The document examines released time education programs in U.S. public schools. It provides background on the history and legal foundations of these programs, which allow students to leave school for religious instruction with parental permission. While upheld by the Supreme Court under certain conditions, critics argue these programs promote particular religious viewpoints, are divisive, and exert pressure on students. The conclusion cites a Bible passage about making disciples of all nations.

1. ICCTE Biennial Conference
Azusa Pacific University
An Examination of Released Time Education
Programs and U.S. Public Schools
James A. Swezey
Liberty University

2. Released Time Bible Education Programs and U.S. Public Schools
Released Time Education (RTE) is a general
name given to programs that afford parents
the opportunity to grant their children
permission to leave the local public school
campus during regular school hours in order to
receive religious instruction.

3. Released Time Bible Education Programs and U.S. Public Schools
• A few states even allow students to receive academic
credit.
• Typically established by private, religiously-affiliated
organizations.
• A variety of religious traditions are represented
including Protestant, Catholic, Latter Day Saints
(Mormons), Jewish, Muslims, and Hindus (Giess &
Moore, 2009).

4. Released Time Bible Education Programs and U.S. Public Schools
Released Time Bible Education (RTBE) is a name commonly
ascribed to programs established by evangelical Christian
organizations.
•Bible presented from a sectarian perspective
•Gospel message presented
•Children proselytized openly

5. Released Time Bible Education Programs and U.S. Public Schools
According to Baer and Carper (2000), “A released-time
model honestly accepts the fact that we are a
religiously diverse society and that trying to teach
religion/spirituality (or even about religion/spirituality)
to all students in common classes will inevitably lead to
distortion and indoctrination” (p. 613).

6. Released Time Bible Education Programs and U.S. Public Schools
• RTBE programs remain largely unknown
• Programs are concentrated in the South and
Midwest, but also exist along the West and East
Coasts

7. Released Time Bible Education Programs and U.S. Public Schools
Dierenfield (1973) examined a national sample of
school districts (N = 830), and discovered
approximately 33% of school superintendents
reported release time programs in their districts.
Dierenfield in reported similar studies reported
26% of schools in 1966 and 30% in 1960.

8. Released Time Bible Education Programs and U.S. Public Schools
Depending upon what programs are counted, and
from what religious traditions, RTE enrollment
numbers range from 250,000 (Johnson, 2002) to
600,000 (Osgood, 1999; Vinson, 2005). The most
widely publicized claims regarding RTBE enrollment
are that there are over 1,000 programs serving
250,000 students across the United States.

9. Historical Foundations
First discussed in 1905 at a school conference in
New York City.
Earliest RTE program is credited to the Church of
Jesus of Latter-day Saints in 1912 (Strader, 2009).
Evangelicals claim it was operationalized in 1914
under the leadership of Dr. William Wirt
(1874-1938).

10. Historical Foundations
LDS commitment dates back to its founder, Joseph
Smith, in 1832 (Strader, 2009).
By 1890, most schools in LDS communities were
state-run and eliminated religious instruction.
The LDS Church began its first RTE program by
“erecting a small building across from Granite High
School in South Salt Lake City, and established it as
the first LDS seminary” (Strader, 2009, p. 15) .

11. Historical Foundations
2012 LDS records report 122,782 students
worldwide enrolled in released-time seminaries
(Church of Jesus Christ of Latter-day Saints, 2006, p. 2).
The LDS operate the most centralized, unified form
of RTE.

12. Historical Foundations
In 1922 RTE programs were active in 23 states,
serving 40,000 students from 200 school districts.
By 1932, 30 states had programs in 400
communities with 250,000 students.

13. Historical Foundations
In 1942 participation reached 1.5 million students in
46 States.
Released Time peaked in 1947 with 2 million
students enrolled in 2,200 communities.

14. Legal Foundations
According to Hodge and Cuddeback (2010),
•7 states generally required state cooperation upon
request
•17 recognized RTE but didn’t require cooperation
•Remaining 26 states had no specific statutes
related to RTE

15. Legal Foundations
Some of the key court cases include
•Lanner v. Himmer (1981)
•H.S. v. Huntington County Community School
Corporation (2009)
•C.S. v. Fort Wayne Community Schools (2010)
•Moss v. Spartanburg (2011)

16. Legal Foundations
McCollum v. Board of Education (1948)
• In 1940 Jewish, Roman Catholic, and Protestant
faiths established Champaign Council on
Religious Education
• Offered classes students in grades four to nine
• Parental permission required
• Once a week classes ran from 30-45 minutes

17. Legal Foundations
McCollum v. Board of Education (1948)
• Taught by Protestant teachers, Catholic priests,
and Jewish rabbis
• Reports of presence or absence were to be made
to their secular teachers

18. Legal Foundations
McCollum v. Board of Education (1948)
Justice Black delivered the Court’s 8-1 majority
opinion finding in favor of McCollum.
The Court warned, “The extent that aspects of these
programs are open to Constitutional objection, the
more extensively the movement operates, the more
ominous the breaches in the wall of separation” (¶
225).

