Section VI: National Trends in Politics, Culture, and Law

Violence, Threats of Violence, and Responses to Threats

Several attacks that took place over the course of the year have political and religious implications.[1] Motives for these attacks can be complex and difficult to assess. Nevertheless, they are troubling for Christians and other people of faith, who seek to build a society in which persons can engage one another on difficult issues without resorting to violence. Demonization of others has become normalized amongst political leaders and media personalities. Some of these incidents express some antagonism towards the religious identity of the victims. Other events seem to be symptoms of the mental health crisis in the United States. In several cases, these incidents reveal a disturbing nihilism driven by internet memes and social media consumption.

While Catholic churches continue to face problems with vandalism and arson, two incidents at Catholic facilities stand out in particular. First, on August 27, a shooter fired on a Mass being held for the beginning of the school year at Annunciation Catholic School in Minneapolis, Minnesota. The shooter fired into the windows from outside the building, killing two children and injuring thirty people, twenty-six children and four adults. While the fact that the shooter was a biological male who identified as female prompted speculation that the attack was motivated by animus over the Church's teachings on human sexuality, investigation into the attack discerned no coherent motive.[2] A graduate of the school, he had written a manifesto and made videos and images expressing a mix of antisemitic, anti-Trump, racist, and anti-Catholic ideas, along with a strong desire to kill children.

In another incident, law enforcement officers removed a man who was armed with explosive devices from the front steps of the Cathedral of St. Matthew the Apostle in Washington, D.C., prior to the church’s annual Red Mass. This Mass marks the beginning of the Supreme Court’s term, and it has often been attended by Catholic justices. The man had a tent in front of the church and was asked to move. After police took him into custody, they discovered two hundred homemade incendiary devices in the tent. He had expressed anti-Catholic and antisemitic views, as well as hostility towards the Supreme Court justices.[3]

One act of political violence that took place in 2025 has had, and will likely continue to have, broad repercussions in American political and religious culture. A conservative activist, Charlie Kirk, was fatally shot during one of his signature campus debates. Kirk founded the organization Turning Point USA, and regularly held open-air debates on college campuses. Kirk was influential in conservative politics, and some reports suggest that the suspected killer may have targeted Kirk because of his views on sexuality and gender.[4] His evangelical Christianity was prominent in his work and his political views. At the time of this writing, no clear motive had been established for the killing. The murder has led to a new round of concerns about polarization and political violence.[5]

The year also saw a number of other religiously and politically inflected acts of violence. On April 13, just hours after the first night of Passover, an arsonist firebombed the home of Joshua Shapiro, governor of Pennsylvania. The suspect stated that he targeted Gov. Shapiro because of “what he wants to do to the Palestinian people.”[6] The next month, another horrific act of violence took place in Washington, D.C. On May 22, a young couple, who both worked at the Israeli Embassy, were killed as they were leaving an event at the Capital Jewish Museum. The suspect attempted to enter the event but was prevented by security. After his arrest, he is reported to have chanted “free, free Palestine.”[7]

On September 28, during a Sunday worship service, a man drove his truck into a Church of Jesus Christ of Latter-day Saints chapel, opened fire on the congregants, and set the building on fire. The attack killed four people and injured eight. Reports surfaced that the suspect had animus toward LDS members following a break-up with his girlfriend. The Federal Bureau of Investigation has classified the crime as being motivated by anti-religious beliefs.[8]

Antisemitism

The promotion of religious liberty is bound up with opposition to antisemitism. The past two years have seen a disturbing rise in antisemitic acts and sentiments. To be sure, opposition to Israeli policies towards Palestinians or promotion of United States policies that prioritize American interests do not in themselves constitute antisemitism. However, much of the rhetoric surrounding Israel and the Jewish community in the past year went far beyond mere critique of policy.

