National Trends in Politics, Culture, and Law
2025 Annual Report of the Committee on Religious Liberty
Section VI
Section VI: National Trends in Politics, Culture, and Law
Politics
The Election
Religious liberty itself does not seem to have been one of the key issues for voters in the 2024 election. However, two significant issues that were prominent in the election have implications for religious liberty: immigration and gender identity.
Exit polls show that immigration was one of the top concerns for many Americans.[48] A central part of President-elect Trump’s campaign was his promise to secure the southern border and to carry out mass deportations of illegal immigrants. Vice President-elect Vance also played a significant role in the proliferation of the false rumor that migrants were eating pets. Although immigration policy is not itself a religious liberty issue, it becomes a religious liberty problem when religious charities and social services are singled out for special hostility, or when their bona fide religious motivations are impugned as pretextual for self-interest. Moreover, the climate engendered by overheated rhetoric can put religious workers in danger.[49]
Gender identity represents another issue that intersects with religious liberty. President-elect Trump ran ads on and drew attention to Kamala Harris’s record on this issue. Although there is insufficient data to conclude that the ads influenced the outcome of the election, some have reports suggested that they were effective. The discussion occasioned by the ads has revealed what appears to be an increase in willingness to publicly confront the claims of gender ideology. After the election, some Democrats seemed to signal a desire to moderate on issues of gender identity, such as in the context of whether males who identify as female should be allowed to play on female sports teams.[50]
Debanking
In recent years, individuals have raised concerns that banks are discriminating on the basis of political and religious viewpoints. Perhaps the most prominent instance of potentially politically motivated debanking took place with Ambassador Sam Brownback.[51] According to Ambassador Brownback, when he learned that his bank account had been closed in 2022, he received little and sometimes conflicting explanations, and at one point, the bank indicated that there was concern about possible exposure to terrorist networks. More recently, Memphis-based Indigenous Advance Ministries, a Christian charity that works in Uganda, has claimed that it was debanked. In this case, the bank offered the explanation that the charity violated the bank’s “debt collection” policy. Indigenous Advance Ministries claims that they do not engage in debt collection but simply remind the people they serve to pay their bills. In 2024, Indigenous Advance Ministries, with help from Alliance Defending Freedom, addressed a Bank of America shareholders meeting, urging increased transparency regarding debanking decisions.[52]
In response to incidents like these, some states have begun passing laws intended to prevent politically motivated debanking. However, the U.S. government argues that these laws hamstring banks, who need to be able to account for potential customer’s exposure to foreign actors.[53] The lack of transparency, though, makes it difficult to ascertain why someone like Ambassador Brownback would be debanked. The USCCB is monitoring this issue but has not taken a position on it.
Culture
Blasphemy and Sacrilege
The ideal of the modern Olympics is that people can come together for friendly competition in a spirit of mutual respect.[54] The 2024 Paris Olympics failed to live up to that ideal when the opening ceremony featured a display that mocked Catholic Christians.
The French bishops noted the contradiction between claiming to celebrate inclusivity while at the same time mocking people of faith.[55] Their response sought to lift up the positive ideals of the Games while lamenting the way the organizers came up short. The Holy See also expressed sadness at the offensive display.[56] Individual bishops also responded. Bishop Robert Barron, a member of the Committee for Religious Liberty, offered his thoughts, stating that these events target the Catholic Church, because the organizers know that the Catholic Church is the most significant opponent of their materialist, relativist worldview.[57] Thomas Jolly, the artistic director of the opening ceremony, claimed that the scene was not meant to evoke the image of the Last Supper, but that “[t]he idea was instead to have a grand pagan festival connected to the gods of Olympus, Olympism.” However, “The idea of the central figure with a halo and a group of followers on either side—it’s so typical of ‘The Last Supper’ iconography that to read it in any other way might be a little foolhardy,” said Sasha Grishin, an art historian and professor emeritus at the Australian National University.[58]
Senator James Lankford issued a letter to the President of the International Olympic Committee decrying the blatantly offensive mockery of the Christian faith.[59] Several members of Congress joined the letter.
