On February 24, Fort Lauderdale’s Sun-Sentinel yielded to pressure from the Catholic League by issuing an apology and a pledge not to run any more anti-Catholic ads. The League raised objections on February 23 regarding the February 9 publication of a four-page ad that had been paid for by a Seventh Day Adventist splinter group. It was one of the fastest victories in the League’s history.

The ad accused the Catholic Church of seeking to create a New World Order and portrayed the Pope as a satanic force. The apocalyptic ad was replete with statements regarding “Earth’s Final Warning,” blaming the Catholic Church for ushering in the “Days of Darkness” and “Days of Peril.” It tried to convey the preposterous message that Pope John Paul II and President Clinton were conspiring together to take command of the world.

By the time the Catholic League was informed of this incident, some of our members in the area, along with others, had already registered their complaints with the newspaper. But not even the Diocese of Palm Beach was able to bring the paper to its senses. Accordingly, the Catholic League contacted the radio and television stations in the area, the opposition newspaper, and the nation’s major media outlets registering its outrage and its demands. We demanded nothing less than “an apology to Catholics and a pledge that no such ads will ever be accepted again.” We added that “If this is not forthcoming, the Catholic League will launch a public ad campaign of its own, one that will directly target the Sun-Sentinel.“

The news release also questioned whether the vice-president and director of marketing, Jim Smith, would have acceded to other groups that wanted to promote bigotry. We asked if the newspaper would publish ads submitted by the Ku Klux Klan or the American Nazi Party.

The Catholic League is pleased with the response of the Sun-Sentinel and is not interested in conducting a public ad campaign against the newspaper. But while this issue has been closed, the larger issue of anti-Catholic bigotry in South Florida is not. That is why we will be starting a chapter in the area.

The Catholic League’s 1994 Report on Anti-Catholicism has just been published. It is the first time that the League has issued what it expects will be an annual publication.

The need for such a report is clear to all Catholic League members, even if it is not so clear to others. Listed in the report are approximately 200 of the most egregious incidents of Catholic-bashing that occurred in 1994. In addition to republishing several of the most offensive cartoons that were published last year, there are seven categories where offenses have been noted: activist organizations; the arts; commercial establishments; education; government; media; and the workplace.

The report does not purport to be an exhaustive study of the degree of anti-Catholicism that occurred in 1994. But it is an important barometer of what is happening nationwide. The purpose of the report is to educate the public and influence decision-makers in government, education and the media.

The Catholic League is disturbed by the extent to which the nation’s elites seem to show unending tolerance for some segments of society while forgoing such tolerance when the subject is the Catholic Church. While we want to resist the fashionable exercise of claiming victim status, we also want to be accorded the same degree of respect for our heritage that is presently given to others. It is our hope that this report will help to accomplish that goal.

The report is being distributed to all members of Congress, the White House, the Equal Opportunity Commission, the U.S. Civil Rights Commission and to prominent members in the fields of the media and education.

I have never met, nor am I likely to meet, Frank Hauck, Catherine D. Grantz, Richard A. Schaefer, John S. Herron, Phil Brennan or Arthur J. Nicholson. Nor am I likely to meet Edward H. Maloney, Father Michael T. Driscoll, Sister Carol Stovall or Father Charles E. Hawkins. But I wish I could.

All of them played a key role in bringing about the victory we had against the Sun-Sentinel. It was those in the first cluster of names (our own Catholic League members!) who initially contacted us about the incident, and it was those in the second cluster who played a role in following through on the matter. Many thanks to all of them.

The way I first found out about the Sun-Sentinel incident is worth sharing with you. I was being grilled by William Macklin, a tough and very bright reporter for the Philadelphia Inquirer, when the mail was dropped off on my desk. I took a quick look at the anti-Catholic ad in the newspaper and immediately recognized the type-face and scurrilous content, pointing out to Mr. Macklin that this was an example of something we would ignore. We would ignore it, I said, because this kind of crazy anti-Catholic stuff is published with regularity by a fringe group, and to our knowledge it has not appeared in any mainstream publication.

But then Macklin took a closer look at it and saw that it was published in the Sun-Sentinel. Having brought this to my attention, I said that that changed everything. We had to do something about it right away.

