Karen White v.

Board of Education 1

Karen White v. Board of Education

Nina Spitler

College of Southern Nevada

Karen White v. Board of Education 2

Abstract

In this case, Karen White, a kindergarten teacher with affiliations to the Jehovah’s Witnesses

religion, refuses to participate in decorating for holidays or leading the students in the Pledge of

Allegiance every morning. After her school tried accommodating her for a school year and her

students were falling behind in certain curriculum, the school asked her that for the next school

year, she will need to teach the students about holidays and the Pledge of Allegiance. She

refused. With the court cases Palmer v. Board of Education and Florey v. Sioux Falls, I showed

how they relate to the case of Karen White and her recommendation for dismissal. They relate in

the sense that she is not meeting the students’ needs. I also used the court cases Wisconsin v.

Yoder and West Virginia v. Barnette to show how her dismissal and disregard for her religion

could be ruled as unconstitutional. With my understanding so far, I think the Supreme Court will

rule against Karen White because her religious beliefs are impeding with the children’s

education.
Karen White v. Board of Education 3

A kindergarten teacher, Karen White, recently acquired a new affiliation with Jehovah’s

Witnesses. Her new religion does not allow her to celebrate holidays or do gift exchanges during

any holiday. This meant that she will not decorate the room for the children during any holiday

or accept any gifts brought to her. Due to her beliefs she was not able to sing the “Happy

Birthday” song during a student’s birthday or recite the Pledge of Allegiance every morning.

Karen White let the parents know so that they would be informed of why she would not be

teaching that to the children. Many parents complained and in turn, Bill Ward, the school

principal, recommended for her dismissal because he felt the students’ needs were not being met.

Karen filed a lawsuit against the school.

In the court case of Palmer v. Board of Education of the City of Chicago, a kindergarten

teacher who’s religion was Jehovah’s witnesses refused to teach lead the students in the Pledge

of Allegiance or any patriotic songs. For the 1976-77 school year, the school tried to

accommodate her by having other teachers come and lead in the Pledge of Allegiance but

sometimes it wouldn’t work out and the students were not properly learning what other students

in the same grade were learning. On one occasion, a student brought Palmer a gift for

Valentine’s Day but she refused to accept it, which made the student cry. When her students

were reaching first grade, the teachers had to teach them material that they should’ve learned in

Kindergarten. For the next school year, the school sent a letter to Palmer explaining seven things

they expected from her for the next school. The seven requests were, “to teach and direct, with

proper diction and understanding, the Pledge of Allegiance to the flag of the United States, teach

and direct the proper words and music of ‘America,’ teach and direct the proper words and music

of other appropriate patriotic songs as well as other songs customarily taught to kindergarten
Karen White v. Board of Education 4

children, teach and direct proper rhythms, dances and body movements to develop large motor

skills, teach, direct and conduct activities preparatory to a variety of holidays commonly

observed so children learn the ethos of all people and develop tolerance and appreciation, teach

and direct play activities which develop social and personal interrelationships, and teach

children, by direction and example, to express skills of appreciation and gratitude.” (Palmer v.

Brd. Of Education, p. 4) Palmer wrote a letter back explaining that because of her religious

beliefs, she would be unable to comply with steps 1, 2, 3, and 5 but would exceed at steps 4,6,

and 7. The school recommended for her dismissal and said they could no longer accommodate

her and could not find a good fit. She filed suit. The court ruled against Palmer. Like in the case

of Karen White, I think the court could use this case to their defense against White because she is

not meeting the needs of her students and therefore her students are not learning the material

other students are learning in the same grade level.

