An investigation of some aspects and implications of released-time for religious education
by James W Zottnick
A THESIS Presented to the Division of Education and the Graduate Division in Partial Fulfillment of
the Requirement for the Degree of Doctor of Education
Montana State University
© Copyright by James W Zottnick (1960)
Abstract:
The thesis Is entitled An Investigation of Some Aspects and Implications of Released-Time for
Religious Education. By way or orientation, "released-time" is the designation assigned to a period of
religious education that falls within the hours of a recognised public-school day. The pupils who desire
to participate are excused for part of the school day to go to a nearby church for religious instruction,
Released-time is designed to bridge the gap between the limitations of the public school in teaching
religious belief, and the inadequacies of traditional church agencies in meeting the spiritual needs of
children.
The author had several purposes In undertaking the study. First, to reveal the historical background and
movements that created a favorable environment for the beginning of released-time. Second, to reveal
the rational foundation that gave meaning and direction to the movement. Third, to analyse some of the
legal decisions and ramifications of these decisions to determine the present legal status of
released-time.
The procedure followed in the study consisted of a survey of the literature available in the areas of
religion and public education. Direct mail inquiries were sent to each state that has taken legislative
action regarding the released-time program, A sampling of letters to various city church councils with
active released-time programs produced some pertinent information.
On the basis of the study the following conclusions were drawn regarding the released-time program.
Religion expressed in sectarian, theological, doctrinal, or dogmatic terms cannot be introduced into the
public school without endangering the principle of church-state separation. When properly established,
the released-time plan can provide religious instruction and experiences on a sound educational basis
without violating the principle of church-state separation.
In summary, there are several possible ways In which the released-time program could be emphasized
in a community.
First, the desire for such a program must be established as far as the community is concerned. This
means that active support must be forthcoming from church, school, and community. Second, the type
of program to be offered must be agreed upon, whether denominational, interdenominational, or
community type program. Last, solid financial backing must be assured to obtain qualified, trained
personnel and good instructional equipment. 
AN INVESTIGATION OP SOME ASPECTS AND IMPLICATIONS 
OF RELEASED-TIME FOR RELIGIOUS EDUCATION
by
JAMES W. ZOTTNICK
A THESIS
Presented to the Division of Education 
and the Graduate Division 
in
Partial Fulfillment of the Requirement 
for the Degree of 
Doctor of Education 
at
Montana State College
Approved;
Head, #ajor Department
Bozeman, Montana 
January, I960
Ii
CURRICULUM VITAE 
James W. Zotfcnick
PERSONAL
Date and place of Birth; April 19# 1930# Missoula, Montana. 
Marital Status; Married. Two Daughters.
EDUCATION
19^3 A.B. Degree from Cascade College, Portland, Oregon.
1956 B.D. Degree from Western Evangelical Seminary, 
Jennings Lodge, Oregon.
1958 M.A. Degree from Montana State College,
Bozeman, Montana.
EXPERIENCE
1953-1956 Ministerial work in Methodist Church, 
Ridgefield, Washington.
1956-1958 Ministerial work in Evangelical United Brethren 
Church, Bozeman, Montana.
1957 Instructor in Religion. Montana State College,
Bozeman, Montana.
1959-1960 Assistant Professor of Education. Westmar Col­
lege, Le Mars, Iowa.