Why the fast change of heart? Because I think it is a gross mistake to give elevation to fiinge groups. Our basic rule of thumb is this: the more mainstream the source of anti-Catholicism, the more likely it is that the Catholic League will respond. We do not want to play into the hands of crackpot bigots who appear on public access television or who publish wacko newspapers and the like. We keep a file on them, to be sure, but we are not interested in giving them media attention.

But when an establishment newspaper such as the Sun-Sentinel offends, it cannot be ignored. The mainstream media, after all, have the credibility and influence that the fringe lacks, and they are therefore much more likely to do real damage. When bigotry ascends to that level, it demands a response from the civil rights organizations established to combat it.

In our news release on the subject, we pledged to conduct a public ad campaign of our own if the Sun-Sentinel did not extend an apology and promise not to publish such ads again. What exactly did we have in mind? We were prepared to take out ads in the opposition newspaper, registering our charge of anti-Catholic bigotry. We were prepared to pay for radio spots making our charge.

We were prepared to buy billboard space along the major arteries surrounding the Fort Lauderdale community. Why not? After all, it is directly due to the generosity of our members-the ranks of which continue to boom-that we are in a position to make such threats. And if I know our members, I know that they want a sharp response, one that will get results. So we deliver.

The press and the radio talk shows asked me if the Catholic League was engaging in censorship by responding the way we did. As always, I informed them that only the government has the power to censor anything. All I can do is register my outrage by exercising my First Amendment right to freedom of speech.

This is the way it works: if the source of bigotry wants to deal with lousy publicity, it can elect to do so. Or it can come to its senses and knock it off. In the event the anti-Catholic bigots want to bite the bullet and stay the course, we’ll do everything we can within the law to make sure that they pay a very high price for doing so. That’s our right, and we have every intention of using it. Again and again.

By Robert H. Bork

The text of the First Amendment is quite simple: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press, or the right of the people peaceably to assemble, and to petition the government for a redress of grievances.” These are not words that would lead the uninitiated to suspect that the law, both with regard to religion and with regard to speech, could be what the Supreme Court has made of it in the past few decades.

Where religion is concerned, for example, a state may lend parochial schoolchildren geography textbooks that contain maps of the United States but may not lend them maps of the United States for use in geography class; a state may lend parochial schoolchildren textbooks on American colonial history but not a film about George Washington; a state may pay for diagnostic services conducted in a parochial school but therapeutic services must be provided in a different building.

The First Amendment’s establishment clause – “Congress shall make no law respecting an establishment of religion” – clearly precludes recognition of an official church, and it can easily be read to prevent discriminatory aid to one or a few religions. But it hardly requires the conclusion that government may not assist religion in general or sponsor religious symbolism. An established religion is one which the state recognizes as the official religion and which it organizes by law. Typically, citizens are required to support the established church by taxation. The Congress that proposed and the states that ratified the First Amendment knew very well what an establishment of religion was, since six states had various forms of establishment at the time; ironically, one reason for the prohibition was to save these state establishments from federal interference.

The history of the formulation of the clause by Congress demonstrates that it was not intended to ban government recognition of and assistance to religion; nor was it understood to require government neutrality between religion and irreligion.

And as we shall see, it most certainly was not intended to erase religious references and symbolism from the actions and statements of government officials.

Had the establishment clause been read as its language and history show it should have been, the place of religion in American life would be very different from what it now is. But in modern times, the Supreme Court has developed a severe aversion to connections between government and religion. Nowhere is that more evident than in the Court’s alteration of its fixed rules to allow such connections to be challenged far more easily than other claimed violations of the Constitution.

Major philosophical shifts in the law can occur through what may seem to laymen mere tinkerings with technical doctrine. Thus, the judiciary’s power to marginalize religion in public life was vastly increased through a change in the law of what lawyers call “standing.” Orthodox standing doctrine withholds the power to sue from persons alleging an interest in an issue only in their capacities as citizens or taxpayers. An individualized personal interest, some direct impact upon the plaintiff, such as the loss of money or liberty, is required. But in 1968, in Flast v. Cohen, the Supreme Court created the rule that taxpayers could sue under the establishment clause to enjoin federal expenditures to aid religious schools.

Though the opinion offered a strained explanation that would fit some suits under other parts of the Constitution, the Court has managed to avoid allowing such suits with still more strained rationales. Every single provision of the Constitution from Article I, Section 1 to the 37th Amendment is immune from taxpayer or citizen enforcement – except one. Only under the establishment clause is an ideological interest in expunging religion sufficient to confer standing.

