Erwin Chemerinsky and Howard Gillman: Weaponization of the Free Exercise Clause

Photo from Shutterstock
People rally for LGBTQ rights outside the Supreme Court on Oct. 8, 2019, as justices heard oral arguments in three cases dealing with discrimination in the workplace because of sexual orientation.

The Supreme Court is trying to stop civil rights advances

This article first appeared in The Atlantic on Sept. 18 and is republished with permission.

By Erwin Chemerinsky
and Howard Gillman

There was a time when the Constitution’s protection of the “free exercise” of religion was a sort of shield, a protection for religious minorities from the prejudices of the powerful. No longer. The Supreme Court’s conservative majority is in the process of transforming this First Amendment clause into a sword that politically powerful Christian conservatives can use to strike down hard-fought advances in civil rights, especially for LGBTQ individuals and women.

At issue is whether religious believers who object to laws governing matters such as health care, labor protections and antidiscrimination in public accommodations should have a right to an “exemption” from having to obey those laws. In recent years, religious pharmacists have claimed that they should not be required to fill prescriptions for a legal and authorized medical procedure if that procedure is inconsistent with their beliefs. A court clerk whose religion defined marriage as a union of a man and woman has claimed a free-exercise right to refuse marriage licenses to same-sex couples who have a constitutional right to marry. Religious business owners, such as bakers and florists, who object to same-sex marriage have claimed a right to refuse service to same-sex couples. And employers have successfully asserted a right to deny their workers health-care benefits that they would otherwise be entitled to, such as contraception or abortion counseling.

Providing such religious exemptions has required a dramatic change in the law by the Supreme Court. In 1990, in Employment Division v. Smith, the Supreme Court held that the Free Exercise Clause of the First Amendment cannot be used as a basis for an exception to a general law, no matter how great the burden on religion, unless the government’s action can be shown to be based on animus to religion. The case involved a claim by Native Americans for a religious exception to an Oregon law prohibiting consumption of peyote.

Justice Antonin Scalia wrote the opinion for the court, ruling against the Native Americans and explained that it would be impossible to provide religious exemptions from civic obligations whenever a person disagreed with the law — there are just too many civic obligations and too many different religious views about those obligations. Also, if the government were to begin down this path, it inevitably would face the impossible task of defining a “religious” belief. Such an approach would force the court to make intrinsically controversial and discriminatory decisions about which religious views were most deserving of special accommodation and which social values should be considered less important than the favored religious views.

This decision was in line with the approach taken by the Supreme Court, in almost all cases, through American history. Courts long held that the Constitution did not require an exception to general laws on account of religious beliefs — that parents could not deny medical aid to their children, that they could not have them work in violation of child-labor laws, even if the work involved dispensing religious literature, that religious schools could not violate laws against racial discrimination, and that a Jewish Air Force psychologist could not ignore the uniform requirement by wearing a yarmulke.

Unfortunately, the conservative justices on the current Supreme Court reject Scalia’s reasoning and may be about to overrule Employment Division v. Smith. If they do so, the Supreme Court’s conservative majority will in essence be saying that the views of Christian conservatives are more important than legal protections for workers and people who seek to engage in ordinary commercial activity without suffering discrimination.

The first sign of this shift came with the 2014 decision in Burwell v. Hobby Lobby, when for the first time in American history, the court held that the religious beliefs of a business’s owner allowed it to refuse to provide employees with a benefit required by law. Under the Affordable Care Act, employers are required to provide health-insurance coverage, including coverage for contraceptives for women. The Affordable Care Act had already carved out an exemption for religious not-for-profit organizations, so that, for example, a Catholic diocese would not have to provide contraceptive care to its employees. (Legislatures can choose to give religious exemptions, even though the Constitution does not require them.) But at issue in Hobby Lobby were the rights of the owners of a purely secular business. The five conservative justices held that a family-owned corporation could deny contraceptive coverage to women employees based on the business owners’ religious beliefs.

The dissenters, led by Justice Ruth Bader Ginsburg, pointed out that “the distinction between a community made up of believers in the same religion and one embracing persons of diverse beliefs, clear as it is, constantly escapes the court’s attention,” and wondered about religious employers who were offended by health coverage of vaccines, or equal pay for women, or medications derived from pigs, or the use of antidepressants. At the very least, there is a compelling interest in protecting access to contraceptives, which the Supreme Court has deemed a fundamental right.

In June 2020, the court ruled in Our Lady of Guadalupe School v. Morrissey Berru that teachers at a Catholic school could not sue for employment discrimination. The two cases before the court involved a teacher who had sued for disability discrimination after losing her job following a breast-cancer diagnosis and a teacher who had sued for age discrimination after being replaced by a younger instructor.

Previously, in Hosanna-Tabor Lutheran Evangelical Lutheran Church and School v. EEOC (2012), the court said that a narrow exception protects religious organizations from being held liable for choices they make about their “ministers,” which traditionally have been considered “exclusively ecclesiastical questions” that the government should not second-guess. But now the court has expanded that exception to all religious-school teachers, meaning that the schools can discriminate based on race, sex, religion, sexual orientation, age and disability with impunity.

This reflects a court that is likely to expand the ability of businesses to discriminate based on their owners’ religious beliefs. A few years ago, the court considered in Masterpiece Cakeshop v. Colorado Civil Rights Commission whether a baker could refuse, on account of his religious beliefs, to design and bake a cake for a same-sex couple. This should be an easy decision: People should not be allowed to violate anti-discrimination laws because of religious beliefs or any beliefs. For more than half a century, courts have consistently recognized that enforcing antidiscrimination laws is more important than protecting freedom to discriminate on account of religious beliefs. A person cannot invoke religious beliefs to refuse service or employment to Black people or women. Discrimination by sexual orientation is just as wrong. Although the justices in this case sidestepped the question of whether the Free Exercise Clause requires such an exemption, a number of other courts have ruled that compliance with general antidiscrimination laws might impose an impermissible burden on the free exercise of the owner’s religious beliefs, at least when the beliefs are Christian and the protected class includes gay and lesbian people. Moreover, the Religious Right has demanded that it is entitled to such exemptions.

