Peloza v. Capistrano Unified School District (1994)
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Evolution & Creationism: Is Evolution a Religion?
Exploring: Church & State > Court Decisions > Evolution & Creationism
Some of those who object to evolution for religious reasons also argue that evolution itself is a religion or, sometimes, that it is a part of secular humanism which itself is a religion. Therefore, they conclude, teaching evolution in public schools violates the Establishment Clause (because it imposes a religion on students) and the Free Exercise Clause (in particular, of the teachers who are forced to teach it). But are such arguments valid? Is evolution a religion?
Background Information
High school biology teacher John E. Peloza brought action against the Capistrano School District, claiming that the school district's requirement that he teach "evolutionism," as well as a school district order barring him from discussing his religious beliefs with students, were infringements both on his rights to free speech and his rights to free exercise of religion.
According to Peloza, "evolutionism" is a religion and therefore being forced to teach it violated the Establishment Clause of the First Amendment. In Peloza's view, Evolutionism is an historical, philosophical and religious belief system, but not a valid scientific theory. Evolutionism is one of "two world views on the subject of the origins of life and of the universe." The other is "creationism" which also is a "religious belief system."
The belief system of evolutionism is based on the assumption that life and the universe evolved randomly and by chance and with no Creator involved in the process. The world view and belief system of creationism is based on the assumption that a Creator created all life and the entire universe.
Peloza also claimed that the district conspired to destroy and damage his professional reputation, career and position as a public school teacher. He had been reprimanded in writing for proselytizing to students and teaching religion in the classroom - according to him, they did this because they were hostile towards practicing Christians.
A District Court had dismissed the suit and awarded attorney fees to the school district, but Peloza appealed.
Court Decision
The Ninth Circuit Court of Appeals completely rejected all of Peloza's arguments. First, they noted that his claims were not entirely consistent - in some places he claimed that it is unconstitutional for the school district to require him to teach, as a valid scientific theory, that higher life forms evolved from lower ones, but at other times he claimed the district was forcing him to teach evolution as fact.
The Court also noted what just about every creationist seems to miss: the fact that evolution is about how life has developed and has nothing to do with the origins or development of the universe itself...
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