141116
ill
TABLE OP CONTENTS
Chapter Page
I. INTRODUCTION 7
Purposes of the Study * * . # . * » . . # *  24 
Procedure of the Study » « * * , * . . # * * * *  14 
Studies in the Field • • • • • • • * • • • • • •  17
II. HISTORICAL BACKGROUND OF RELEASED-TIMB........  21
The Seedbed of Released-Tlme • • • • • • • • • •  21
From Sectarianism to Secularism * * * * # , »  21
Forerunners of the Released-Time Program • • • 31
The Formative Years of Released-Time
(1905-1930) . * ..........................  39
More Recent Aspects of Releaaed-Time * * * * * *  49
The Progressive Years (1930-1947) • * • • • *  49
From Limelight to X-ray (1948-1952)........  51
The Program Forges Ahead * * * * * * * * * * *  53
Summary * * * * * * * * * * * * * * * * * *  62
III. THB PHILOSOPHY OF RELEASED-TIME.......... .. * 65
A Dilemma of Thwarted Spiritual Need • • • • • •  65
The Moral and Spiritual Needs of Children * * 66
Limitation of the Public School * * * * * * *  72
The Church and Released-Tlme 79
The Inadequacy of the Sunday School • • • • • 79
Released-Time Bridges the G a p ............ * 84
The Objectives of Christian Education * * * * 90
Summary * * * * * * * * * * * * * * * * * * * *  94
IV, SOME LEGAL RAMIFICATIONS OF RELBASED-TIMB * • • 97
Early Entanglements in Litigation • • • • • • •  97
A Hazy Court Focus • • * • • • • • • • • • • •  97
Iv
Chapter Pag®
State Court Deoislona 100
United States Supreme Court Decision. . . . . . . .  H O
A Legal "Red Light" (Vaahtl HeCollum Case). . . .  Ill 
A Legal "Green Light" (Zoraeh Case) . . . . . . .  12$
Summary 137
V. SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS lit-0
Summary . . . . . . . . . . . . . . . . . . . . . .  IyO
Conclusions lij-7
Recommendations . . . . . . . . . . . . . . . .  1$1
BIBLIOGRAPHY, 152
APPENDIX 168
Appendix Al 
Appendix Bt 
Appendix Ct 
Appendix Dt 
Appendix Bi
State Laws Regarding Weekday Religious
Education On Released-Time . . . . . .  169
Letter Sent to States for Released-
Time Inquiry . . . . . . . .  178
Letter Sent to Selected Cities for 
Released-Time Information. . . . . . .  179
First and Fourteenth Amendments to the 
Constitution of the United States. * * 180
A Statement by the Christian Education 
Leaders of Cooperating Protestant 
Bodies . . . . . . . . . . . . .  181
VACKNOWLEDGMENT
The completion of this study Involved the assistance 
and cooperation of a number of people. The Investigator wishes 
to thank Professor Alice Kruse and Professor Harvey Kluckhohn 
of the Westmar College faculty for the time and thought they 
most graciously gave In proofreading the manuscript. He Is 
also especially grateful for the valuable suggestions and crit­
icisms he received from his graduate committee.
The writer Is deeply appreciative for the work of his 
long-suffering wife who typed the manuscript and rendered sin­
cere encouragement throughout the study.
J.W.Z.
Vi
ABSTRACT
The thesis is entitled An Investigation of Some Aspects 
end Implications of Released-Tlne for Religious Education. By 
way or orientation, ^released-time" is the designation assign- 
ed to a period of religious education that falls within the 
hours of a recognised public-school day. The pupils who de­
sire to participate are excused for part of the school day to 
go to a nearby church for religious instruction, Released- 
time is designed to bridge the gap between the limitations of 
the public school In teaching religious belief, and the inade­
quacies of traditional church agencies in meeting the spiritu­
al needs of children.
The author had several purposes In undertaking the 
study. First, to reveal the historical background and move­
ments that created a favorable environment for the beginning 
of released-time. Second, to reveal the rational foundation 
that gave meaning and direction to the movement. Third, to an­
alyse some of the legal decisions and ramifications of these 
decisions to determine the present legal status of released- 
time.
The procedure followed in the study consisted of a sur­
vey of the literature available in the areas of religion and 
public education. Direct mail inquiries were sent to each 
state that has taken legislative action regarding the released- 
time program. A sampling of letters to various city church 
councils with active released-time programs produced some per­
tinent information.
On the basis of the study the following conclusions were 
drawn regarding the released-time program. Religion expressed 
in sectarian, theological, doctrinal, or dogmatic terms cannot 
be introduced into the public school without endangering the 
principle of church-state separation. When properly establish­
ed, the released-time plan can provide religious Instruction 
and experiences on a sound educational basis without violating 
the principle of church-state separation.
In summary, there are several possible ways in which the 
released-time program could be emphasized in a community.
First, the desire for such a program must be established as far 
as the community is concerned. This means that active support 
must be forthcoming from church, school, and community. Second, 
the type of program to be offered must be agreed upon, whether 
denominational,"interdenominational, or community type program. 
Last, solid financial backing must be assured to obtain quali­
fied, trained personnel and good instructional equipment.
CHAPTER I 
INTRODUCTION
Education and religion have historically been closely 
associated in American life. Since the search for religious 
freedom was a driving force that brought many colonists to the 
shores of America, it was not surprising that early institu­
tions bore out the religious character. It would be naive to 
infer that the settlers were all of one mind in the matter of 
religious beliefs. Each colony reflected its own separate 
background of religious history and belief and developed its 
institutions accordingly.
In view of the religious background of early American 
colonists, nothing was more natural than that the first schools 
should follow the pattern which their founders had known over­
seas. Cubberly pointed out that as the church was the central 
Institution of the colonial community, the school was motivated 
by religious aims. So vital were these church schools consid­
ered to the welfare of the government and so closely were they 
associated with the government "town meeting" that they were 
financed wholly or in part out of public funds.1 This practice 
caused no debate at the time, since the individual communities 
were substantially homogeneous in their religious make-up.