In recent months, the court expanded civil-rights protection for gay, lesbian and transgender individuals, but there is reason to fear that the conservative justices are about to undercut this. In June 2020, the Supreme Court ruled that the federal law Title VII, which prohibits employment discrimination based on sex, forbids employment discrimination based on sexual orientation or gender identity. But Justice Neil Gorsuch’s majority opinion left open the possibility of giving an exception to employers who discriminate because of their religious beliefs. The court should emphatically reject such claims. Selling goods and hiring people on the open market is not the exercise of religion, and stopping discrimination based on sexual orientation or gender identity is a compelling government interest that judges should not dismiss because members of a favored religion disagree with the policy.

Unfortunately, the court appears to be headed in exactly the opposite direction. Next term, which began in October, the court will consider, in Fulton v. City of Philadelphia, whether free exercise was violated by a city’s barring a Catholic Social Services agency from participating in placing children in foster care, because the agency refused to certify same-sex couples as foster parents — in violation of the city’s general nondiscrimination policy. One of the questions before the Court is whether to “revisit” Employment Division v. Smith.

Five justices [perhaps six, pending Amy Coney Barrett’s confirmation status] may be about to do just that — paving the way for the court to allow religious organizations and persons to ignore nondiscrimination laws that protect the LGBTQ community, as well as ignore federal requirements to provide full health benefits to women.

Erwin Chemerinsky is the dean of the University of California, Berkeley School of Law. Howard Gillman is the chancellor of the University of California, Irvine. They co-authored The Religion Clauses: The Case for Separating Church and State.

Nate Phelps: ‘Everything I had been taught was a lie’

Members of Westboro Baptist Church appeared with their signs in front of Ground Zero on the anniversary of the World Trade Center attacks on Sept. 11, 2014.
(Shutterstock photo)
Nate Phelps (lower left) was one of 13 children of Fred Phelps.
Nate Phelps survived living with his abusive father, Fred Phelps, before escaping from the family at age 18.

Nate Phelps is the 2020 recipient of FFRF’s Henry Zumach Freedom From Religious Fundamentalism Award for his years of speaking out publicly for freethought and humanism as the son of Fred Phelps. Nate has received $10,000, thanks to FFRF Member Henry Zumach, who has so generously set up this annual award to reward individuals who are making a difference in fighting religious fundamentalism. Since the 2020 national convention had to be canceled this year due to COVID-19, instead of delivering this speech in person, Nate has submitted this moving article about leaving the Westboro Baptist Church, founded by his father Fred Phelps, known for its inflammatory hate speech.

By Nate Phelps

I am the sixth of 13 children born to Fred and Margie Phelps. I was raised in the Westboro Baptist Church in Topeka, Kan. Our childhood was defined by my father’s interpretation and application of the fundamentalist ideology of John Calvin.

Twice every Sunday, we sat in his small church learning the doctrines of his faith. Absolute Predestination, the cornerstone of Calvinism, turns a key aspect of Christianity on its ear. The notion that one can ask God into their heart and be saved is rejected. Instead, Calvinism argues that humankind is dead in his trespasses and sins and has no capacity to receive salvation unless God first acts on the heart. Humankind has no say about its salvation. God decides. This key doctrine, coupled with the biblical notion that only a “remnant” of humans will be saved, led my father to the conclusion that only those within his church would go to heaven.

Other ideas gleaned from Calvin’s bible (the subservient position of women, corporeal discipline, and lifetime dominion over his children), coupled with Fred’s predisposition to extreme black and white thinking, created an environment of physical and emotional violence in our home.

Because Eve had been fooled by the snake in the Garden of Eden, women were second-class citizens in the Church. They were to be silent. Men were to have dominion over them. They were to wear head coverings in the sanctuary to cover their shame. Paul’s instruction in Corinthians that a woman have long hair became a rigid biblical standard that no woman in our church could ever put scissors to her hair.

Returning from school one day, I found my mother weeping in the vestibule of the church building where we lived. A scarf covered her head. My older brother Mark rubbed her back, trying to console. Suddenly, she tore the scarf from her head exposing the butchered remains of her hair. Her white scalp showed through in several places. “He cut my hair off!” she cried. I recall the feeling of horror, not just for her distress, but because I knew this meant she would go to hell. My father was all-powerful, consigning the disobedient to their eternal destinations.

Physical abuse

When the barber strap that he used to beat his children began to fray at one end, he went in search for a new tool of discipline. Calling a meeting of all the children, he held up the handle of a mattock. Quoting from Proverbs, he reminded us that “Foolishness is bound in the heart of a child; but the rod of correction shall drive it far from him.” This would be his new rod of correction. He called my brother Mark up for an example blow. Swinging the mattock in a high arc like a baseball bat, he struck him on the backside. Mark went white and the lesson was learned.

Several years later, in the early 1970s, my younger brother Jon and I brought home less than perfect report cards from middle school. Forty blows later, the skin on the back of our legs was broken and bleeding. Suspecting abuse, the principal of our school notified the police. An investigation led to charges of child abuse, but my father’s combative and litigious predisposition succeeded in getting the charges dropped. The long-term fallout was more violence for subjecting the Church of the Lord Jesus Christ to ridicule and shame.

Another passage claiming that our physical bodies were God’s temple became the impetus for several extreme experiences in our youth. It began with a health scare when Fred collapsed in his bedroom. Rushed to the hospital, his excess weight and abuse of drugs was determined to be the cause.

Back home from the hospital, Fred read the back of a box of Wheaties where exercise guru Jack LaLanne had outlined an exercise program where one could earn “benefit points.” Within a few days, we were all at the local high school track running laps. Soon, Fred decided he needed to find a way to drop the weight quicker. So, he went on a fast. No calories . . . zero. Days passed and he soon retired to his bed from the weakness. Weeks passed. He dove deep into the bible for inspiration and motivation. At one point late in his fast, his body and mind muted, he spoke of seeing an angel at his bedside. Too weak to move, he used a bell on his nightstand to summon his wife or a child for his every need.

Forty-seven days and nearly 100 pounds lighter, he rose from his bed and rejoined the world. To avoid regaining the lost weight, he returned to the track with renewed vigor and motivation. Like in so many other areas in his life, he went to extremes. A regular running routine quickly morphed into a rigid training regime to run a marathon. Charts were displayed in the back of the church showing the activity and benefit points each child had earned. If a child fell behind, the mattock came out of the corner.