A particularly concerning development has been the mainstreaming of antisemitic and neo-Nazi tropes among some conservative institutions and media figures. A major flashpoint took place in November, after the popular and influential pundit, Tucker Carlson, interviewed the young podcaster, Nick Fuentes. Like earlier generations of American entertainers, Fuentes has established his reputation, in part, by saying things most people find shocking, for example, claiming that the leader of Nazi Germany, Adolf Hitler, was “cool.” After the interview, Carlson faced the accusation that he did not sufficiently challenge Fuentes’s views. Following those accusations, the President of the Heritage Foundation, Kevin Roberts, released a video indicating his support for Carlson. These events served to put a spotlight on the mainstream conservative movement, with some reports indicating that as many as thirty percent of young Republican government staff workers are sympathetic to the views of Fuentes.[9]

Attacks on Catholic Services in the Media

One of the goals of religious liberty advocacy has long been to ensure that faith-based organizations can freely cooperate with governments in order to advance the common good. The Trump administration seems to acknowledge the good work that religious groups do in some of its executive orders (see Section IV of this report). However, that work is undermined when media figures and political leaders accuse religious organizations of acting in bad faith when they participate in public programs.

In February, Vice President JD Vance was asked in an interview about criticism the administration had received over its immigration policies. In his response to the question, Vice President Vance suggested that the U.S. Catholic bishops have served immigrants and refugees in order to profit from government grants.[10] In fact, Catholic charitable services to noncitizens generally operate at a loss. Archbishop Timothy Broglio, then-president of the United Stated Conference of Catholic Bishops, issued a statement rebutting the remark.[11] Cardinal Timothy Dolan, Archbishop of New York, called the remarks “scurrilous.”[12] The remarks followed a pattern that the Committee for Religious Liberty has identified in previous reports of media figures making false and misleading claims about the work of the bishops and other Catholic ministries. Kim Daniels, director of the Initiative on Catholic Social Thought and Public Life at Georgetown University, commented, “It all comes down to an old strategy: politicians targeting Catholics for political gain.”[13]

Christian Expression in the Federal Government

The Trump administration undertook a number of actions in 2025 to put religion at the center of public life, with a special focus on Christianity. In addition to the work of the Religions Liberty Commission, which has primarily highlighted issues affecting Christians, and the task force on anti-Christian bias, the administration developed an initiative called “America Prays” as part of its America 250 activities. The goal of America Prays is to encourage 1 million Americans to commit to praying 1 hour per week during the year-long celebration of the two hundred and fiftieth anniversary of the founding of the United States.[14]

The administration has taken other steps to indicate its support for public expressions of Christianity, including Catholicism President Trump issued messages for several Catholic feast days, including the Feast of St. Michael the Archangel and the Solemnity of the Immaculate Conception.[15] Executive agencies have also deployed Christian symbols on social media posts in ways that indicate the administration sees its activities in explicitly Christian terms.[16] There were also more subtle actions, such relocating a painting of Jesus to a more prominent place at the U.S. Merchant Marine Academy.[17] With these kinds of actions, some Christians see the “most Christian” administration they have ever known,[18] while others suggest that the use of Christian language and symbolism functions as “the pinch of incense that makes believers comfortable with worldly deeds and choices.”[19] At the same time, other faith communities are concerned by what they perceive as efforts to privilege Christian discourse in the public sphere.

Law and Litigation

With a few exceptions, religious liberty litigation proceeded along largely familiar lines in 2025. Notable new developments included conflicts in the context of federal immigration policy and enforcement, and an attack in Washington State on the seal of the confessional.

Ongoing Litigation over Existing Regulations

While the Trump administration alleviated the threat of federal enforcement of various Biden-era regulations that infringed religious liberty, the administration did not formally rescind those regulations, so litigation against them continued. Early in 2025, two federal district courts vacated the U.S. Department of Education’s Title IX Rule, which had prohibited sexual orientation and gender identity discrimination on education programs receiving funding from the Department. [20] In October, another vacated the U.S. Department of Health and Human Services’ (HHS) Section 1557 Rule to the extent it prohibited discrimination on the basis of gender identity.[21] The USCCB and Catholic Benefits Association won injunctions against the abortion-accommodation mandate in the Equal Employment Opportunity Commission’s regulations implementing the Pregnant Workers Fairness Act.[22]

Remarkably, fourteen years after the Obama administration’s HHS first issued regulations requiring employers to include contraceptives and abortifacients in their health plans—commonly known as the contraceptive mandate—litigation over the mandate carries on. In August, a federal district court struck down the exemptions from the mandate that the first Trump administration had established for religious and moral objections.[23]

