Mid Vermont Christian School v. Saunders

The Second Circuit reversed the district court’s upholding of the Vermont Principals’ Association’s expulsion of Mid Vermont Christian School, finding that the VPA’s rule may not qualify as neutral and generally applicable.

ReligiousLiberty.TV
February 26, 2026
2 min read
Year: 2025
Education Free Exercise LGBTQ & Religious Liberty
Holding: The Second Circuit reversed the district court's upholding of the Vermont Principals' Association's expulsion of Mid Vermont Christian School, finding that the VPA's rule may not qualify as neutral and generally applicable.

Background

Mid Vermont Christian School was expelled from the Vermont Principals' Association (VPA) due to policies that conflicted with the association's non-discrimination rules regarding LGBTQ students. The school challenged this expulsion, arguing that the VPA's action violated their First Amendment right to free exercise of religion by forcing them to choose between their religious beliefs and participation in interscholastic athletics.

Legal Question

Whether the Vermont Principals' Association's expulsion of a religious school for maintaining policies consistent with its religious beliefs regarding LGBTQ issues violates the Free Exercise Clause, specifically whether the VPA's non-discrimination rule qualifies as neutral and generally applicable under the Supreme Court's decision in Employment Division v. Smith.

Holding

The Second Circuit Court of Appeals reversed the district court's decision that had upheld the VPA's expulsion of the school. The appellate court found that the VPA's rule may not qualify as "neutral and generally applicable" under First Amendment jurisprudence, which would subject the rule to strict scrutiny rather than the more deferential rational basis review. This suggests the court found potential issues with either the rule's neutrality toward religion or its general applicability across different situations.

Significance

This decision represents an important development in the ongoing tension between religious liberty and anti-discrimination policies in educational settings. The case contributes to the evolving landscape of Free Exercise jurisprudence following recent Supreme Court decisions that have been more protective of religious exercise rights. It particularly impacts how religious schools navigate participation in state athletic associations while maintaining faith-based policies, and may influence similar disputes across other circuits involving the balance between religious autonomy and inclusive policies.

Key Statutes & Provisions

  • First Amendment Free Exercise Clause
  • Employment Division v. Smith (neutral and generally applicable test)
  • Likely Vermont state anti-discrimination statutes
  • VPA membership and non-discrimination policies
*Note: Given the limited information provided and the case being from 2025, specific factual details about the school's particular policies and the complete procedural history are not available for inclusion in this synopsis.*

Official Documents

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Coverage on ReligiousLiberty.TV

📎 Document links found in our articles: 📄 opinion

Mid Vermont Christian School v. Saunders is a Education case in 2025. The court held that the Second Circuit reversed the district court's upholding of the Vermont Principals' Association's expulsion of Mid Vermont Christian School, finding that the VPA's rule may not qualify as neutral and generally applicable.

## Background
Mid Vermont Christian School was expelled from the Vermont Principals’ Association (VPA) due to policies that conflicted with the association’s non-discrimination rules regarding LGBTQ students. The school challenged this expulsion, arguing that the VPA’s action violated their First Amendment right to free exercise of religion by forcing them to choose between their religious beliefs and participation in interscholastic athletics.

## Legal Question
Whether the Vermont Principals’ Association’s expulsion of a religious school for maintaining policies consistent with its religious beliefs regarding LGBTQ issues violates the Free Exercise Clause, specifically whether the VPA’s non-discrimination rule qualifies as neutral and generally applicable under the Supreme Court’s decision in Employment Division v. Smith.

## Holding
The Second Circuit Court of Appeals reversed the district court’s decision that had upheld the VPA’s expulsion of the school. The appellate court found that the VPA’s rule may not qualify as “neutral and generally applicable” under First Amendment jurisprudence, which would subject the rule to strict scrutiny rather than the more deferential rational basis review. This suggests the court found potential issues with either the rule’s neutrality toward religion or its general applicability across different situations.

## Significance
This decision represents an important development in the ongoing tension between religious liberty and anti-discrimination policies in educational settings. The case contributes to the evolving landscape of Free Exercise jurisprudence following recent Supreme Court decisions that have been more protective of religious exercise rights. It particularly impacts how religious schools navigate participation in state athletic associations while maintaining faith-based policies, and may influence similar disputes across other circuits involving the balance between religious autonomy and inclusive policies.

## Key Statutes & Provisions
– First Amendment Free Exercise Clause
– Employment Division v. Smith (neutral and generally applicable test)
– Likely Vermont state anti-discrimination statutes
– VPA membership and non-discrimination policies

*Note: Given the limited information provided and the case being from 2025, specific factual details about the school’s particular policies and the complete procedural history are not available for inclusion in this synopsis.*