Nutrition experiments

Reading everything he could find on fitness and health, he began imposing a variety of unusual nutrition experiments on his family. One book extolled the virtues of raw eggs, so each child was required to slide two or three eggs, “Rocky” style, down their throat. A variety of nutritional supplements soon became standard fare in our diets. It was not unusual to sit down to a dinner plate of 25 brewer’s yeast tablets, 10 bone meal tablets, rose hips and a half head of steamed cabbage.

Eventually his focus on health turned dark. Our mother, having gone through 16 pregnancies, had lost her youthful shape and that was unacceptable. Entering puberty, several of the children were also putting on a bit too much weight for his liking. Again, citing God’s instruction to treat the body as a temple, he demanded that the weight be dropped. A daily routine of weighing outside his bedroom door led to violent beatings if a child had not lost weight that day.

Several years after Fred began practicing law in Kansas, he was suspended for two years for ethical violations. Without an income, he hit upon the idea to send his children out to sell candy. The official line was that we were raising money for a new piano for our church. Early successes prompted a more expansive effort where the children were spending three or four hours every evening after school, covering the entire city over and over.

When people questioned whether we had raised enough for a piano, it became new carpet and a new organ. After several years, sales in town began to dry up so we started working other communities nearby. On Saturdays, we would travel greater distances to Kansas City and other larger cities. On weekend nights, young children would canvas the bars where drunken patrons were more apt to buy candy and offer generous tips. If a bit of violence occurred, it was a small price to pay to insure the solvency of the Church. And like everything else, corporeal discipline was instilled to motivate the children to maintain proper sales volumes. 

Religious ideology

Our lives were soaked in his religious ideology. Verses were posted and required memorization. At a young age, the children were required to memorize the names and order of all the books in the bible to minimize the time it took to look up passages while he preached. As the children grew, Fred’s sermons became interactive experiences. A child would be called upon to look up a verse and be prepared to read it aloud when directed. Sometimes commentary on the passages read were demanded. Any misstep in this process would lead to a command from my father, “Someone smack that kid!” He was building his army for God and had no patience for ignorance, incompetence or delay.

While all of this was going on, we returned every Sunday to the pews to be trained up in the way we should go. Much like Fred in those years, his God was an angry God. His brand of Christianity beat us over the head constantly about our sinful, evil nature and the righteousness of God’s wrath if he were to condemn us to an eternity of flames where the worm that eats on you never dies. Throughout our childhood, we were constantly reminded of our duty to church and family. It was made clear early on that Fred would have absolute authority over us for our lifetime. An obscure passage in the bible about a man leaving his father and mother to cleave to his wife secured his authority, as our father, until marriage.

From that point on, his authority was derived from his role as our pastor. Any attempt to defy that authority, to forge our own paths in life, meant banishment from the Church and family and eternal damnation.

Approaching the age of maturity, several of the older children attempted to assert control over their own lives. Our father was not having any of that. When my oldest sister left several months before turning 18, he mounted a posse of minions and kidnapped her back home. For several months, she was locked in a room upstairs at the church. My father was determined to beat the rebellion out of her by regularly abusing her and forcing her to fast. When the two oldest boys left as adults, he employed a variety of means to coerce them back. When the second oldest boy, Mark, succeeded in leaving, Fred exploded with anger. Behind the pulpit he made sure the entire congregation knew they were subject to excommunication and other discipline if they had anything to do with him.

Observing Mark’s success, a guttering flame of hope ignited within me. You see, I had taken Fred’s message to heart. I knew that Christ was going to return around the year 2000 and I knew when he did, I would be cast into Gehenna, the final hell of punishment. But perhaps I could live life just a little outside the violence and control of my father. So, at the age of 16, I began to plan. Over the next year, I worked out my strategy. Each violent encounter with my father reinforced my determination. Late in my 17th year, I purchased an old Rambler Classic from the security officer at my high school. I kept it hidden from my family. As my 18th birthday approached, I quietly packed my meager belongings, a box at a time, and hid them in the cluttered garage. 

Walking away

On the night before my 18th birthday, I waited until the household was quiet. I walked down the street to my car and backed it into the driveway. Checking to ensure no one had awoken, I returned to the garage and packed my belongings into the trunk. Returning to the house, I stood in the dining room and watched the clock move slowly toward midnight. I was both excited for a future away from this place and terrified that God would strike me down. When the clock reached midnight, I turned and walked away from a childhood of extreme religious indoctrination and violence.

For years, I lived in fear, certain that God was waiting for the best time to exact his revenge. Walking down the sidewalk in downtown Kansas City, I recall looking up to see if a piece of the building was falling toward me. As much as possible, I avoided thinking about it. I moved to southern California and got married. When my wife announced that she was pregnant, I was elated and terrified. I had never told her that I was certain God would never give me children. My father was clear on the message that children were a gift from God. He surely would not bestow that blessing upon me. The birth of my son changed everything. As I considered my responsibilities for that tiny life, I was forced to confront the past that haunted me. How would I raise this child? What would I teach him about this God I lived in fear of?

I entered counseling for several years. At the same time, we joined an Evangelical Free congregation, where I began my search for the kinder, gentler God of mainstream Christianity. Meanwhile, we had two more children, twins. My most fervent desire was to raise them in a healthy, happy environment where they could grow into self-realized adults.

Angry God of Calvin

As I studied the bible with a new focus, I could not reconcile its words with the messages from our pastor. Where they preached an all-loving, all-caring creator, I saw passage after passage that pointed squarely to the angry God of Calvin and Jonathan Edwards. As I began to ask questions of religious leaders both locally and nationally, I was shocked to discover that their answers were shallow and unresponsive.

When I confided in a few close friends that I had doubts, their response was unsatisfying. One day, my oldest son asked me about Jesus. I tried to describe him in the loving terms I hoped for, but he interrupted me with a question. “What about the people who don’t believe?” Bless his little atheist heart. I had no better answer than to tell him they went to hell. He began to weep and my heart burst. What was I doing? How could I expose my little children to such an idea? So, I began to pull away from Christianity. 