State Insurance Mandates

At the state level, mandates to cover abortion in employer health plans remained a source of concern. After the Supreme Court already granted, vacated, and remanded Diocese of Albany v. Harris back to the Second Circuit in 2021, for reconsideration in light of Fulton v. Philadelphia, the case reached the Court yet again and was granted, vacated, and remanded yet again, this time for reconsideration in light of Catholic Charities Bureau v. Wisconsin Labor & Industry Review Commission.[24] In Illinois, a state appeals court upheld a ruling find that the Illinois Baptist State Association suffered no burden on its religious liberty under Illinois’ abortion mandate because the association had not exhausted its options to purchase a plan from out of state.[25] And in Washington State, there was another development in Cedar Park Assembly of God v. Kreidler. On the case’s first trip to the Ninth Circuit, the court reversed the district court’s ruling that Cedar Park lacked standing. On its second trip, however, the Ninth Circuit changed its mind, ruling that Cedar Park did in fact lack standing. But in July, after Cedar Park petitioned for en banc review, the circuit panel withdrew its opinion. A new opinion is anticipated.[26]

Intersections of Immigration and Religious Liberty

The Trump administration’s immigration policies and enforcement efforts produced a number of religious liberty conflicts. As discussed in Section 4, ICE’s rescission of a memorandum restricting enforcement at sensitive locations, such as churches and schools, generated several lawsuits. In Pennsylvania, an interfaith coalition led by the Society of Friends (commonly known as the Quakers) won a preliminary injunction against ICE enforcement on their properties, while in D.C., a coalition led by the Mennonites appealed after being denied relief on the basis that they lack standing.[27] A third case in Oregon remains awaits judgment.[28]

The ICE detention facility in Broadview, Illinois generated controversy and a lawsuit over ICE officials’ treatment of religiously motivated protestors and denial of requests to access the facility to attend to the religious needs of detainees .[29]

At the state level, Texas Attorney General Paxton’s action to dissolve Annunciation House, a Catholic charity serving immigrants, was allowed to move forward when the Texas Supreme Court ruled that further proceedings would not violate the state’s version of the Religious Freedom Restoration Act.[30] However, AG Paxton’s attempt to obtain a pre-suit deposition of the Executive Director of Catholic Charities, Rio Grande Valley was rejected by the Texas Court of Appeals.[31] And in Indiana, the state attorney general sought information from Catholic Charities of Fort Wayne—South Bend in an investigation into human trafficking and violations of anti-sanctuary laws.[32]

In all these instances, there is a growing tension between the longstanding efforts of people of faith, and Catholics in particular, to serve and accompany immigrants and refugees, consistent with their deeply held beliefs, and government actors’ inconsistent approach to immigration policy. In the absence of long overdue reform of the U.S. immigration system by policymakers, religious organizations addressing people’s spiritual and corporal needs without discriminating on the basis of immigration status become convenient scapegoats. Meanwhile, these very organizations, which have been essential in encouraging the successful integration of immigrants, helping combat their exploitation, and in the process supporting the development of American communities, somehow become the ones accused of acting against the national interest. 

Religion and Religious Exercise in Public Schools

Public schools remained a hotbed of litigation over conflicts between religion and gender ideology. One line of cases involves the parental rights of religious parents challenging school policies that conceal their children’s “social transitions.”[33] Another involves teachers and students who object to school policies requiring affirmation of students’ asserted gender identities, such as by using their preferred pronouns.[34]

Meanwhile, lawsuits challenged requirements that the Ten Commandments be posted in public school classrooms in Arkansas, Louisiana, and Texas.[35] All three state laws were enjoined under Stone v. Graham, a 1980 Supreme Court case that struck down a similar Kentucky statute under the Establishment Clause because it had no “secular legislative purpose.” The states argue that that is no longer the correct test under the Court’s more recent Establishment Clause jurisprudence. Some challengers, in addition to their Establishment Clause claims, argue that forced exposure of children to the Ten Commandments violates their rights under the Free Exercise Clause. The en banc Fifth Circuit will hear the Texas and Louisiana cases together, while the Arkansas case remains in district court.