In October, Michigan governor Gretchen Whitmer appeared in a social media video in which she gave a tortilla chip to a podcast host in a manner that lewdly imitated a priest giving communion at Mass. Governor Whitmer apologized, saying that the video “had been misconstrued.”[60] The Michigan Catholic Bishops Conference issued a statement, saying, “The skit goes further than the viral online trend that inspired it, specifically imitating the posture and gestures of Catholics receiving the Holy Eucharist, in which we believe that Jesus Christ is truly present. . . . It is not just distasteful or ‘strange;’ it is an all-too-familiar example of an elected official mocking religious persons and their practices.”[61]
Bishop Rhoades Speech on Depolarizing Religious Liberty
July 9–11, 2024, the University of Notre Dame held its Religious Liberty Summit on the theme of Depolarizing Religious Liberty.[62] The summit was sponsored by the Notre Dame Religious Liberty Clinic. Bishop Kevin Rhoades was invited to deliver a keynote address.
The summit brought together scholars, advocates, and experts from a variety of fields and perspectives to reflect on the meaning of religious freedom both here in the United States and abroad. Bishop Rhoades addressed the issue of truth in his keynote. He remarked that religious liberty in itself should not be polarizing, since there is widespread agreement amongst Americans that religious freedom is important. However, we do have deep disagreements around religion and issues of ultimate concern, and our polarized discourse about religious liberty often concerns where the limits of religious freedom lie.
According to Bishop Rhoades, we struggle to bridge our divides because our politics is not rooted in truth. Rather than seek to reason with others, we attempt to impose our will on those with whom we disagree. The purpose of politics has become a matter of self-assertion and opposing perceived enemies. Indeed, this is what it means to say that politics is polarized—it is a matter of groups identifying themselves in opposition to others.
Bishop Rhoades concluded by discussing the work of the USCCB to promote religious liberty, and how the Committee for Religious Liberty works to address polarization by not becoming polarized itself. For example, while the Committee often finds itself working with conservatives in order to defend the right of people of faith to live and work truthfully with respect to marriage and sexuality, the Committee also defends the rights of Catholic ministries to migrants and refugees, even as those ministries have come under attack by groups with whom it has worked. In order to promote religious liberty without being polarized, the Committee puts truth over post-truth politics.
Symposium: Religious Liberty in a Culture of Self-Invention
On September 9, 2024, the Committee brought together scholars, advocates, and church leaders to reflect on the current culture of self-invention in our nation—a culture that views the self as the center of meaning, and that regards personal identity as a matter entirely of our own creation. Participants explored how that culture presents unique challenges to religious freedom and what the Catholic Church in the United States can do to meet those challenges. Speakers included Bishop Kevin Rhoades, Mary Rice Hasson, D. C. Schindler, Abigail Favale, Marc DeGirolami, Melissa Moschella, Anthony Picarello, Helen Alvaré, and Paul Scherz.
During the panel discussions, several themes were raised. Five stood out as especially significant for the Committee:
- The prevalent understanding of freedom in the United States today is that the sheer capacity to choose among contraries is authentic freedom. In the traditional Catholic understanding, the capacity to choose the good constitutes true freedom.
- The dominant understanding of freedom entails even the freedom to choose, rather than receive, one’s identity. A culture of self-invention, then, grows, in part, from the idea of freedom as sheer choice. However, the self-invented identity is unstable, as it can come into conflict with reality. For example, while I may use the language of “family” to refer to the people I choose to consider as family, I cannot really choose my family. These kinds of identities come into conflict with nature. Hence, persons who expend significant energy asserting a chosen identity require others to affirm that identity. And this pressure on others to affirm one’s chosen identity leads to religious liberty problems, particularly in the area of gender identity.
- In a culture of self-invention, religion can be viewed as a matter of personal identity rather than a response to the Creator. To be sure, religion does involve identity, but it has traditionally been understood primarily as an obligation to God, and so the right to religious freedom protects persons who seek to carry out their obligations. If religion is considered to be primarily a matter of the identity that one chooses for oneself, then it is difficult to see why it would deserve special protection. It also potentially pits religious freedom against the common good.