When the Gulf War came along, roughly the same time my family began their campaign of hate against the gay community, I was terrified that Armageddon was starting. The undefinable fear returned. Weeping at the dinner table one night, I told my wife I did not want to go to hell. But the year 2000 was rapidly approaching, and with it my eternal destruction. The new century arrived without any sign of Jesus. As the months passed, a tiny spark of hope came with it. While I continued to try and reconcile my own experiences and my doubts with the message of the bible, I was quietly entertaining doubts about the whole thing. Then 9/11 happened.

A young lady in our community who had attended school with my stepdaughter had just graduated from Boston College. She was returning home on the second plane that flew into the World Trade Center. The impact was devastating locally and nationally. Then, I noticed something that struck me as odd, even dangerous. The entire country was responding to a violent act of faith by turning to their own blind faith. For the first time I considered, in a personal way, the harm that religion was causing the world. I considered the world my children would inherit, and I was afraid all over again.

In 2005, following a painful separation, I moved to Canada. By this time, my birth family had gained international notoriety as they focused their “God Hates Fags” campaign on the funerals of soldiers who had died in the war on terrorism. For the most part, I avoided requests for interviews about my family. Then, in 2008, a young journalism student climbed into the back of my cab. As we drove to the airport, he mentioned a documentary he had recently seen on a small church in Kansas. I told him I knew about it, that it was my family. After the shock wore off, he requested an interview. The ensuing article garnered several hundred thousand views online. He called me one day and said he had contact information requests from several people who had read the article. I gave him permission to provide it. 

I had recently read Richard Dawkins’ The God Delusion and for the first time in my life I was willing to consider that I might be an atheist. That was such a horrible, terrifying word that I would not say it out loud. But this was much bigger than that. This would be, for the first time, me embracing my own ideas about God publicly. At the same time, I would be openly defiant toward my family and their campaign of hate. You see, even in all that had passed, I still hoped for a reconciliation. If I did this very public speech, if I was finally truthful to myself and the world, that hope was lost. I also knew that the hard-wired message of my rebellious, sinful, damned nature would be forced back out into the open. The words . . . the emotions that were so psychologically destructive would be laid bare. 

No answers or evidence

And what was that truth? The story of a god that I grew up with was wholly predicated on the words written in the bible. But no one could provide answers that satisfied the lifelong question I struggled with, the question, by my estimation, that is at the heart of faith: What evidence proves that the bible is the inspired, inerrant, immutable word of a divine creator? Absent adequate evidence supporting that claim, everything I had been taught was a lie.

Every effort to discover the truth of this matter was met with more and more strident, defensive challenges to my lack of faith. Challenging this claim, I came to understand that faithful ideas, by definition, are unaccountable to reality. Injecting an all-powerful, divisive, punitive entity into a belief system robs the adherents of any hope of analysis and reason. Really, what choice does a person have if they believe not believing will cause separation from all they love AND an eternity of unspeakable pain? Surely, you can argue that those who embrace it wholly are happier for that choice, but at what cost? 

At a social level, a system that judges and condemns those who act outside their moral parameters must be harmful. Any attempt at social change is stymied and corrupted by the truculence of immutable faith. We see a rich history of that with Christianity. From using scripture to justify slavery for generations, to the longstanding assault of our LGBTQ brethren, Christianity — this unsustainable assertion that an all-knowing, all-powerful lawmaker hates them — has been the spear tip of condemnation and injustice for broad swathes of our fellow humans.

Since my family began their picketing campaign in 1991, Christian America has, with one voice, condemned their message. But I would argue that Westboro Baptist Church is just giving voice to the same destructive ideology at the foundation of even the most moderate iteration of that faith. How do we sit idly by considering that reality? So, I gave my first public talk before a gathering of nonbelievers. Then, I gave more talks. I talked about the ugly truth behind the ugly, God-ordained placards of my family’s protests.

Today, I embrace the humanistic ideas that this life, this brief moment in time we share, is all we have. I see concern and love toward our fellow humans as paramount. I reject any idea that marginalizes one group over another. Today in America, as we once again face separation and division inspired by religious ideology, the words of British philosopher, Bertrand Russell come to mind. 

When asked what message he would want people to take from his example, he said: “I should like to say two things, one intellectual and one moral. The intellectual thing I should want to say to them is this: When you are studying any matter, or considering any philosophy, ask yourself only what are the facts and what is the truth those facts bear out? Never let yourself be diverted by what you wish to believe, or by what you think would have beneficent social effect if it were believed. But look only and solely at what are the facts. That is the intellectual thing that I should wish to say. The moral thing I should wish to say to them is very simple: I should say love is wise, and hatred is foolish. In this world, which is getting more and more closely interconnected, we have to learn to tolerate each other, we have to learn to put up with the fact that some people say things that we don’t like.

We can only live together in that way — and if we are to live together and not die together, we must learn a kind of charity and a kind of tolerance, which is absolutely vital to the continuation of human life on this planet.”

James A. Haught: The dubiousness of miraculous revelations

In 1995, a statue of the Virgin Mary appears to cry blood tears in Civitavecchia, Italy. About 60 people testified to witnessing the alleged phenomenon. However, the blood on the statue was later found to be male, and the owner of the statue refused to take a blood test.

This column first appeared on FFRF’s blog page at

By James A. Haught

In the mid-1800s, a prisoner in Persia (as Iran was then known) allegedly saw a vision of a “heavenly maiden” who informed him of his holy status. Later he declared that he was Baha’u’llah, the Promised One of All Religions. In effect, he said he was Jesus returning for Christians, the Messiah coming for Jews, Lord Krishna coming for Hindus, a long-awaited divine imam coming for Muslims, and so on. He drew thousands of followers, called Baha’i. Surrounding Shi’ite Muslims massacred them, but they persisted. The Persian’s brother tried to poison him and declared himself, instead, the Promised One of All Religions. But the brother’s attempt fizzled. Baha’is slowly grew to 7 million around the world today, although they remain cruelly persecuted in Iran.

Also in the mid-1800s, a Chinese man read Christian missionary tracts and said he experienced a vision in which God told him he was a divine younger brother of Jesus. God commanded him to “destroy demons.” The vision-receiver drew followers, launched the Taiping religion and a Taiping army that conquered much of China, causing an estimated 20 million deaths.