The unhistorical severity of establishment-clause law was codified in the Supreme Court’s opinion in Lemon v. Kurtzman (1971). To pass muster, the Court held, a law must satisfy three criteria: (1) the statute or practice must have a secular legislative purpose; (2) its principal or primary effect must be one that neither advances nor inhibits religion; and (3) it must not foster an excessive government entanglement with religion.

So few statutes or governmental practices that brush anywhere near religion can pass all of those tests that, were they uniformly applied, they would erase all traces of religion in governmental affairs. But there are too many entrenched traditions around for Lemon to be applied consistently. While a case challenging the use of a paid chaplain in Nebraska’s legislature was pending in the Supreme Court, the appeals court on which I then sat gathered to hear a challenge by atheists to the practice of paying the chaplains who serve Congress. We and counsel stood while a court officer intoned, “God save the United States and this honorable court,” an inauspicious beginning for the plaintiffs since the ritual, followed in the Supreme Court as well, would appear to violate all three prongs of Lemon.

Our case was later rendered moot because the Supreme Court approved the Nebraska legislature’s chaplain in Marsh v. Chambers (1983). Justice William Brennan, dissenting, argued that the state’s practice could not pass the Lemon test since it hardly had a secular purpose, and the process of choosing a “suitable” chaplain who would offer “suitable” prayers involved governmental supervision and hence “entanglement” with religion. The Court majority, however, relied on the fact that employing chaplains to open legislative sessions conformed to historic precedent: not only did the Continental Congress employ a chaplain but so did both houses of the first Congress under the Constitution which also proposed the First Amendment. In fact, they also provided paid chaplains for the Army and Navy.

Presumably for that reason, Chief Justice Burger, who had written Lemon, did not apply it in Marsh. And quite right he was. The Court often enough pays little attention to the historic meaning of the provisions of the Constitution, but it would be egregious to hold that those who sent the amendment to the states for ratification intended to prohibit what they had just done themselves.

But if the Lemon test should be ignored where there exists historical evidence of the validity of specific practices or laws that could not otherwise pass muster, then it is a fair conclusion that the test itself contradicts the original understanding of the establishment clause and is destroying laws and practices that were not meant to be invalidated.

As matters stand, Lemon makes it difficult for government to give even the most harmless or beneficial forms of assistance to religious institutions. New York City, for example, implemented a program, subsidized with federal funds, under which public-school teachers could volunteer to teach in private schools, including religious schools. The program offered instruction to educationally deprived children in remedial reading, mathematics, and English as a second language. The teachers were accountable only to the public-school system, used teaching materials selected and screened for religious content by city employees, and taught in rooms free of religious symbols. The teachers were generally not members of the religious faith espoused by the schools to which they were assigned. There was no evidence that any teacher complained of interference by private school officials or sought to teach or promote religion.

The court of appeals said this was “a program that apparently has done so much good and little, if any, detectable harm.” Nevertheless, constrained by Lemon, that same court held the program an impermissible entanglement because the city, in order to be certain that the teachers did not inculcate religion, had to engage in some form of continuing surveillance. The Supreme Court, in Aguilar v. Felton (1985), affirmed on the same ground. The educationally deprived children were then required to leave the school premises and receive remedial instruction in trailers.

The Supreme Court has found the “establishment of religion” in the most innocuous practices. A lower court held that it was unconstitutional for a high school football team to pray before a game that nobody be injured. Another court held that a Baltimore ordinance forbidding the sale of non-kosher foods as kosher amounted to the establishment of religion. A federal court decided that a school princi- pal was required by the establishment clause to prevent a teacher from reading the Bible silently for his own purposes during a silent reading period because students, who were not shown to know what the teacher was reading, might, if they found out, be influenced by his choice of reading material.

The list of such decisions is almost endless, and very few receive Supreme Court review, not that that would be likely to change things. After all, the Supreme Court itself decided in Stone v. Graham (1980) that a public school could not display the Ten Commandments. (The school authorities were so intimidated by the current atmosphere that they attached a plaque stating that the display was intended to show our cultural heritage and not to make a religious statement; no matter, it had to come down. It also did not matter that the courtroom in which the case was heard was decorated with a painting of Moses and the Ten Commandments.)