- Religious liberty advocacy needs a definition of religion. In the current climate, some groups make spurious religious liberty claims, using religious freedom arguments to claim immunity from legitimate laws. Religious liberty advocates could serve the common good by helping the law to develop a definition of religion.
- Catholic religious liberty advocacy needs to be rooted in Catholic tradition. Faith and reason work together in Catholic tradition, but the tendency in religious liberty advocacy is to lead with reason. For example, in defending the rights of Catholic schools to hire people who support the mission of Catholic education, rather than talk about the issue in terms of choice or the integrity of mission-driven organizations, we might begin by talking about how Jesus Christ calls us to self-sacrificial love and what that love looks like. We should use the opportunities afforded by political and legal advocacy to clearly articulate what we believe and why. In that sense, our advocacy can also be a work of evangelization.
Antisemitism on College Campuses
Following the Hamas attack on Israel on October 7, 2023, pro-Palestinian demonstrations broke out across the country. One of the prominent sites for protests in 2024 was the American university. Crowd Counting Consortium identified 3,220 protest actions in the spring semester and 1,151 actions in the fall semester.[63] While many of these demonstrations aimed primarily to express solidarity with suffering Palestinians, some were reported to include antisemitic elements, such as comparing Israeli policy to that of the Nazis and rejecting the right of the state of Israel to exist.
Columbia University formed a task force to investigate antisemitism on campus following the protests that dominated the campus in the 2024 spring semester. Those protests were influential on the campus protest movement across the country, as it was the attempt by the university to restrict encampments there that helped to inspire encampments at other universities.
The task force’s second report presents some shocking findings.[64] Jewish students were assaulted, spit on, and verbally abused. Jewish students were also discriminated against by their teachers. Professors held class at the very encampments where Jewish students were being harassed. Jewish students were excluded from clubs. When Jewish students reported problems to campus authorities, their concerns were regularly dismissed. The task force describes a campus where Jewish students suffered real harm and leadership not only failed to stop the antisemitic activity but, in many cases, abetted it.
Events at the University of California in Los Angeles (UCLA) have prompted a lawsuit. During the protests, demonstrators set up encampments that blocked access to public facilities, including the library. The protesters essentially set up check points, where they prevented Jewish students from entering school buildings. Demonstrators set up a “Jew Exclusion Zone,” and chanted “death to Jews.” Students have filed a lawsuit against the school, saying UCLA failed to adequately protect Jewish students.[65] As the district court put it:
In the year 2024, in the United States of America, in the State of California, in the City of Los Angeles, Jewish students were excluded from portions of the UCLA campus because they refused to denounce their faith. This fact is so unimaginable and so abhorrent to our constitutional guarantee of religious freedom that it bears repeating, Jewish students were excluded from portions of the UCLA campus because they refused to denounce their faith.
UCLA is not the only school facing a lawsuit. Over 20 schools, including Harvard, Northwestern, Haverford, and others, have faced legal actions for failing to protect Jewish students.
Law and Litigation
Challenges to Recently Issued Federal Regulations
As federal agencies finalized numerous regulations harmful to religious liberty this year (see Section IV above) they were met with a wave of lawsuits. The heaviest litigation centered around the Title IX, Section 1557, and PWFA final rules, and all but a handful of the cases that had reached initial judgment as of the time of this writing had achieved some form of relief against the rule in question. Injunctions against enforcement of the Title IX rule are in place in numerous states, and the problematic components of the Section 1557 Rule are enjoined nationwide.
Republican state attorneys general brought the majority of these cases, which, because of the nature of a state as a claimant, could not assert religious liberty claims against the rules. However, religious liberty claims brought against the PWFA regulations by the USCCB and the Catholic Benefits Association found success, as did the CBA’s claims against the EEOC’s Workplace Harassment Guidance.[66]
Lawfare Against Catholic Service to Migrants
As political tensions mounted over the situation at the southern border, the Attorney General of Texas, Ken Paxton, brought the weight of his office to bear on the efforts of Texan Catholic ministries that serve migrants, sparking a controversy that garnered national attention.