Around the same time period (a fertile era for revelations apparently), a much-arrested mystic named Joseph Smith said he was visited by an angel named Moroni who showed him golden tablets buried on a New York state hill. The angel allegedly gave him magic stones that enabled him to translate ancient writing on the tablets. It became the Book of Mormon, describing a North American civilization that was visited by Jesus. But nobody could see the golden tablets and magic stones as proof, because the angel supposedly took them back to heaven. Today, the Mormon faith numbers 15 million worldwide.

Mary Baker Eddy said she heard supernatural voices as a child, and she later became devoted to a hypnotist healer. Then she claimed that divine inspiration led her to write a faith-healing book and launch the Church of Christ Scientist in the 1870s. But critics claimed that she lifted most of her spiritual healing ideas from the hypnotist and from Eastern religions.

In 1935, according to the Unification Church, Jesus appeared to Sun Myung Moon in Korea and commanded him to finish the “incomplete” work that Christ started 2,000 years earlier. Moon began evangelizing and slowly created the “Moonie” faith that spread worldwide.

In the 1970s, a French racecar driver called Rael said he was visited by ancient extraterrestrials called the Elohim, who originally created all life on Earth. Rael wrote books and launched a religion that consists mostly of naked assemblies, casual sex, and efforts to bring the Elohim back to the planet. Estimates of the number of Raelians range from 50,000 to 90,000.

And, as everyone knows, the Prophet Muhammad claimed in the seventh century that the Angel Gabriel visited him repeatedly for 23 years, dictating the Quran. Muhammad was illiterate, but supposedly relayed the angel’s words to others and scribes, who put them on paper. This launched the Muslim faith, which now has 1.5 billion adherents.

You get the picture. Time after time throughout history, various people have claimed miraculous visits. The visionaries began preaching and spawned religions. They drew great numbers of followers — showing a remarkable human craving for miracle tales.

Alleged communication from gods and godlings goes back to the earliest known writings. Greek King Agamemnon supposedly offended the goddess Artemis, who calmed winds when the king’s army tried to sail for Troy. The goddess supposedly told the prophet Calchas that she would relent only if Agamemnon sacrificed his daughter Iphigenia, and it was done.

The bible reports many angel visitations. Genesis 6 implies that fallen angels came to Earth, impregnated women and bred giants.

The all-time champion of holy appearances is the Virgin Mary, who often makes herself visible to believers — in 1531 at Guadalupe, Mexico; in 1858 at Lourdes, France; in 1917 at Fatima, Portugal; in 1981 at Medjugorje, Bosnia; in 1983 at a farm in Georgia, to name a few. Vast multitudes of worshipers flock to these sites. It’s odd that Mary doesn’t appear to Jews, Buddhists, Protestants or atheists. As a wag said, “Some things must be believed to be seen.”

Troy Taylor, a collector of ghost tales, wrote that the Virgin made numerous appearances in Illinois. A retired railroader, praying by a crucifix at Queen of Heaven Cemetery at Hillsdale in 1990, was visited by Mary, St. Michael and three angels, he said. Swarms of believers rushed to the spot and made miracle reports of their own. At Belleville in 1993, a man said a voice told him to visit the Lady of the Snows shrine, where Mary appeared from a bright light and gave him messages. Meanwhile, various Orthodox churches around Illinois reported weeping or bleeding statues or paintings of the Virgin. And a family at Hanover Park said Mary appeared in 1997 in shadows on an apartment wall, drawing crowds of the faithful.

Taylor wrote that all these happenings may be “the fevered imaginings of a religious mind” or they may be genuine miracles — “We leave that up to you to decide.”

How many divine revelations and visitations have been claimed through the centuries? Tens of thousands? Millions? The total is uncountable. Clearly, it’s part of human experience. It’s somewhat akin to people who say they were abducted by space aliens, taken aboard UFOs and subjected to sexual experiments.

Are these vision-seers psychotics or “fantasy-prone” neurotics who really believe their tales? Or are they charlatans who invent lies, then spend the rest of their lives repeating them?

One exception to the lie-repeating premise is an American named Alex Malarkey. In 2004, when he was 6, a car crash sent him into a coma. After he woke up, he said he had gone to heaven and visited Jesus and Satan. His father helped him write a best-selling book, The Boy Who Came Back from Heaven, which sold a million copies and was made into a television movie. But at age 16, the paralyzed boy said his tale was a hoax to get attention. The publisher halted sales of his book. His name should have been a giveaway.

The widespread phenomenon of miraculous encounters should be a field of study for psychiatrists. What facet of the mind causes some people to claim that divine visitors came to them — and causes other people to believe them?

FFRF member James A. Haught was the longtime editor at the Charleston Gazette and has been the editor emeritus since 2015.

1st place: People of color essay contest — Nidhi J. Nair

Nidhi J. Nair

Freedom from Hinduism: A personal journey

FFRF awarded Nidhi $3,500.

By Nidhi J. Nair

My great-grandmother used to tell me stories from the Mahabharata and the Ramayana every night before bed. I would curl up at her feet and swat away the mosquitos that would plague us in the sweltering Indian heat. She would drink her tea and raise a wrinkled, trembling finger before enthralling me with stories of brave heroes, epic wars, beautiful heroines and wily gods.

Her stories made me feel proud to be a Hindu and an Indian. Even at a young age, I sensed the rich tapestry of culture and history that thrived in these tales, narrated through centuries by people who understood the enduring humanity of anger, passion, betrayal, lust and pride. I carried this appreciation for my religion throughout my childhood. 

However, I experienced a paradigm shift in my thinking when my parents decided to move from Mumbai to a small town in South India called Kochi. They enrolled me in an orthodox Hindu school (Chinmaya Vidyalaya School), where I faced forced indoctrination of Hindu values. After enduring weekly Bhagavad Gita classes, where we spent many exhausting hours analyzing the ancient poem and long prayer sessions that consisted of angry mass chanting, I started feeling stifled and constrained at school. 

Hinduism became more than the glorious and imaginative epic stories I heard from my grandmother. In my mind, Hinduism became the malignant force that restricted me from going to the temple when I was menstruating, and the justification for the sexist beliefs that gave my male classmates wonderful academic opportunities when I was equally talented. It became the religion that reinforced Indian patriarchy, which viewed me as the property of men, and the impetus for the pervasive caste system and mass communal violence. As I watched poor people get lynched by fanatical Hindus for selling cows and young Hindu-Muslim couples get brutally murdered for falling in love, it became clear to me that my religion was unscientific, monolithic and cruel.

