NEW BRITAIN, Conn. — A federal judge has denied a request from a longtime public school teacher who sought to display a crucifix on her classroom wall, ruling that her religious expression—though deeply personal—was made in her capacity as a government employee and therefore subject to constitutional limits.
Marisol Arroyo-Castro, a seventh-grade social studies teacher at DiLoreto Elementary & Middle School in the Consolidated School District of New Britain, had filed suit after being suspended and reassigned for refusing to remove the crucifix. She alleged violations of her rights under the Free Speech and Free Exercise Clauses of the First Amendment, as well as under Connecticut’s religious freedom statute.
In a 90-page decision issued October 9, 2025, Judge Sarala V. Rao of the U.S. District Court for the District of Connecticut denied Arroyo-Castro’s motion for a preliminary injunction, holding that the crucifix was posted “pursuant to her official duties” and therefore not protected as private religious expression.
“Ms. Castro acted pursuant to her official duties when she posted items on the classroom wall that students would see during instructional time,” Judge Rao wrote. “The classroom wall decorations are thus speech pursuant to Ms. Castro’s official duties and subject to the District’s control.”
The case, Arroyo-Castro v. Gasper, 3:25-CV-00153 (D. Conn. 2025), has drawn attention from both religious liberty advocates and public education officials. While the crucifix display was personal in meaning—Arroyo-Castro testified it had belonged to a close friend and provided her with peace and strength during the school day—the court emphasized the importance of context. The crucifix was posted on a classroom wall next to student instructional materials, where it was visible to students during regular class periods.
Although the school district permitted some personal décor and “expressive items,” such as team pennants and holiday decorations, Judge Rao distinguished between decorative content and what could be reasonably perceived as religious endorsement by the state.
“The relevant question is whether the speech was pursuant to the employee’s official job duties, not whether it related to the duties,” she wrote, citing Garcetti v. Ceballos, 547 U.S. 410 (2006). She further noted that under district policy, teachers were responsible for ensuring that classroom wall displays aligned with instructional goals and supported student learning.
The court’s analysis repeatedly returned to the distinction between private belief and public endorsement, particularly in a setting where attendance is compulsory and teachers act as agents of the government. In reaching her conclusion, Judge Rao contrasted the situation with Kennedy v. Bremerton School District, where a football coach prevailed after being disciplined for praying at midfield. The key difference, she wrote, was that in Kennedy, the prayers occurred after the school day and were not part of the employee’s official responsibilities.
Arroyo-Castro’s attorneys had argued that her display of the crucifix should be viewed similarly to personal religious jewelry or a mezuzah placed on an office doorframe. But the court rejected that analogy, noting that the crucifix was placed as part of wall décor in a space used for daily instruction and was therefore subject to different constitutional treatment.
The decision raises broader questions about how religious symbols are treated differently based on context and tradition. A mezuzah—a small parchment containing verses from Deuteronomy placed on a doorframe—is often considered a private religious item and has been the subject of its own legal disputes. In 2009, the U.S. Court of Appeals for the Seventh Circuit ruled in Bloch v. Frischholz, 587 F.3d 771, that removing a mezuzah from a condo hallway could be challenged under the Fair Housing Act. In workplace settings, courts have sometimes treated the mezuzah as analogous to religious attire—visible but personal, rather than institutional.
The distinction, as reflected in the Arroyo-Castro opinion, appears to rest heavily on whether the item is part of an employee’s personal religious practice or is displayed in a setting that suggests government endorsement.
For now, Arroyo-Castro remains in a non-teaching role within the school district. The court’s ruling only addressed her request for immediate reinstatement and classroom return. The broader constitutional claims will proceed through further litigation.
No appeals have yet been filed, and no final ruling on damages or long-term remedies has been issued.
TLDR (Too Long / Didn’t Read Summary)
A federal judge denied a public school teacher’s request to return to the classroom after she was disciplined for displaying a crucifix on the wall. The court ruled that because the crucifix was posted as part of her official duties and visible to students during instruction, it constituted government speech. The case highlights the legal difference between personal religious practice and public endorsement in schools.
Case Caption and Ruling
Marisol Arroyo-Castro v. Anthony Gasper et al., No. 3:25-CV-00153 (D. Conn.)
Ruling on preliminary injunction issued: October 9, 2025
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AI Disclaimer: This article was prepared with the assistance of AI. This article does not constitute legal advice. For legal guidance, please consult a licensed attorney.
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