So, too, in Lee v. Weisman, decided in 1992, a five-Justice majority held that a short, bland nonsectarian prayer at a public-school commencement amounted to an establishment of religion. The majority saw government interference with religion in the fact that the school principal asked a rabbi to offer a nonsectarian prayer. Government coercion of Deborah Weisman was detected in the possibility that she might feel “peer pressure” to stand or to maintain respectful silence during the prayer. (She would, of course, have had no case had the speaker advocated Communism or genocide.) Thus was ended a longstanding tradition of prayer at school-graduation ceremonies. The law became a parody of itself in Lynch v. Donnelly, a 1984 decision concerning Pawtucket, Rhode Island’s inclusion of a creche in its annual Christmas display. The Court held that the display passed muster, but only because along with the creche, it also included such secular features as a Santa Claus house, reindeer pulling Santa’s sleigh, candy-striped poles, a Christmas tree, carolers, cut-out figures repre- senting such characters as a clown, an elephant, and a teddy bear, hundreds of colored lights, and a large banner that reads ‘SEASON’S GREETINGS.’ The display of a menorah on a public building has been subjected to a similar analysis. In other words, the question to be litigated nowadays is whether there is a sufficient number of secular symbols surrounding a religious symbol to drain the latter of its meamng.

Despite all this, governments regularly and inevitably take actions that do not have a secular purpose, whose principal effect is to advance religion, and which entangle them with religion.

Aside from the examples already given, there are property-tax exemptions for places of worship, which do not have a secular purpose and do advance religion. Government, in the form of boards, courts, and legislatures, determines what qualifies as religion in order to award draft exemptions for conscientious objectors, aid to schools, and the like. In order to see that education is properly conducted, states must inspect and demand certain levels of performance in religious schools. Federal employees receive paid time off for Christmas, and the National Gallery preserves and displays religious paintings.

In short, our actual practices cannot be made consistent with the complete separation of religion and government.

The tendencies of the Supreme Court’s unhistorical applications of the First Amendment are fairly clear. The late social critic Christopher Lasch asked what accounted for our “wholesale defection from standards of personal conduct – civility, industry, self-restraint – that were once considered indispensable to democracy.” He concluded that though there were a great number of influences, “the gradual decay of religion would stand somewhere near the head of the list.”

Despite widespread religious belief, public life is thoroughly secularized. The separation of church and state, nowadays interpreted as prohibiting any public recognition of religion at all, is more deeply entrenched in America than anywhere else. Religion has been relegated to the sidelines of public debate.

As religious speech is circumscribed in the name of the First Amendment, however, the Court – in the name of that same amendment – strikes down laws by which communities attempt to require some civility, some decency in public expression. The Ten Commandments are banned from the schoolroom, but pornographic videos are permitted. Or, as someone has quipped about the notorious sculpture by Andres Serrano, a crucifix may not be exhibited – unless it is dipped in urine, in which case it will be awarded a grant by the National Endowment for the Arts.

The result of all this is an increasingly vulgar and offensive moral and aesthetic environment, and, surely, since what is sayable is doable, an increasingly less moral, less happy, and more dangerous society.

The Supreme Court should therefore revisit and revise its First Amendment jurisprudence to conform to the original understanding of those who framed and enacted it. Religious speech and symbolism should be permissible on public property. Nondiscriminatory assistance to religious institutions should not be questioned. Communities, if they so desire, should be permitted to prefer religion to irreligion.

There is no justification whatever for placing handicaps on religion that the establishment clause does not authorize.

The Catholic League is proud to announce that Michael Schwartz has assumed the duties as the Catholic League’s Washington Bureau Chief. No stranger to the Catholic League, Mike worked for the League in the 1980s, and has remained active in a variety of Catholic causes ever since. His office is located in the National Press Building, in close proximity to the White House. Mike is an accomplished author and media personality, and though the position is not a full-time one, it will provide the League with an important presence in the nation’s Capitol.

The March edition of Catalyst featured an anti-Catholic cartoon that appeared in the student newspaper of the University of Michigan, the Michigan Daily. Dr. Donohue registered a complaint with the president of the university, Dr. James J. Duderstadt, and sent a copy of the letter to the school newspaper. We are happy to report that an apology from the cartoonist and a conciliatory letter from Dr. Duderstadt have brought this issue to a close .