In February of 2024, officials from the attorney general’s office arrived at Annunciation House, an independent Catholic ministry in El Paso, and demanded to inspect their records. After Annunciation House sought a court order allowing them time to verify what records could be disclosed, Attorney General Paxton countersued Annunciation House for violation of a Texas business statute requiring that his office be given “immediate” access to the records of any entity registered to operate in the state. The suit sought outright closure of Annunciation House under the same statute. Bishop Rhoades expressed solidarity with ministries to migrants, saying, “As the tragic situation along our border with Mexico increasingly poses challenges for American communities and vulnerable persons alike, we must especially preserve the freedom of Catholics and other people of faith to assist their communities and meet migrants’ basic human needs.”[67]
Weighing Annunciation House’s request for a temporary injunction, the court wrote:
The Attorney General’s efforts to run roughshod over Annunciation House, without regard to due process or fair play, call into question the true motivation for the Attorney General’s attempt to prevent Annunciation House from providing the humanitarian and social services that it provides. There is a real and credible concern that the attempt to prevent Annunciation House from conducting business in Texas was predetermined.[68]
In response to Annunciation House’s argument that Attorney General Paxton’s actions violated the organization’s religious freedom, Attorney General Paxton argued that the charity is not religious:
For starters, it is highly doubtful whether Annunciation House, as an institution, even has any bona fide religious component. [One deponent stated] that Annunciation House goes periods of “nine, ten months” without offering Catholic Mass, does not offer confessions, does not offer baptisms, does not offer communion, and makes “no” efforts to evangelize or convert its guests to Catholicism[]. By its House Director’s own admission, “probably only about half” of its volunteers subscribe to any particular religion. Instead, Annunciation House’s members appear to subscribe to a more Bohemian set of “seven commandments,” including commandments to “visit” people when “incarcerated” and “care [for them] when they’re sick.”[69]
Attorney General Paxton has appealed the case up to the Texas Supreme Court. Meanwhile, he began investigations of Catholic Charities of the Rio Grande Valley, seeking to depose its staff.
Religion and Religious Exercise in Public Schools
Public schools remained a battleground in the confrontation between gender ideology and religious liberty, freedom of speech, and parental rights. Numerous teachers and students either filed or continued to pursue lawsuits challenging school district policies that required them to use students’ preferred pronouns. Coalitions of parents have challenged school policies and curricula that promote gender ideology in the classroom. These cases have had mixed results.
In 2023, the Seventh Circuit had remanded a case to an Indiana district court to reconsider, under Groff v. DeJoy’s clarified standard for religious accommodations under Title VII, whether a teacher named John Kluge should be permitted to refer to students by their last names instead of their preferred pronouns.[70] Yet in April of 2024, the district court nonetheless found that the school was within its rights to deny Kluge that accommodation for his religious beliefs.[71]
In Massachusetts, a public school student was told he could not wear a t-shirt that said “there are only two genders” because it violated a provision in the school dress code that prohibits hate speech. The First Circuit sided with the school, and the case is on petition to the Supreme Court.
Parent coalitions have advanced different causes of action against school policies that promote gender ideology. In Parents Protecting Our Children, UA v. Eau Claire Area School District, Wisconsin, the Supreme Court denied review of the Seventh Circuit’s rejection of a claim, based on the fundamental right of parents to direct the upbringing of their own children, brought against a school policy of concealing students’ asserted gender identities from their parents.[72] Another, Mahmoud v. Taylor, asserts that a Maryland school district’s inclusion of pro-gender-ideology content in the elementary school curriculum violates the parents’ religious freedom.[73] A petition seeking review of the parents’ loss before the Fourth Circuit remains pending before the Supreme Court.
