CASE NOTE: 10-17720 Plans Inc. v. Sacramento City Unified School District

Ninth Circuit Court of Appeals - San Francisco

SAN FRANCISCO, CA – MAY 17, 2012 –

The Ninth Circuit Court of Appeals is hearing a case this morning on the issue of whether the Sacramento Unified School District is violating constitutional principles of separation of church and state in awarding Waldorf-method charter public schools tax-based funding.

In the case brought by People for Legal and Nonsectarian Schools (PLANS), PLANS argues that Waldorf-method schools should not publicly funded because they are rooted in a spiritual philosophy called Anthrosophy, which was developed by Rudolf Steiner in the late 1800s. Proponents of Anthrosophy attempt to "extend the clarity of the scientific method to phenonema of human soul-life and to spiritual experiences." This includes developing new concepts of objective spiritual perception.
In the lawsuit, PLANS contends that this is based on spiritualist beliefs such as reincarnation and combines elements of Hinduism, European occultism, Gnostic Christianity, and other religions.

In a website,, Waldorf proponents state that, "anthroposophy strives to bridge the clefts that have developed since the Middle Ages between the sciences, the arts and the religious strivings of man as the three main areas of human culture, and build the foundation for a synthesis of them for the future."

Waldorf proponents deny that Anthroposophy is a religion
 because it is open to people of any faith or no faith at all and that this openness in practice, leadership, and belief precludes it from being categorized as a religion. Members are not required to perform a specific form of spiritual practice, and there is no profession of faith.

According to, which features links to a variety of Waldorf materials but is not affiliated with Waldorf education, teachers in Waldorf schools are encouraged to read a variety of books on spiritual topics, including A Western Approach to Reincarnation and Karma.
Pacific Justice Institute attorney Kevin Snider, who is arguing the case on behalf of PLANS,states, "The record is replete with examples of Anthrosophy that cannot be described as anything other than religious. We cannot have a double standard where mainstream religions like Christianity and Judaism are excluded from public schools while the door is open for esoteric, occult beliefs."

In 2003, the Ninth-Circuit Court of Appeals ruled that PLANS had tax-payer standing to pursue the case.



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