In his letter to Dr. Donohue, Dr. Duderstadt said that “The University is committed to a policy of non-discrimination and this policy includes religion.” Indeed, he stressed that “Last November, in an effort to promote greater awareness of our religious and ethical responsibilities, the University sponsored a successful conference on the Role of Religion and Ethics in Transforming the University.”

However, the conference obviously did not succeed in dissuading the cartoonist from offending Catholics, nor did it succeed in convincing the editors of the Michigan Daily from accepting the cartoon. Nonetheless, the Catholic League accepts the cartoonist’s apology and is grateful for the letter from Dr. Duderstadt.

On December 25, 1992, clerks Kathleen Pielech and Patricia Reed refused to show up for their jobs at a Massachusetts racetrack and were fired. The women filed suit against Massasoit Greyhound, the owners of Raynham-Paunton Greyhound Park, where they had been employed. The Judge in the lower court ruled in June, 1994, that the Catholic religion did not require the plaintiffs to abstain from work on Christmas Day. The plaintiffs appealed their loss in the lower court to the Supreme Judicial Court of Massachusetts, which accepted the case in December. A ruling is expected this spring.

The League released the following statement concerning the case:

“At the invitation of Kathleen Pielech, the Catholic League welcomes the opportunity to file an amicus brief on her behalf, and in support of Patricia Reed, as well. At stake is whether Americans can practice their religion with-out penalty from the state. So elementary is this right that organizations like the ACLU and the ADL have joined with the League in backing the plaintiffs. Freedom of religion means nothing if those who worship are penalized for practicing the tenets of their faith.

“It was decided in 1963 by the Supreme Court, in Sherbert v. Verner, that the government may not refuse unemployment compensation to a person unwilling to work on Saturday, the Sabbath of her faith. Thirty years later, in the 1993 Religious Freedom Restoration Act, it was decided that the state must demonstrate a compelling government interest before it can substantially burden the exercise of religious beliefs. Given this legacy, it behooves the Supreme Judicial Court to recognize that Catholics should be allowed the right to abstain from work on what is surely one of the most pivotal days of the year for Christians of any denomination. The ritual observance of holy days by attending services and seeking time away from work for quiet and prayerful reflection has been a respected mode of honoring the deity. We hope that the Supreme Judicial Court will sustain that tradition by overturning the ruling of the Superior Court.”

Clearly, the fact that the League has joined the ACLU and the ADL in filing a brief in support of Pielech is an indication of the threat to a fundamental First Amendment right to religious liberty and the broad implications the ruling will have for all religions.

The Episcopal church of St. Mark’s in New York’s East Village has long had a reputation as a center for the alternative culture. On February 13, however, it moved from alternative to degrading when it provided a forum for an offensive, bigoted and anti-Catholic “poetry” reading.

The main features were readings from “The Pope is a Pedophile,” an explicitly anti-Catholic work popular with some members of the gay community and another selection entitled “Icon Casserole.” The author and presenter, Kevin O’Neill, released a press statement announcing his reading and took that opportunity as well to air his slanted and bigoted views: the release contained scurrilous statements such as “Given the Catholic Churchs [sic] proclivity for the sexual exploitation of docile, defenseless children, especially young boys… ” and “The nefarious papist doctrine involving the surreptitious sexual subjugation of innocent youth by ranks of catholic [sic] clergy…” Errors of fact were also evident in the news release.

In a press release issued by the Catholic League on February 16, William Donohue, President of the Catholic League, gave the following statement:

“I have never heard of Kevin O’Neill, but I have heard of St. Mark’s Church. It is absolutely astounding that any church would give a platform to those who seek to malign the leaders of any religion. If a Catholic Church allowed its facilities to be used by those who sought to bash the Episcopal Church, we would never hear the end of it.

“Unfortunately, this is not the first time that an Episcopal church has been used to attack Catholicism. On June 25, 1994, a renegade Catholic gay group, Dignity, held a ‘mass’ at St. Bartholomew’s Church in midtown Manhattan, using the occasion to mock the Catholic Church.

“I have no doubt that the large majority of the faithful of every religious community, including Episcopalians, do not sanction bigotry against another religion. But it is a pity nonetheless that some simply don’t care whom they offend and where they ventilate their offenses.”