Conversely, a teacher in Ohio filed a lawsuit claiming that her religious liberty was violated when she was prohibited from keeping books in her classroom that promote gender ideology.[74]
2024 also saw challenges brought against state efforts to make public schools more religious. A group of parents in Louisiana obtained a preliminary injunction against implementation of a state bill requiring display of a Protestant version of the Ten Commandments in public school classrooms, finding that the bill likely violates the Free Exercise and Establishment Clauses.[75] And a coalition in Oklahoma argued that the Oklahoma state constitution’s religious freedom provisions prohibit the state superintendent from requiring that the King James Bible be incorporated into public school curricula.[76]
The Relationship of Religious Schools to the State
Last year saw further developments in the long-running line of cases probing the degree to which religious schools can maintain their autonomy while receiving generally available public benefits.
Title IX, a federal statute prohibiting sex discrimination in any school that receives federal funds, contains a robust religious exemption. That exemption has been particularly operative, and subject to scrutiny, since Title IX began to be interpreted to prohibit sexual orientation and gender identity discrimination as well. In August of 2024, the Ninth Circuit affirmed the constitutionality of the exemption, finding that it violates neither the Equal Protection Clause nor the Establishment Clause.[77]
Exclusion of religious schools from government programs based on their religious character or exercise remained a prominent theme in 2024. The two successor cases to Carson v. Makin went on appeal to the First Circuit, after Maine district courts ruled against religious schools challenging Maine’s most recent attempt to exclude them from the state’s tuition assistance program.[78] In California, Jewish parents won a victory at the Ninth Circuit in a case challenging California’s exclusion of “sectarian” schools from eligibility for federal funds meant to help students with disabilities.[79]
While Oklahoma’s state superintendent sought to have the Bible read in public school classrooms, its attorney general worked to quash a state board’s approval of the state’s first religious charter school: St. Isidore of Seville Virtual Charter School, a joint project of the Archdiocese of Oklahoma City and the Diocese of Tulsa. St. Isidore’s has sought Supreme Court review of the Oklahoma Supreme Court’s ruling that the school would be a government entity and therefore prohibited from conducting itself according to Catholic teaching.[80]
The Ministerial Exception and Title VII’s Religious Employer Exemption
The ministerial exception—a constitutional principle that secures religious organizations’ right to select who ministers their faith—remains an active area of litigation. Under the doctrine, religious organizations are generally immune from claims of employment discrimination from individuals employed as ministers. Since the Supreme Court first recognized the ministerial exception in the landmark Hosanna Tabor v. EEOC case in 2012, legal battles large and small have been fought over the scope of the doctrine—who counts as a “minister,” and how broad are the protections afforded by the doctrine.
Courts in 2024 continued to disagree on the boundaries of the exception. For instance, the Supreme Court of Nebraska found that the exception shielded the Archdiocese of Omaha from a defamation claim brought by a priest,[81] while a federal district court in New Jersey found that the exception did not bar a defamation claim.[82]
Title VII’s exemption for religious employers, properly understood, protects religious organizations for employment decisions motivated by their religious beliefs. The exemption is in a sense a mirror image of the ministerial exception—while the ministerial exception covers only certain employees who qualify as ministers, it applies regardless of the employer’s motivation, whereas the Title VII exemption applies to all employees but turns on the employer’s reasons for the adverse employment action.
Curiously, recent debate over the meaning of the Title VII religious employer exemption may create pressure to expand the scope of the ministerial exception. In the past two years, courts have begun to embrace the correct reading of the exemption, rather than a narrow view that it only protects against claims of discrimination on the basis of the employee’s religion. Some who wish to keep the Title VII exemption narrow may prefer that a case be resolved under the ministerial exception instead.
