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Segraves v. California: Anti-Dogmatism Policies Protect Teaching of Evolution, How about Questioning Evolution? (Updated)

In Segraves v. California, a California state court found it legal for a public school to teach evolution. Now, if only California’s anti-dogmatism policy would likewise protect teachers who inform students about scientific dissent from neo-Darwinian evolution.

Update: For those who protest me discussing this case, I want to note that I would not have even known of this case were it not for the fact that the NCSE has been touting it and citing it for years on its Ten Major Court Cases about Evolution and Creationism page.

1. Summary
Plaintiff Kelly Segraves, a parent of children in California public schools, challenged the California State Board of Education’s Science Framework that mandated the teaching of evolution.84 Segraves alleged that the mandatory teaching of evolution prevented both himself and his family from freely exercising their religion.85 Although the California Superior Court accepted that evolution was incompatible with the Segraves’ religious beliefs, the Court held that California’s anti-dogmatism policy provided sufficient accommodation for their views.86 This policy stated that discussions about origins were intended to emphasize that scientific explanations are more about the processes of nature rather than ultimate causes.87 The court stressed that scientific discussions should be focused on how life began and evolved and not on the ultimate cause of life’s origin.88

2. Importance and Commentary
Similar to Wright and Crowley, the Segraves decision holds that learning about evolution in public schools does not infringe upon the free exercise of religion.89 Segraves also recognized that evolution can violate the religious beliefs of students and other members of the community, and the court emphasized the importance of embracing tolerance when dealing with such controversial subjects.90 Under this reasoning, it is presumable that California’s “anti-dogmatism policy” would protect the teaching of any scientific theory, even if it offended the views of some citizens. This opinion is of minimal value as precedent, as it comes from a lower state court and was never officially published as a legal opinion.91 Nonetheless, it implies that evolution education policies may avoid establishing religion when they are based upon the legitimate secular purpose of avoiding dogmatism in the classroom.

[Editor’s Note: This survey of Segraves v. California is an excerpt from the article “Does Challenging Darwin Create Constitutional Jeopardy? A Comprehensive Survey of Case Law Regarding the Teaching of Biological Origins,” Hamline University Law Review, Vol. 32(1):1-64 (Winter, 2009), published by Hamline University School of Law. This excerpt covers the case Segraves v. California; the full article can be read here.]

References Cited
[84.] Segraves v. California, No. 278978 (Super. Ct. Sacramento County 1981)
[85.] Id.
[86.] Id.
[87.] Id.
[88.] Id.
[89.] Segraves v. California, No. 278978
[90.] Id.
[91.] Id.


Casey Luskin

Associate Director and Senior Fellow, Center for Science and Culture
Casey Luskin is a geologist and an attorney with graduate degrees in science and law, giving him expertise in both the scientific and legal dimensions of the debate over evolution. He earned his PhD in Geology from the University of Johannesburg, and BS and MS degrees in Earth Sciences from the University of California, San Diego, where he studied evolution extensively at both the graduate and undergraduate levels. His law degree is from the University of San Diego, where he focused his studies on First Amendment law, education law, and environmental law.



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