ruled in a 6-3 decision in 2022 that limiting Maine’s tuitioning program to nonsectarian schools violated the First Amendment’s religious liberty protections.
Source: U.S. Supreme Court
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The Maine Legislature amended the Maine Human Rights Act to explicitly prohibit discrimination on the basis of gender identity and religion in education.
Source: Maine Legislature
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The Maine Legislature clarified that an exemption allowing religious schools to discriminate based on sexual orientation only applied to schools not receiving public funds.
Source: Maine Legislature
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Saint Dominic Academy and Crosspoint Church challenged the amendments to the Maine Human Rights Act in the U.S. District Court for the District of Maine in 2023.
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The schools argued that the state’s antidiscrimination rules were not neutral toward religion and violated their First Amendment rights.
Source: Saint Dominic Academy and Bangor Christian Schools
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Crosspoint Church argued that following the Maine Human Rights Act would force Bangor Christian Schools to admit students with sexual orientations, gender identities, or religious views inconsistent with its central religious tenets.
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Saint Dominic Academy argued that state laws would require it to facilitate a student’s gender transition over parental objection and discipline staff who object to using a student’s preferred pronouns.
Source: Saint Dominic Academy
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A U.S. District Court judge denied both schools’ requests in 2024, finding no constitutional violations in the state’s implementation of its antidiscrimination laws.
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The court ruled that private religious schools receiving public tuition assistance cannot discriminate against students on the basis of gender identity or sexual orientation.
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The court ruled that private religious schools receiving public tuition assistance cannot give preferential treatment to students of a particular faith in the admissions process.
U.S. Court of Appeals for the First Circuit, court
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"Just as combatting religious discrimination qualifies as a legitimate governmental pursuit, so too combatting sexual-orientation and gender-identity discrimination rises to that level," the court found.
Relevance: supporting · Type: background
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The Maine Human Rights Act allows religious schools receiving public funding to hire only members of their own faith or ensure employees conform to religious tenets.
Source: Maine Human Rights Act
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The court found that requiring students to attend religious services and agree to uphold the school’s mission does not violate current state law.
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The court sent the issue of the Maine Human Rights Act provision forbidding discrimination between religious practices back to the lower court.
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The court found that the Religious Expression Rule would interfere with a religious school’s ability to foster an expressive environment consistent with its religious mission.
U.S. Court of Appeals for the First Circuit, court
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"And while such an example may seem fanciful, the point is that the Religious Expression Rule would inevitably interfere with a religious school’s ability to foster an expressive environment consistent with its religious mission," the court wrote.
Adèle Keim, attorney
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Adèle Keim, an attorney with The Becket Fund for Religious Liberty representing Saint Dominic Academy, described it as "ridiculous" to suggest a Catholic school couldn’t give parish members preference in admissions.
Adèle Keim, attorney
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Adèle Keim said the First Circuit "stuck their finger in the eye of the U.S. Supreme Court" by finding Maine’s application of gender identity antidiscrimination policies constitutional.
Jeremy Dys, senior counsel
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Jeremy Dys, senior counsel at First Liberty Institute representing Crosspoint Church, said the First Circuit opinions allow Christian schools to teach what they believe but refuse to give them the freedom to require conduct consistent with those beliefs.
Jeremy Dys, senior counsel
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"We’re looking at all the correct options right now for our client in response to this opinion," Dys said.
Jeremy Dys, senior counsel
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"Certainly an appeal to the Supreme Court may become necessary," Dys said.
American Civil Liberties Union of Maine, organization
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The American Civil Liberties Union of Maine stated that all schools receiving state funding should "play by the same rules."
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The U.S. Supreme Court is set to hear a case this fall regarding whether a Colorado law requiring preschools to comply with an equal opportunity requirement to receive public funding violates the ruling in Carson v. Makin.
Source: U.S. Supreme Court
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