This appears to be what happened in Billard v. Charlotte Catholic High School, a May 2024 ruling from the Fourth Circuit in which the school had defenses under the ministerial exception and the Title VII religious employer exemption. The ACLU attorney representing the teacher told the Fourth Circuit at oral argument that, if his client were to lose, it would be better to lose under the ministerial exception. The court obliged, ruling in favor of the school on the grounds of the ministerial exception instead of Title VII.[83]
Religious Beliefs at Issue in Adoption, Foster Care, and Child Custody
Religious individuals seeking to adopt or become foster parents sought relief in court when state agencies concluded their religious beliefs on matters of human sexuality made them unfit to be parents. For instance, a prospective foster mother in Oregon appealed a district court’s’ ruling that her religious liberty was not violated when the state excluded her based on its requirement that all parents in the state’s foster care program agree to affirm a child’s asserted sexual orientation or gender identity.[84]
Chillingly, states have even removed children from their parents’ custody based on the parents’ religious beliefs. The Supreme Court denied review of an Indiana case in which the state took custody of a child because their religious beliefs prevented them from affirming their son’s assertions that he is a girl.[85] In Montana, state child protective services seized a child from her parents when she expressed suicidal ideation because her parents would not affirm, contrary to their religious beliefs, that she is a boy.[86]
FACE Act Convictions
The Freedom of Access to Clinic Entrances Act, or FACE Act, is a 1994 law that criminalizes 1) certain kinds of interference with access to reproductive health services or churches, and 2) intentional damage to the property of reproductive health clinics or churches. The term “reproductive health” has long been understood to refer to abortion clinics, although it can also apply to pro-life pregnancy resource centers.
Historically, the FACE Act has been used almost exclusively to protect abortion clinics and has never been used to protect a church. Certainly, some prosecutions under the FACE Act have been just— for arson or for bomb threats, for example—but in other cases the penalties have seemed disproportionate to the conduct in question—for example, peacefully sitting and praying in front of the doors of an abortion clinic.
The lopsided enforcement of the FACE Act has long been noted but has received renewed attention in recent years, as increasing attacks on pro-life pregnancy resource centers have gone largely unpunished, while some actions brought against protesters outside abortion clinics seemed unjustifiably severe.
While one way to address this disparity is to advocate for the repeal of the FACE Act, another way is to more fairly enforce it. To that end, the Florida Attorney General charged four people in 2023 under the FACE Act for vandalism on pro-life pregnancy centers. Following the Supreme Court’s overturning of Roe v. Wade in 2022, they had spraypainted threatening messages on the centers, such as “If abortions aren’t safe than niether [sic] are you,” “WE’RE COMING for U,” and “We are everywhere.” Three of the defendants pleaded guilty.[87] One was sentenced to 1 year and 1 day in prison, while the others were sentenced to 30 days in prison and 60 days in home detention. The fourth defendant was convicted on December 19, 2024.[88]
[48] See, for example, Monica Potts, “Why voters chose Trump,” ABC News, 14 November 2024: abcnews.go.com/538/voters-chose-trump/story?id=115827243.
[49] See Miriam Jordan, “Faith-Based Groups That Assist Migrants Become Targets of Extremists,” New York Times, 2 June 2024: www.nytimes.com/2024/06/02/us/migrants-charities-shelters-threats.html.
[50] See, for example, Adam Nagourney and Nicholas Nehamas, “Harris Loss Has Democrats Fighting Over How to Talk About Transgender Rights,” New York Times, 20 November 2024: www.nytimes.com/2024/11/20/us/politics/presidential-campaign-transgender-rights.html.
[51] Kevin Williamson, “Debanking Is Just a Tax on Dissent,” The Dispatch, 31 July 2024: thedispatch.com/article/debanking-tax-dissent/. Mr. Brownback has served as a Republican governor of Kansas and as Ambassador-at-Large for Religious Freedom in the Donald Trump administration. He is now the president of the National Committee for Religious Liberty.
[52] See Alliance Defending Freedom [news release], “De-banking victim Steve Happ of Indigenous Advance Ministries to Bank of America: ‘I don’t want it to happen to anyone else’,” 23 April 2024: adflegal.org/press-release/de-banking-victim-steve-happ-indigenous-advance-ministries-bank-america-i-dont-want/ ; Jeremy Tedesco, “Bank of America Needs To Come Clean About ‘De-Banking’ Practices,” RealClearMarkets, 13 May 2024: www.realclearmarkets.com/articles/2024/05/13/bank_of_america_needs_to_come_clean_about_de-banking_practices_1030907.html.