The Relationship of Religious Schools to the State

Both Maine and Colorado prohibit discrimination on the basis of sexual orientation and gender identity as a condition for schools to receive state funds—in Maine, for a program that pays tuition at private schools for students in districts without public schools, and in Colorado, for schools to participate in the state’s universal pre-kindergarten program. In each state, a Catholic school represented by the Becket Fund and a Protestant school represented by Alliance Defending Freedom challenged the states’ exclusion of schools that adhere to true beliefs on human sexuality—St. Dominic Academy and Crosspoint Church in Maine, and St. Mary’s School and Darren Patterson Christian Academy in Colorado.[36]

The Maine cases follow on the state’s loss in Carson v. Makin, where the Supreme Court struck down the state’s exclusion of religious schools that use state funds to teach religion. The state responded to the loss by imposing the nondiscrimination requirement as another means of excluding disfavored religious schools. The cases were argued together at the First Circuit in early 2025 and still await a ruling.

The Tenth Circuit upheld Colorado’s law in St. Mary’s v. Roy, reasoning that it passes the test set out in Employment Division v. Smith.[37] The case is now pending certiorari before the Supreme Court. Darren Christian Patterson Academy v. Roy still awaits a ruling from the Tenth Circuit.

Attack on the Seal of the Confessional

Washington State’s law on mandatory reporting of child abuse exempts covered persons from reporting abuse in certain situations where they received the information in a legally privileged setting, such as the attorney-client privilege. In 2025, the state amended its law to specifically eliminate the privilege for clergy who receive such information in the context of confession, while leaving other forms of privilege intact. Finding that the law likely violates the Free Exercise Clause, a federal district court issued a preliminary injunction prohibiting enforcement of the law against Catholic priests in the state. “[T]he text of the bill and its legislative history,” wrote the court, “arguably evince the intentional abrogation of a practice that the legislature understood to be religiously sacrosanct.”[38] The state then folded, agreeing to enter a permanent injunction against enforcement of the law as to the Catholic sacrament of Confession or other such practice in other faiths.[39]

Church Autonomy in the Spotlight

The church autonomy doctrine—a principle, deriving from both the Free Exercise and the Establishment Clauses, that civil authorities may not decide matters of a church’s faith, governance, or internal discipline—has increasingly figured in religious liberty litigation in recent years. For instance, at the Supreme Court, Justice Thomas’s concurrence in Catholic Charities Bureau argued that the Wisconsin Supreme Court violated the church autonomy doctrine by disregarding the Diocese of Superior’s religious understanding of its own internal structure—an “error of treating a religious institution as nothing more than its corporate entities.” And in 2025, the doctrine received likely its most full-throated articulation from a Court of Appeals yet, in McRaney v. North American Mission Board of the Southern Baptist Convention. “Where the church autonomy doctrine applies, its protection is total,” wrote the court. “That is because the doctrine is a constitutional immunity from suit…Abridgement of the church autonomy immunity imposes irreparable injury on the religious organization, so its denial is subject to an immediate interlocutory appeal.”[40]

Not every court saw it that way. In O’Connell v. United States Conference of Catholic Bishops, a class-action lawsuit alleging the USCCB is liable for fraud because the Holy See used some funds offered to Peter’s Pence for investments and operating the Church rather than immediately using them for certain charitable matters, a panel of the D.C. Circuit denied the USCCB’s interlocutory appeal over the suit’s intrusion into church autonomy.[41] Judges Rao and Walker warned that their Circuit’s conclusion threatened irreparable harm to the First Amendment and would render church autonomy a “dead letter.”[42] By contrast, in Huntsman v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, the en banc Ninth Circuit unanimously rejected similar fraudulent-tithing claims. While ten judges found the claims failed on their face, five explained in two concurrences that the claims also obviously violated the church autonomy doctrine: “Nothing says ‘entanglement with religion’ more than Huntsman’s apparent position that the head of a religious faith should have spoken with greater precision about inherently religious topics, lest the Church be found liable for fraud.”[43] And in Gaddy v. Corporation of the President of the Church of Jesus Christ of Latter-day Saints, the Tenth Circuit also rejected fraudulent-tithing claims, in part under the church autonomy doctrine.[44]

[1] There were a number acts of political violence that did not appear to implicate religion, such as attacks on ICE agents and the assassination of two state lawmakers in Minnesota. See Joe Walsh, CBS News, “Political violence has gripped the U.S. this year. Experts say it's not as simple as left and right,” 27 October 2025: www.cbsnews.com/news/political-violence-experts-left-and-right/. 