In response to my views, my father always told me that Hinduism was not a static religion, and that each generation had to reinterpret its core values to suit their era. He told me stories of how Hinduism “liberated” women and how the “divine” female body was venerated. However, in my teenage years, stories of Hindu greatness no longer made a positive impact on me. I grew more and more intellectually curious and increasingly skeptical of traditional Hindu values, and whenever I thought of the religion I was born into, I could only see the hate crimes, violence and nationalism it spawned.

Slowly, I began to disaffiliate from Hinduism. My personal identity morphed to include my atheism, and I stopped labeling myself as a Hindu. I started falling in love with data science, and I inculcated a passion for reason and logic. I started seeing the value of having a scientific temper, and, as my worldview expanded, I felt released from the shackles of tribalistic religious emotion. When I moved to the United States to study economics and statistics at the University of Connecticut, I felt like a new person, unbound by any religious or ideological constraints. For the first time in my life, I felt truly free.

Today, I am grateful for my divorce from Hinduism, because it forced me to undergo a journey of self-discovery that helped me become the woman I am today — independent and strong, fearless and free.

Nidhi, 19, is an international student from India studying economics and statistics at the University of Connecticut. Nidhi conducts a weekly radio show, “Content is King,” at WHUS Radio and contributes to the Daily Campus.

2nd place (tie): People of color essay contest — Taylor Fang

Taylor Fang

Painting a future of freedom, compassion

FFRF awarded Taylor $3,000.

By Taylor Fang

Sky blue fabric, washi tape and popsicle sticks. In first grade, when I was invited by friends to attend a “craft club,” I wasn’t aware that these innocent craft supplies were actually tools for indoctrination. Growing up in a small town in Utah, which is dominated by the Mormon church, I was the constant target for conversion. Before every craft club, I sat awkwardly as the group said a prayer. After a few meetings, I was given the Book of Mormon. Slowly, I began to feel ashamed for being an “aberration” in my town: as an atheist, feminist and daughter of Chinese immigrants.

Yet, although I did not have access to many resources about independent thought, I began spending afternoons at the library. Reading gave me companionship. More importantly, literature taught me to evaluate objective evidence, to think for myself, and to think critically. I began recognizing the hypocrisy of a church which claimed to welcome all, yet which denied women status outside of the family and portrayed homosexuality as sinful. I realized that following one’s own moral conscience and beliefs, rather than dogma and tradition, is the path to ultimate freedom of conscience.

I can especially recall a moment of enlightenment while reading Margaret Atwood’s The Handmaid’s Tale. Atwood depicts a theocratic society where priests use religion for social control. Faith is weaponized to justify the subjugation of certain groups. “Nothing changes instantaneously: In a gradually heating bathtub you’d be boiled to death before you knew it,” writes Atwood. In Atwood’s words, I recognized the danger of a society based on religious fanaticism. I had been slowly proselytized into believing the only way I could fit in was through conversion. When I refused, I was excluded from friend groups, discussions, social events and gatherings. Yet, The Handmaid’s Tale illuminated to me that struggling against the grain is necessary to escape this religious-based manipulation.

I’ve begun realizing that I can employ science and logic to answer questions about the world, rather than using religion as a veil to cloud reality and truth. I can apply my time and energy to raising awareness of important social issues, rather than looking toward a church leader’s dogma on LGBTQ+ rights and abortion. And I can strive to support marginalized groups through service.

Throughout the past three years, I’ve especially worked to help educate females in my community. Education is the path to greater understanding. After learning that Utah is last in the entire nation for women in STEM, I started teaching my own seven-week afterschool coding program for middle-school girls. Since 2017, I’ve directly impacted 150 Utah girls and dedicated over 200 hours to this project. My goal is to teach my students to think critically and independently, and to encourage them to step outside the Mormon gender role where “a woman’s place is in the family.”

A world where church and state are separate is a more equal world — one where ignorance has no place and empathy can build true community. Rather than seeing faith weaponized to justify conservative values, I hope to continue speaking up and advocating for free thought. I’m grateful to have strong role models in this journey. My parents were not fluent in English when they came to United States, and they felt further isolated for being non-Mormon. Yet still, they persevered. Their story inspires me to continue pursuing my ambitions as a woman of color. I envision a more compassionate world where minorities are respected for their identities, and where all individuals, no matter their background, have the freedom to think for themselves.

Taylor, 17, is a freshman at Harvard University. She is a nationally recognized poet and has been published in the New York Times and the Pulitzer Center. Taylor is also the founder of Girls Explore Tech (GET), a seven-week series of coding workshops for local Utah middle-school girls.

2nd place (tie): People of color essay contest — Gianna White

Gianna White

The choice of worship not limited to religion

FFRF awarded Gianna $3,000.

By Gianna White

In his speech, “This is Water,” David Foster Wallace claims “there is actually no such thing as atheism. There is no such thing as not worshipping. Everybody worships. The only choice we get is what to worship.” I think about this quote frequently because it has since left me with the question of what I worship.

The African slave trade was the beginning of what would turn into a long history of dispossession and displacement for my people. In a twist of fate, my ancestors were forced to worship the Christian God by the very people they needed saving from. Like many colonized groups around the world, my ancestors were robbed of their gods and to this day the majority of Black Americans subscribe to the Abrahamic religions forced on them across generations.

My ancestors were continuously robbed of autonomy. They were never given a choice of what to worship. It is because of this I am extremely grateful for the freedom of choice, and in part why I am not religious. I do not reject religion simply because it was forced on my ancestors. It is because it was forced on them that I have taken the time to analyze my own thoughts toward spirituality and reach my own conclusions. This process has made me analyze and critique established systems and power structures in my life. It has enabled me to search for what I worship

I have tried to be a Christian and I have looked to other religions to try to discover spiritual worship. I could not rationalize any religion I came across. I found contradictions everywhere.

Religion is not immune from hatred, it is not immune from sexism, it is not immune from power imbalances — in fact, it thrives on them. And this is not because religion is inherently hierarchical, it is because religion is a reflection humanity has made of itself and humanity is deeply flawed. I once read the reason why the Catholic Church has yet to stomp out its pedophilia problem is that the church provides the perfect cover for abusers. The Catholic Church is a space where maleness + authority = untouchable. I have yet to find a religion where this equation is not true — a religion where women are not seen as subservient either in holy text or by its practitioners. 