[53] Michael Stratford, “The looming battle over ‘debanking’,” Politico, 3 July 2024: www.politico.com/newsletters/morning-money/2024/07/03/the-looming-battle-over-debanking-00166402. See also Richard Vanderford, “State Laws Barring ‘Debanking’ Could Harm National Security, Treasury Says,” Wall Street Journal, 19 July 2024: www.wsj.com/articles/state-laws-barring-debanking-could-harm-national-security-treasury-says-ca30503a.
[54] See “Olympic Values - Excellence, Respect and Friendship” at olympics.com/ioc/olympic-values.
[55] Jean-Benoît Harel, “French Bishops lament ‘scenes mocking Christianity’ at Olympic Ceremony,” Vatican News, 28 July 2024: www.vaticannews.va/en/church/news/2024-07/french-bishops-lament-scenes-mocking-christianity-at-olympics.html.
[56] “Vatican says it was ‘saddened’ by Olympics’ opening ceremony,” Catholic News Service, 4 August 2024: www.usccb.org/news/2024/vatican-says-it-was-saddened-olympics-opening-ceremony.
[57] Bishop Robert Barron, “Bishop Barron’s Olympics Commentary,” Word on Fire: www.wordonfire.org/bishop-barron-olympics/.
[58] Yan Zhuang, “An Olympics Scene Draws Scorn. Did It Really Parody ‘The Last Supper’?” New York Times, 28 July 2024: www.nytimes.com/2024/07/28/sports/olympics-opening-ceremony-last-supper-paris.html.
[59] Senator James Lankford [news release], “Lankford Calls Out Olympic Committee for Mocking Christian Faith,” 30 July 2024: www.lankford.senate.gov/news/press-releases/lankford-calls-out-olympic-committee-for-mocking-christian-faith/.
[60] Kate Quiñones, “Michigan’s Gov. Whitmer apologizes for how Dorito video was ‘construed’,” Catholic News Agency, 14 October 2024: www.catholicnewsagency.com/news/259835/michigans-gov-whitmer-apologizes-for-how-dorito-video-was-construed.
[61] Michigan Catholic Conference [news release], “Gov. Whitmer’s Social Media Skit Prompts Catholic Bishops Conference to Urge Greater Respect for Religion in Public Life,” 11 October 2024: www.micatholic.org/advocacy/news-room/news-releases/2024/whitmers-social-media-skit-prompts-catholic-bishops-conference-to-urge-greater-respect-for-religion-in-public-life/.
[62] Sarah Doerr, “Experts from across the globe convene at fourth annual Notre Dame Religious Liberty Summit, seeking to promote and depolarize religious liberty,” University of Notre Dame Law School, 22 July 2024: law.nd.edu/news-events/news/experts-from-across-the-globe-convene-at-fourth-annual-notre-dame-religious-liberty-summit-seeking-to-promote-and-depolarize-religious-liberty/.
[63] Johanna Alonso, “Massive Decline in Protests from Spring to Fall 2024,” Inside Higher Ed, 19 December 2024:www.insidehighered.com/news/students/free-speech/2024/12/19/2000-fewer-pro-palestinian-protests-fall-spring-2024
[64] Columbia University Task Force on Antisemitism, “Report #2: Columbia University Student Experiences of Antisemitism and Recommendations for Promoting Shared Values and Inclusion,” August 2024: president.columbia.edu/sites/default/files/content/Announcements/Report-2-Task-Force-on-Antisemitism.pdf.
[65] Becket [news release], “Federal court orders UCLA to stop helping antisemitic activists target Jews,” 13 August 2024: www.becketlaw.org/media/breaking-federal-court-orders-ucla-to-stop-helping-antisemitic-activists-target-jews/.
[66] Cath. Benefits Ass’n v. Burrows, 732 F. Supp. 3d 1014 (D.N.D. 2024).
[67] USCCB [news release], “Freedom to Meet Migrants’ Basic Human Needs Must be Preserved, says Bishop Rhoades,” 26 February 2024: www.usccb.org/news/2024/freedom-meet-migrants-basic-human-needs-must-be-preserved-says-bishop-rhoades.