[2] Odette Yousef, NPR, “‘There is no message’: The search for ideological motives in the Minneapolis shooting,” 29 August 2025: www.npr.org/2025/08/29/nx-s1-5522038/minneapolis-shooting-motive.

[3] Richard Szczepanowski, OSV News, “Man arrested outside Washington cathedral ahead of Red Mass found to have explosives,” 7 October 2025: www.osvnews.com/man-arrested-outside-washington-cathedral-ahead-of-red-mass-found-to-have-explosives/.

[4] Jon Haworth and Megan Forrester, ABC News, “Tyler Robinson said he killed Charlie Kirk because he ‘spreads too much hate’: Officials,” 16 September 2025: abcnews.go.com/US/tyler-robinson-set-face-formal-charges-shooting-death/story?id=125614396; Jesse Bedayn, Hannah Schoenbaum, and John Seewer, Associated Press, “Suspect left note saying he planned to kill Charlie Kirk, later confessed in texts, prosecutor says,” 17 September 2025: www.wyff4.com/article/tyler-robinson-capital-murder-charlie-kirk-assassination/66119457. 

[5] Alfonso Serrano and Arie Perliger, The Conversation, “‘This will not end here’: A scholar explains why Charlie Kirk’s killing could embolden political violence,” 11 September 2025: theconversation.com/this-will-not-end-here-a-scholar-explains-why-charlie-kirks-killing-could-embolden-political-violence-265060.

[6] Aaron Katersky and Sasha Pezenik, ABC News, “Alleged arsonist targeted Pennsylvania Gov. Josh Shapiro over Palestine, search warrant says,” 16 April 2025: abcnews.go.com/US/alleged-arsonist-targeted-pennsylvania-gov-josh-shapiro-palestine/story?id=120860365.

[7] Pierre Thomas, Aaron Katersky, Josh Margolin, Jack Date, Luke Barr, T. Michelle Murphy, Jon Haworth, and Megan Forrester, ABC News, “2 Israeli Embassy staffers killed in ‘act of terror’ in Washington, DC,” 22 May 2025: abcnews.go.com/US/2-shot-fbi-field-office-washington-dc/story?id=122059162.

[8] Justin A. Hinkley and Kelly House, Bridge Michigan, “FBI: Grand Blanc shooting was ‘targeted’ attack on Mormons: What we know,” 3 November 2025: bridgemi.com/michigan-government/reports-grand-blanc-attacker-held-grudges-against-mormons-what-we-know/; Tim Arango Anushka Patil and Thomas Fuller, New York Times, “Michigan Church Attacker Is Said to Have Held a Grudge Against Mormons,” 29 September 2025: www.nytimes.com/2025/09/29/us/michigan-church-attack.html?unlocked_article_code=1.708.A75l.RXlNbxn-8x5g&smid=url-share.

[9] Michael Warren and John McCormack, The Dispatch, “Conservatism at a Crossroads,” 7 November 2025: thedispatch.com/article/heritage-foundation-kevin-roberts-tucker-carlson-nick-fuentes/.

[10] Maria Wiering, OSV News, “Vance spars with US bishops over their pushback on Trump’s immigration policy,” 26 January 2025: www.osvnews.com/vance-spars-with-us-bishops-over-their-pushback-on-trumps-immigration-policy/. 

[11] Kate Scanlon, OSV News, “Vance spars with US bishops over their pushback on Trump’s immigration policy,” 26 January 2025: www.osvnews.com/vance-spars-with-us-bishops-over-their-pushback-on-trumps-immigration-policy/. 

[12] Jonah McKeown, Catholic News Agency, “Cardinal Dolan: Vance’s remarks on bishops and immigration ‘scurrilous,’ ‘very nasty’,” 29 January 2025: www.catholicnewsagency.com/news/261889/cardinal-dolan-vance-s-remarks-on-bishops-and-immigration-scurrilous-very-nasty.