19. Legal Foundations
McCollum v. Board of Education (1948)
The Court ruled that “religious education so
conducted on school time and property is patently
woven into the working scheme of the school. The
Champaign arrangement thus presents powerful
elements of inherent pressure by the school system
in the interest of religious sects” (¶ 228).

20. Legal Foundations
McCollum v. Board of Education (1948)
Justice Black further wrote, “The children belonging
to these non-participating sects will thus have
inculcated in them a feeling of separatism when the
school should be the training ground for habits of
community” (¶ 228).

21. Legal Foundations
McCollum v. Board of Education (1948)
Justice Reed attacked the Court’s majority on
several fronts. “From the holding and the language
of the opinions, I can only deduce that religious
instruction of public school children during school
hours is prohibited. The history of American
education is against such an interpretation of the
First Amendment” (¶ 241).

22. Legal Foundations
Zorach v. Clauson (1952)
In its 6-3 decision, the Court found that programs
Constitutional.
•Established off-campus
•Operating with parental consent
•Not supported in any manner by the taxpayer
funds

23. Legal Foundations
Zorach v. Clauson (1952)
Plaintiffs argued, “The weight and influence of the school is put
behind a program for religious instruction; public school
teachers police it, keeping tab on students who are released;
the classroom activities come to a halt while the students who
are released for religious instruction are on leave; the school is a
crutch on which the churches are leaning for support in their
religious training; without the cooperation of the schools this
“released time” program, like the one in the McCollum case,
would be futile and ineffective.” (¶ 310)

24. Legal Foundations
Zorach v. Clauson (1952)
The Court found case differed from McCollum:
•No religious instruction in public school classrooms
•No expenditure of public funds
•No coercion to encourage or pressure students

25. Legal Foundations
Zorach v. Clauson (1952)
The Court found, “the present record indeed tells us
that the school authorities are neutral in this regard
and do no more than release students whose
parents so request” (¶ 311).

26. Legal Foundations
Zorach v. Clauson (1952)
Justice Black dissented vehemently:
“I see no significant difference between the invalid
Illinois system and that of New York here sustained.
Except for the use of the school buildings in Illinois,
there is no difference between the systems which I
consider even worthy of mention” (¶ 316).

27. Legal Foundations
Zorach v. Clauson (1952)
Justice Frankfurter reasoned, “The unwillingness of
the promoters of this movement to dispense with
such use of the public schools betrays a surprising
want of confidence in the inherent power of the
various faiths to draw children to outside sectarian
classes—an attitude that hardly reflects the faith of
the greatest religious spirits” (¶ 323).

28. Discussion
McCollum and Zorach
“In McCollum, students participated in (1) state-
approved religious exercises (2) in school (3) upon
parental consent, but in Zorach, students
participated in (1) purely private religious exercises
(2) off campus (3) upon parental request”
(McWilliams, (2002, ¶ 9, original italics).

29. Discussion
Release-time programs will generally be upheld:
•No punishing absentees from the released time
programs with truancy sanctions
•School authorities remain neutral
•Do not coerce attendance
•Do not bring instruction into the public school
(Lofaso, 2009)

30. Discussion
Release-time programs will generally be upheld:
•Avoid the use of public funds
•Cannot operate on school grounds
•Avoid being promoted, endorsed, or otherwise
favored by the public school and its faculty
(Vinson, 2005)
•Parental permission

31. Discussion
Lithwick (2005) posited several criticisms:
2)Students who didn’t attend classes were
ostracized,
3)Classes subtract from classroom time
4)Discriminate against those who aren't Christians
5)Promote an evangelical, denominational, or
sectarian viewpoint.

32. Discussion
Pfeffer (1948) surmised four chief dangers:
2)Introduces religious differences within the public
schools and is therefore divisive and is a threat to
separation of Church and State
3)It exerts unfair pressure on students to enroll
religious classes

33. Discussion
1) Jewish children are tempted to attend Christian
classes to avoid disclosing their Jewish faith
2) Religious instruction is often accepted as a
satisfactory substitute for real religious
instruction even though the amount imparted
under released time is negligible.

34. Conclusion
Baer and Carper (2000) wrote, “Today, evangelical
Christians and traditional Catholics constitute a
problem for liberal education, for they refuse to see
the Gospel as just one religious truth among many”
(p. 601).

35. Conclusion
“Then Jesus came to them and said, ‘All authority in
heaven and on earth has been given to me.
Therefore go and make disciples of all nations,
baptizing them in the name of the Father and of the
Son and of the Holy Spirit, and teaching them to
obey everything I have commanded you. And surely
I am with you always, to the very end of the age’”
(Matthew 28:18-20, NIV).