Where then am I left as a Black woman? Where do I belong? Is there a space that will accept me, treat me as an equal? Where I am free to ask questions?

In my family, being nonreligious is generally met with disapproval and subtle attempts to convert me — the casual text message inviting me to a bible service or reminder that God loves me even if I am astray. I love my family, and I am not upset with them or their actions because I know they are acting out of love. However, I think that they and secular communities at large could learn to respect and acknowledge our differences. Do not ignore my culture, my gender, my individual identities because they do not matter to a God or higher power. They matter to me and they affect how the world sees me and in turn how I see the world. Acknowledge differences, but do not let them cause alienation.

Know that I, too, worship. I do not worship in a spiritual sense, instead, I worship freedom. I worship love, togetherness, perseverance, empathy. I worship the best aspects of humanity, the same principles that govern most religions. All I ask is that others respect my choice of worship. 

Gianna, 20, is a junior at New York University, majoring in sustainable urban environments. Gianna is an organizer for March for Science NYC and volunteers with environmental and social justice groups, including Sunrise Movement, Earth Day Initiative, Black Lives Matter, March for Our Lives.

3rd place (tie): People of color essay contest — Stephanie Black

Deep trenches: Finding the path to humanity

FFRF awarded Stephanie $2,500.

By Stephanie Black

Stephanie Black

Fear. The word is very familiar to me as I have lived most of my life growing up living in fear. The familiar feeling of my heartbeat speeding up, of the sweat coating my forehead and my hands, the anxiety creeping up my spine. I felt like I did not have a voice, I did not have a mind, and I did not have freedom. I felt fear that I was constantly being disobedient, that I was not being the perfect child of God. I feared judgment, I feared ridicule, I feared not getting into heaven by making even the slightest mistake. “God looks high and looks low.” People would tell me that every chance they got and the fear would build up in me.

Caged. Growing up in a Christian family, I had to attend bible study on Wednesdays, Sunday school on Sunday, church service on Sunday, and church school during the summer. That, however, was not exactly the worst part. I was caged within the cycle of physical, emotional and verbal abuse. I felt that the abuse I endured was a punishment for disobeying God whenever I did something that went against the 10 Commandments or went against the word of God preached during the church sermons. I felt that my imperfections were condemned. I blamed myself for not being able to follow after God’s example. But, there were times when I had not done anything wrong and was still a victim of the cycle of abuse. And, so, I wonder why God did not protect me since he protected all of his children. I was a caged prisoner, and, as I reached out past the bars, all that was there for me was the back that God turned on me.

Starvation. I began to question my beliefs as, continuously, people would tell me to pray about the abuse I was experiencing, even when praying did not do anything for me. I began to experience emotional starvation as my challenge of religious beliefs broke bonds that I held dear to me. Romantic relationships crumbled, friendships collapsed and family bonds decayed. One of my closest friends withdrew from our friendship because I questioned the persecution and discrimination of groups of people by the hands of God. My friend believed that if God said so and if it is within the will of God, it is OK for people to be discriminated against. It broke me that I could not keep the friendship because of the fact that I refused to abide by hatred. I was frustrated with the fact that I was starving and was not able to consume the emotional connections I desperately desired because I rejected religion.

Freedom. Mahatma Gandhi once asserted, “Freedom is not worth having if it does not include the freedom to make mistakes.” Breaking away from religion has granted me the understanding of what it means to be human. I am no longer standing yards away from freedom, forever reaching for it but barely catching it. I am no longer suffocating from the pressure of being the perfect individual. I am no longer succumbing to the exclusion of groups of people. I am no longer making excuses for receiving harsh treatment. I  am no longer living in fear, I am no longer caged and I am no longer starving. I know now that it is more than OK to have a mind of my own, to speak up about dark situations, and to make mistakes as I am thinking through my steps in life. I regained pieces of my humanity.

Stephanie, 19, attends Rensselaer Polytechnic Institute, majoring in physics and math. Stephanie’s goal is to earn a Ph.D. in plasma astrophysics. “I am a social media Black activist in which I use my Instagram account to promote Black-owned businesses, Black art, Black authors/poets and Black musicians,” Stephanie writes. “I also use my social media platform to educate my follows on Black history and Black modern-day issues.”

3rd place (tie): People of color essay contest — Justine Vega

Justine Vega

Against la cultura: Why I am not religious

By Justine Vega

My relationship with religion began at an early age, as Latin culture is deeply intertwined with Christianity and my upbringing reflected that. My mother enrolled me into a Christian school, where I spent my days reading the bible and attending church. However, I never became religious due to my father, an adamant nonbeliever, who took the time to educate me on the history of Latin America. He would tell me folktales, teaching me about the Spanish conquistadors who came and forcibly converted indigenous peoples, slaughtering those who refused. The most memorable story passed down to me was of the last Inca emperor, Atahualpa.

The story goes that a Spanish priest had shown Atahualpa a bible, proclaiming the book to be God. Confused, he smacked the book to the ground and, because of this, lost his life to the Spanish, the entire empire falling with him. This history of violence and genocide contributed to my uneasy relationship with religion, which seemed to be a political tool rather than a spiritual outlet. 

Understanding the role religion played, specifically Christianity, in the oppression of nonbelievers in Latin America and around the world created a deep skepticism inside of me. I could never fully immerse myself in religious practices, such as going to church or praying. This created tension in my life since I was raised in the Hispanic community. Latin culture is heavily influenced by Christian ideas, especially in regard to gender roles. Although the path toward gender equality continues, there still exists a clear distinction between the expectations for men and those for women. Since I never fully believed in the Christian ideals of womanhood, I often felt trapped in a world that did not fit me.

I did not adhere to traditional femininity — I was not quiet or interested in taking care of children or the home. I was a tomboy who liked to play sports and help my dad work in construction, loud and opinionated.

As I matured, this discomfort only grew and, as I furthered my education by reading different philosophies of religion, I realized it was OK for me not to aspire to Christian expectations of women. Separating myself from religion allowed me to sharpen my critical mind, made me curious to find answers to my questions outside of a religious framework. This curiosity for knowledge propelled my interest in studying, and I eventually graduated high school early because of it. 