[13] Kate Scanlon, OSV News, “Audited financials show claims the church profits from refugee work ‘just wrong’,” 31 January 2025: www.osvnews.com/audited-financials-show-claims-the-church-profits-from-refugee-work-just-wrong/.

[14] See America Prays: An Invitation to Prayer & Rededication of the United States as One Nation Under God: www.whitehouse.gov/america250/america-prays/. 

[15] Presidential Message on the Feast of Saint Michael the Archangel, 29 September 2025: www.whitehouse.gov/briefings-statements/2025/09/presidential-message-on-the-feast-of-saint-michael-the-archangel/; Presidential Message on the Feast of the Immaculate Conception, 8 December 2025: www.whitehouse.gov/briefings-statements/2025/12/presidential-message-on-the-feast-of-the-immaculate-conception/. 

[16] See, for example, Noah Hurowitz, The Intercept, “Official Propaganda for Caribbean Military Buildup Includes ‘Crusader Cross’,” 9 December 2025: theintercept.com/2025/12/09/crusader-cross-boat-strikes-propaganda-military/.

[17] Madalaine Elhabbal, Catholic News Association, “‘Bring Jesus up!’: Sean Duffy rallies merchant marines over controversial painting move,” 10 April 2025: www.catholicnewsagency.com/news/263299/bring-jesus-up-sean-duffy-rallies-merchant-marines-over-controversial-painting-move. 

[18] Tim Busch, National Catholic Register, “The Trump Administration: More Catholic Than You Know,” 6 March 2025: www.ncregister.com/commentaries/trump-administration-catholic-christian-faith. 

[19] Ross Douthat, New York Times, “Why Is Christianity So Hard to Find in the Trump Administration?” 6 December 2025: www.nytimes.com/2025/12/06/opinion/trump-hegseth-christian-nationalism.html?unlocked_article_code=1.F1A.YR_U.ZnUGF19Pd2oo&smid=url-share. 

[20] Tennessee v. Cardona, 762 F. Supp. 3d 615 (E.D. Ky. 2025), as amended (Jan. 10, 2025); Carroll Indep. Sch. Dist. v. United States Dep’t of Educ., No. 4:24-CV-00461-O, 2025 WL 1782572 (N.D. Tex. Feb. 19, 2025).

[21] Tennessee v. Kennedy, No. 1:24CV161-LG-BWR, 2025 WL 2982069 (S.D. Miss. Oct. 22, 2025).

[22] U.S. Conf. of Cath. Bishops v. Equal Employment Opportunity Commission, No. 2:24-cv-00691-DCJ-TPL, slip op. at ___ (W.D. La. Sept. 3, 2025) (order granting preliminary injunction pending appeal); Cath. Benefits Ass’n on behalf of Diocese v. Lucas, No. 1:24-CV-00142, 2025 WL 1144768 (D.N.D. Apr. 15, 2025).

[23] Pennsylvania v. Trump, 795 F. Supp. 3d 607 (E.D. Pa. 2025).

[24] Roman Cath. Diocese of Albany v. Harris, 145 S. Ct. 2794, 222 L. Ed. 2d 1084 (2025).

[25] Illinois Baptist State Ass’n v. Dep’t of Ins., 2025 IL App (4th) 241282-U.

[26] Cedar Park Assembly of God of Kirkland, Washington v. Kuderer, 146 F.4th 885 (9th Cir. 2025).

[27] Philadelphia Yearly Meeting of Religious Soc’y of Friends v. U.S. Dep’t of Homeland Sec., 767 F. Supp. 3d 293 (D. Md. 2025); Mennonite Church USA v. U.S. Dep’t of Homeland Sec., 778 F. Supp. 3d 1 (D.D.C. 2025).

[28] Pineros y Campesinos Unidos del Noroeste v. Noem, No. 6:25-cv-00699-AA, Compl. (D. Or. Apr. 28, 2025).

[29]Coalition for Spiritual & Public Leadership v. Noem, No. ___, Compl. (N.D. Ill. Nov. 19, 2025).

[30] Paxton v. Annunciation House, No. 24-0573, 2025 WL 1536224 (Tex. May 30, 2025).