In Florey v. Sioux Falls School District, Roger Florey sued the school district because of

a number of songs the students had to memorize for a Christmas assembly at the school. Two

kindergarten classes had to rehearse and memorize “the beginners Christmas quiz,” which was a

religious Christmas quiz for an assembly during the holiday season. Roger felt that the school

was pushing religion on the children and filed suit. The school felt that they were only teaching

the song to expand education and understanding of different beliefs of Christmas and was only

done during the holiday season. After doing the Lemon test, the court ruled “that the policy, rules

and the implementation thereof do not result in any particular relationship between the school

and any religious authority.” (Florey v. Sioux Falls, p. 37) I believe this court case relates to

Karen White because like in this situation where the students were being taught about Christmas,

Karen’s kindergarten students would miss out on learning about it due to her religion. This
Karen White v. Board of Education 5

would probably be the first time they are being taught about Christmas in a school setting and

she would deprive them of that, unlike the rest of their peers in the school. When the students

reach first grade, they will lack knowledge on the subject. Therefore, I think the court will use

this case to rule against Karen for once again, not meeting the students’ needs.

In the court case of Wisconsin v. Yoder, a member of the Old Order Amish Religion sued

the school district for charging him with violating Wisconsin’s compulsory school attendance

law after they took their children out of school after the eighth grade for religious reasons. In the

Amish community they feel that the children only need basic education to succeed in the Amish

community and that “high school education beyond the eighth grade is contrary to Amish

beliefs.” (Wisconsin v. Yoder, p. 18) Because they chose to take their kid’s out of school, they

were charged for violation the compulsory school attendance law so they sued the school. The

court ruled that, “the state had no compelling interest in requiring Amish children to attend

school past the time their basic educational skills had been learned.” (Underwood & Webb, p.

211) I believe the court will use this case to rule in favor of Karen White because the school is

being unconstitutional to Karen’s religious rights.

Finally, in the court case of West Virginia v. Barnette, a student refused to stand and

salute the flag and recite the Pledge of Allegiance due their religious beliefs which resulted in

suspension for “insubordination.” The school counted the absences as unlawful, resulting in a

$50 dollar fine to the student’s parents. (W. Virginia v. Barnette, p. 14) The student was

affiliated with Jehovah’s witnesses and therefore it is against their religion to honor the country’s

flag. The parents filed suit. The court ruled the school’s actions unconstitutional and ruled in

favor of the student. I believe this case could be used in favor of Karen White because like
Karen White v. Board of Education 6

Barnette, she is affiliated with Jehovah’s Witnesses and it is against her religion and beliefs to

recite the pledge, which in turn, she cannot teach it to the students.

After reading each court case, I think the court will rule against Karen White. Although it

is her religion and the school cannot force her to recite the pledge, her job is to teach her students

and if she cannot meet part of the curriculum, then she would seem unfit for the job. Like in the

court case of Palmer v. Board of Education, she is not meeting the needs of the students and in a

school environment, the students come first. With all due respect, she knew what she was signing

up for when she was attending school to become a teacher; therefore, if she knew she would be

unable to fully do her job, then she should have chosen a different profession. As teachers, we

are there to teach the students to the best of our abilities and when the students are reaching first

grade but are behind in some subjects because of the teacher’s beliefs, then she is restricting

those students and a parent has every right to be upset. I believe as a teacher, you have the right

to practice any religion you want so long as it is outside of school hours and it does not affect

your quality of work.

Karen White v. Board of Education 7

REFERENCES

Palmer v. Board of Education (1979, January 31). In Justia U.S. Law. Retrieved October 12,

2018, from https://law.justia.com/cases/federal/district-courts/FSupp/466/600/2361432/

Florey v. Sioux Falls School District (1979, February 13). In Justia U.S. Law. Retrieved October

12, 2018, from https://law.justia.com/cases/federal/district-courts/FSupp/464/911/1520042/

Wisconsin v. Yoder (1972, May 15). In Justia Supreme Law. Retrieved October 12, 2018, from

https://supreme.justia.com/cases/federal/us/406/205/

West Virginia v. Barnette (1943, June 14). In Justia Supreme Law. Retrieved October 12, 2018,

from https://supreme.justia.com/cases/federal/us/319/624/

Underwood, J., & Webb, L. D. (2006). School Law for Teachers Concepts and

Applications (fourth ed., p. 211). Upper Saddle River, NJ: Pearson Education Inc.