Although I was fortunate enough to be exposed to different teachings, many of the kids I grew up with never received those opportunities. The best way to combat ignorance is through education, and as someone who went to public school, I experienced firsthand the lack of resources and funding, especially in working-class areas. Children of color often reside in these poorer neighborhoods, attending schools that lack funding for new books and better class offerings. If we want minority communities to be exposed to different viewpoints, funding public education and programs for at-risk communities is the first step.

As our nation faces a turning point, those in the secular community who wish to see change can help by championing both primary and secondary education for people of color. Access to a high-quality education that challenges its students to think critically will allow them the choice to consider a more secular perspective. An educated mind is a free one and by funding education we can pave the way to a progressive future.

Justine, 19, is a first-generation American attending New York University, majoring in political science. As a first-year student, Justine studied in Paris and wrote a research paper on French secularism and its relationship to minority communities in France.

4th place (tie): People of color essay contest — Leila Okorie

Leila Okorie

My life is at peace because of atheism

FFRF awarded Leila $2,000.

By Leila Okorie

My questioning of religion started at a fairly young age. Being half Nigerian and having grandparents who slipped God into every other sentence, I grew up pretty Christian. I rarely went to church as a kid, and the few memories I have of going consist of me falling asleep, being bored out of my mind, and wondering why they were calling grape juice Jesus’ blood and a cracker his flesh.

I just never quite felt like I belonged in churches, or like there were any real spiritual forces at play within them, and my experience has yet to change.

I slowly went from praying on my knees every night before bed, to praying in bed every other night, to simply praying in my mind every once in a while. As this went on, I began to notice that I only prayed when I was afraid or I wanted something. What’s more, I never received what I asked for, and I never got any replies back. Not only did this make me realize I was being selfish with my prayers, but it made me feel silly for spending time talking to something that has never once responded to me.

In fourth grade, I was at recess and I asked my friend, “If God created Jesus, then who created God?” I will never forget the distress and shock in her face before she said she didn’t want to talk about that. Not too long after, she no longer wanted to be friends with me.

The older I got, the more I began to distance myself from religion. I learned about how many wars and massacres had happened in history, and still continue to happen, over religion. I learned about how people used, and still use, religion to justify discrimination against different races, sexual orientations and genders. Middle school was also when I learned that I was not straight, and, a few years later, one of my best friends came out to me as transgender. I had people I knew and loved that were in the LGBTQ+ community, including myself, who I knew were good people, and yet they supposedly deserved to burn in hell.

Discovering myself and my identity only raised more questions. If there is a God, why does he create people that automatically deserve to go to hell? Why do people who question a being that provides no scientific proof of its existence deserve to go to hell? I also hated seeing people using religion as an excuse to turn a blind eye to real life concerns, such as not vaccinating their children, or saying they’re “sending prayers” during times of crisis or saying that “everything happens for a reason.”

By ninth grade, I decided that being an atheist was best for me and my mental health. I was tired of feeling like I was being watched and judged for every decision I made, and tired of apologizing for my identity.

I hold no disdain for religious people, and I believe everyone should choose the lifestyle that makes them happiest. But, being an atheist allows me to live my life with the mindset that every day matters because this is the only life we have. Death no longer holds the same weight because I’m not afraid of going to hell for being a “bad” person. It has also helped me feel more in control of my life and keeps me more accountable, because I know a prayer of forgiveness won’t erase the consequences of my actions. For me, atheism is to live peacefully.

Leila, 19, is a senior at the University of Washington, and is on track to earn a bachelor’s degree in art. “Being an African-American woman who is also a part of the LGBTQ+ community, I strive to be an example that you can excel in your passions.” Leila writes. “I want to become a concept artist for video games and film so I can help bring more diverse characters to media.”

4th place (tie): People of color essay contest — Nickaela Steele

Nickaela Steele

I am my own refuge

FFRF awarded Nickaela $2,000.

By Nickaela Steele

A stained-glass door opens and I am hastily ushered down the altar. All the church ladies stare back as if to say, “You’re late! How dare you!” The silence of their stares is more deafening than crashing drums. Amid what my 5-year-old mind perceived as chaos was a tall man in a long robe overpoweringly repeating the phrase, “Lord, you are my refuge.” Over and over he repeated the phrase, as if it were glazed in honey as it fell from his lips and he wanted to savor every letter.

I often replay this memory in my mind and also remember the faces of the people next to me as their minds, with relief, accepted this idea as truth. But I never truly knew what he meant by this, until, one day, I thought about the people behind the phrase. I thought about the pastor who is from a small village in Jamaica and the many people standing in the congregation who come from similar places, where their religion was all they had. This was the only way they knew how to cope with the everyday lows.

I often thought, “If only these people knew they were their own refuge.” It was an “aha” moment for me when I realized that this is true for many Black people across the world. When it feels the world is against them, Black people rely upon their God to release the hurt and grant them back their humanity, which has been battered so frequently.

For Black people, religion is woven into our identities and we are made to believe that everything we need is outside of ourselves. Looking for forgiveness? Get it from God. Looking for love? Ask God.

But what happens when our desires are not delivered to us by God? Must we simply give up on ourselves? I could not help but wonder: What if we were just to simply ask for these things from ourselves? To love ourselves and humankind unconditionally and to forgive others while we learn to forgive ourselves?

So, I put it to the test. I put down the bible and gave myself all the love and support I was taught to give to God. Instead of looking outward for refuge when I felt emotionally low or mentally weak, I looked inside myself and worked actively to find these answers. And, to no surprise, I have seen a positive shift in my emotional and mental health due to actually working through these feelings and understanding them instead of suppressing them and looking to God to make them stop. This has created a blissful awareness of myself and others: Now I can fix my own problems, I can take my own responsibility for my own emotions, I can be my own refuge.

Even regarding the recent tragic outcry caused by deaths in the Black community, my first thought is, “What can I do to help my people?” and I work actively to be the change I want to see.

In order for the secular community to become more inclusive to people of color, it is imperative that the impact religion has had on us be understood through a historic and humane lens. It must also be understood that because of our background our perspective of how we maneuver our secular identity may differ from our white counterparts, and, most importantly, we should affirm together we can thrive without religion: We are our own refuge.

Nickaela, 18, attends Howard University and is interested in screenwriting and acting.