[31] In re Office of the Attorney General of the State of Texas, No. 15-24-00091-CV, 2025 WL __, (Tex. App.—15th Dist. Aug. 4, 2025) (orig. proceeding) (mandamus denied).

[32] Bishop Kevin Rhoades and Dan Florin, South Bend Tribune, “Showing up with faith, compassion, despite distraction,” 3 December 2025: www.southbendtribune.com/story/opinion/columns/guest/2025/12/03/showing-up-with-faith-compassion-despite-distraction-opinion/87571677007/. 

[33] Lee v. Poudre Sch. Dist. R-1, No. 25-89, 2025 WL 2906469 (U.S. Oct. 14, 2025); Doe No.1 v. Bethel Loc. Sch. Dist. Bd. of Educ., No. 23-3740, 2025 WL 2453836 (6th Cir. Aug. 26, 2025); Foote v. Ludlow Sch. Comm., 128 F.4th 336 (1st Cir. 2025).

[34] Kluge v. Brownsburg Cmty. Sch. Corp., 150 F.4th 792 (7th Cir. 2025), Defending Educ. v. Olentangy Loc. Sch. Dist. Bd. of Educ., 158 F.4th 732 (6th Cir. 2025); Theis v. Intermountain Educ. Serv. Bd. of Directors, No. 2:25-CV-00865-HL, 2025 WL 2406871 (D. Or. Aug. 20, 2025)

[35] Roake v. Brumley, 141 F.4th 614 (5th Cir.), reh'g en banc granted, opinion vacated, 154 F.4th 329 (5th Cir. 2025); Nathan v. Alamo Heights Indep., 795 F. Supp. 3d 910 (W.D. Tex.), hearing en banc ordered sub nom. Nathan v. Alamo Heights Indep. Sch. Dist., 157 F.4th 713 (5th Cir. 2025); Stinson v. Fayetteville Sch. Dist. No. 1, No. 5:25-CV-5127, 2025 WL 2619159 (W.D. Ark. Sept. 10, 2025). 

[36] St. Dominic Acad. v. Makin, 744 F. Supp. 3d 43 (D. Me. 2024); Crosspoint Church v. Makin, No. 1:23-CV-00146-JAW, 2024 WL 2830931 (D. Me. June 4, 2024); St. Mary Cath. Par. in Littleton v. Roy, 154 F.4th 752 (10th Cir. 2025); Darren Patterson Christian Acad. v. Roy, 765 F. Supp. 3d 1194 (D. Colo. 2025).

[37] St. Mary Cath. Parish, 154 F.4th at 775 (2025).

[38] Etienne v. Ferguson, 791 F. Supp. 3d 1226, 1246 (W.D. Wash. 2025); see also Orthodox Church in America v. Ferguson, No. 2:25-cv-00209-RLP, slip op. (E.D. Wash. July 25, 2025) (order granting stipulated preliminary injunction).

[39] Etienne v. Ferguson, No. 3:25-cv-05461-DGE, slip op. (W.D. Wash. July 15, 2025) (order granting stipulated motion to enter preliminary injunction and stay proceedings).

[40] McRaney v. N. Am. Mission Bd. of the S. Baptist Convention, Inc., 157 F.4th 627, 641 (5th Cir. 2025); see also Union Gospel Mission of Yakima v. Brown, 162 F.4th 1190, 1201-08 (9th Cir. 2026) (applying church autonomy doctrine to protect religiously motivated hiring decisions by religious employers).

[41] O'Connell v. United States Conf. of Cath. Bishops, 134 F.4th 1243 (D.C. Cir. 2025) (reh’g en banc denied).

[42] O’Connell v. United States Conf. of Catholic Bishops, No. 23-7173, 2025 WL 3082728, at *1-2, *6-17 (D.C. Cir. Nov. 4, 2025) (Rao, J., dissenting, and Walker, J., concurring).

[43] Huntsman v. Corp. of the President of the Church of Jesus Christ of Latter-Day Saints, 127 F.4th 784, 798 (9th Cir. 2025) (Bress, J., concurring); see also id. at 812-14 (Bumatay, J., concurring).

[44] Gaddy v. Corp. of the President of the Church of Jesus Christ of Latter-day Saints, 148 F.4th 1202, 1211-16 (10th Cir. 2025).