The Catholic League has registered its protest with the rector of St. Mark’s and the Episcopal bishop of New York City. It is our sincere hope that the Episcopal church, and St. Mark’s in particular, will be more careful in the future for what purposes they allow their facilities to be used.

On February 19 and 20, the Arts and Entertainment Network (A&E) broadcast “The Boys of St. Vincent,” a Canadian film about priestly pedophilia in a Catholic orphanage in Newfoundland. A&E was the only network which chose to air this chilling indictment of the Catholic clergy. On February 8, the League sent a letter to Brooke Bailey Johnson, the Vice President of Programming and Production, with whom it has corresponded in the past.

It is revealing that, despite the fact that the film was funded in part by the National Film Board of Canada, the Canadian courts initially held up the showing of “The Boys of St. Vincent” because it was so vile. And when the film came to America, not even the Village Voice missed the fact that the movie was “programmed to offend.” Indeed, A&E was the only network that agreed to air the film. Not even PBS would touch it.

When the League first communicated with Ms. Johnson in the fall of 1994, she defended the network saying A&E has “aired programming which could only be described as highly laudatory about the [Catholic] Church.” But a quick review of past programs aired by A&E proved quite the contrary. Of the five most recently aired programs dealing with the Catholic Church, only one, the “Biography of Pope John Paul II,” could be considered “laudatory.” The others, “Brides of Christ,” “Behind the Veil,” “Sex and the Church: A House Divided,” and now “The Boys of St. Vincent” could be called “unfavorable,” at best.

Clearly, a pattern seems to be emerging at A&E. The League posed a scenario to both Ms. Johnson and the media in a release sent out prior to the airing of “The Boys of St. Vincent.” It read: “Consider this: a network airs successive programs about homosexuals that cast them in a bad light. It then airs a program that puts gays in a good light, only to be followed by another negative portrayal. Would you think there was reason in the gay community to wonder what was going on? More important, do you think any network-including A&E-would dare offend gays in such a manner?”

Where you can write:

Arts & Entertainment Network
235 East 45th St. 
New York, NY 10017

Major Television Media Outlets I

Capital Cities/ABC Inc.

77 West 66th Street New York, NY 10023-6298 (212) 456-7777

CBS Inc.

51 West 52nd Street, 34th floor New York, NY 10019-6188 (212) 975-4321

Cable News Network (CNN)

Five Pennsylvania Plaza New York, NY 10001-1878 (212) 714-7800

FOX Television Network

1200 Sixth Avenue New York, NY 10036 (212) 556-2400

National Broadcasting Corporation (NBC)

Thirty Rockefeller Plaza New York, NY 10112-0035 (212) 664-4444

Public Broadcasting Service (PBS)

1320 Braddock Place Alexandria, VA 22314-1698 (703) 739-5000

(Include the program name on the front of the envelope when registering a complaint.)

The Massachusetts Legislature is considering a Parents Rights Bill, which would require parental notice and consent before public school students could be exposed to programs that address “morally or religiously sensitive topics.” The bill, AN ACT TO REAFFIRM THE RIGHT OF P ARENTS TO CONTROL THE MORAL AND RELIGIOUS EDUCA TION OF THEIR CHILDREN AND TO PROVIDE FOR PRIVACY PROTECTION (House Bill 1817), is a response to the increasing number of school districts which distribute contraceptives to adolescents, in most cases without the knowledge and approval of parents, and which subject students to graphic and controversial AIDS education, sex education, and homosexual programs.

The proposed law would mandate a 10 day notification period for parents before such programs could be introduced and would give parents the right to withdraw their children if they find the material to be presented morally objectionable. The burden of securing parental consent would be on the public school.

Catholic League Operations Director C. Joseph Doyle hailed the measure as “a long overdue defense of parental authority and religious freedom” and character- ized it is “a necessary remedy to the aggressive intrusions of special interests into public education.” “In a free society, the values of parents ought to prevail over those of the state in the moral and religious upbringing of children,” Doyle said. “When the government, acting through the public schools, gives a Catholic child a condom, or tells that student that homosexual behavior is a morally acceptable option, then the state is effectively encouraging Catholic children to violate their religious beliefs, and to ignore the authority and religious convictions of their parents.”