[68] Annunciation House v. Paxton, No. 2024-DCV-0616 (Tex. Dist. Ct., El Paso County, Mar. 10, 2024).
[69] Application for Temporary Injunction, Annunciation House v. Paxton, No. 2024-DCV-0616 (Tex. Dist. Ct., El Paso County), filed May 8, 2024.
[70] Kluge v. Brownsburg Cmty. Sch. Corp., No. 21-2475, 2023 WL 4842324 (7th Cir. July 28, 2023).
[71] Kluge v. Brownsburg Cmty. Sch. Corp., 732 F. Supp. 3d 943 (S.D. Ind. 2024).
[72] Parents Protecting Our Child., UA v. Eau Claire Area Sch. Dist., Wisconsin, 95 F.4th 501 (7th Cir. 2024), cert. denied, No. 23-1280, 2024 WL 5036271 (U.S. Dec. 9, 2024).
[73] Mahmoud v. McKnight, 102 F.4th 191 (4th Cir. 2024).
[74] Cahall v. New Richmond Exempted Village School District Board of Education, et al., No. 1:24-cv-00688-DRC, Complaint (S.D. Ohio, filed Dec. 2, 2024).
[75] Roake v. Brumley, No. CV 24-517-JWD-SDJ, 2024 WL 4746342 (M.D. La. Nov. 12, 2024).
[76] Walke v. Walters, No. [Case Number Pending], Complaint (Okla. Sup. Ct. filed Oct. 17, 2024).
[77] Hunter v. U.S. Dep’t of Educ., 115 F.4th 955 (9th Cir. 2024).
[78] St. Dominic Acad. v. Makin, No. 2:23-CV-00246-JAW, 2024 WL 3718386 (D. Me. Aug. 8, 2024); Crosspoint Church v. Makin, 719 F. Supp. 3d 99 (D. Me. 2024), judgment entered, No. 1:23-CV-00146-JAW, 2024 WL 2830931 (D. Me. June 4, 2024).
[79] Loffman v. California Dep’t of Educ., 119 F.4th 1147 (9th Cir. 2024).
[80] Drummond ex rel. State v. Oklahoma Statewide Virtual Charter Sch. Bd., 2024 OK 53, 558 P.3d 1.
[81] Syring v. Archdiocese of Omaha, 317 Neb. 195, 9 N.W.3d 445 (2024).
[82] Uzomechina v. Episcopal Diocese of New Jersey, No. CV 23-2914 (MAS) (TJB), 2024 WL 197752 (D.N.J. Jan. 18, 2024).
[83] Billard v. Charlotte Cath. High Sch., 101 F.4th 316 (4th Cir. 2024).
[84] Bates v. Pakseresht, No. 23-4169, Appellant’s Opening Brief (9th Cir. filed Jan. 11, 2024); Bates v. Pakseresht, No. 2:23-CV-00474-AN, 2023 WL 7546002 (D. Or. Nov. 14, 2023).
[85] M. C. v. Indiana Dep't of Child Servs., 144 S. Ct. 1084, 218 L. Ed. 2d 255 (2024).
[86] Kolstad v. Baillargeon, et al., No. 1:24-cv-00055-SPW-TJC, Complaint (D. Mont. filed May 20, 2024).
[87] U.S. Department of Justice Office of Public Affairs [news release], “Three Defendants Plead Guilty to a Civil Rights Conspiracy Targeting Pregnancy Resource Centers,” 14 June 2024: www.justice.gov/opa/pr/three-defendants-plead-guilty-civil-rights-conspiracy-targeting-pregnancy-resource-centers.
[88] U.S. Department of Justice Office of Public Affairs [news release], “Florida Woman Convicted of Civil Rights Conspiracy Targeting Pregnancy Resource Centers,” 20 December 2024: www.justice.gov/opa/pr/florida-woman-convicted-civil-rights-conspiracy-targeting-pregnancy-resource-centers.