1Cubberly, E. P., Public Education in the Unlted States.
7
p. 171
Later on, when populations became more heterogeneous, as sects 
multiplied, and especially after the appearance of the tax- 
supported public schools It became increasingly evident that 
public financial aid should no longer be continued to sectarian 
schools# It was out of this struggle and clash of sectarian 
belief and organization that the American public school system 
developed#
The disavowal of public support for sectarian education 
was buttressed by the constitutional doctrine of church-state 
separation. The principle of separation of church and state 
has become one of the fundamental concepts of government In 
the United States. Perhaps It could be considered one of the 
greatest contributions to culture made by the United States, 
and the most distinctive gift to the Ideas of government. 
Whereas a close alliance of church and state Iiad been regarded 
by other nations as a necessity, the United States government 
deliberately took action to divest itself of all legislative 
control over religion. The founding fathers believed that any 
Interference with religion by the government would constitute 
an unwarranted encroachment. These men were concerned that 
every religion maintain Itself by the excellence of Its own 
doctrines, since any alliance between church and state might 
prove detrimental to the people and to the safety of the new 
government. Thus church-state separation has been interpreted 
as meaning that there shall be no ecclesiastical control of
8
9the political functions of government and there shall be no 
political supervision or dictation In the ecclesiastical 
sphere# This Is not to say that the church has no obligations 
to the state or that the state must remain aloof to the inter­
ests of religion# Nor does it imply that religion shall say 
nothing regarding the operations of government# The principle 
signifies that the church as an institution and the state as 
an institution must retain their respective autonomies in such 
a fashion that neither controls the other#
The question is posed: What are the implications of
church-state separation within the field of education? Within 
the past three hundred years the American people have evolved 
the public school as a unique institution, expressive of the 
American way of life# It is a democratic institution, being 
responsive to the character of the community it serves and 
being largely controlled and managed by the local community.
It is a free school in the recognition that a government which 
is based upon the assumption that human intelligence la capa­
ble of ordering human affairs must not neglect any measures 
which might increase the capacities of that intelligence#
Thus, at public expense, it assists young people of varied 
abilities and diverse backgrounds to develop their talents and 
realize their highest potential# It is a secular school, 
searching for ways in which ideals common to the American way 
of life can be taught without affiliation with specific
10
religious organizations* As Indicated by Lee, with the early 
multiplication of religious sects in America, it became appar­
ent that the educational system could not be public and at the 
same time be the agency for the dissemination of sectarian
doctrine*2
The storm center of the church-state controversy has 
been the debated question of religious teachings and observ­
ances in the public schools and also the vexing problem of 
state aid, directly or indirectly, to schools which are not 
tax-supported* Individuals have contended that any sort of 
teaching about religion or the reading of the Bible In the 
schools is a violation of the basic American principle of the 
separation of church and state* Yet, as noted by Johnson, how 
can public education, in accord with its function of putting 
each generation in possession of its full cultural heritage, do 
justice to the religious phase of that heritage without doing 
violence to religious liberty as constitutionally safeguarded 
in the First Amendment to the American Constitution?^ The edu­
cative process has a unitary quality which makes a dualism of 
the secular and the religious unrealistic* It Is Indeed diffi­
cult to exclude religious subject matter from an educational
p
Lee, 0* C., Education in Modem America, p* 13$.
3Johnson. Fe B*. American Education and Religion.
P* 187.
11
program without warping it.^
Of the problems confronting American education perhaps 
none is of graver consequence than the question regarding moral 
and spiritual values as they relate to the scientific and his­
toric values which the public schools of today assign central­
ity. This problem is at least as Important as those of disci­
pline, increased birth rate, inadequate facilities, and other 
vital issues on the educational scene. Perhaps, as noted by 
Johnson, there are those who would contend that there is no 
real issue at all, that It is artificially created by religious 
leaders. However, it Is seen that an objective problem does 
exist on this point because of conflicting concerns and demands 
in a community.^
Theories have been put forth arguing for the reintroduc­
tion of religious instruction into the public school on the 
basis that if religion fails, democracy is bound to fail as 
well. Some have contended that democracy needs the ballast of 
religion, as indicated in the following statementI
The public school is confessedly and deliberately 
secular. I am bound, therefore, to lay on the doorstep 
of our educational system the prime responsibility for 
the decline of religion and the steady advance of secu­
larism, another name for atheism, in American society... 
Protestant children in public schools are under an in­
fluence with which the churches cannot compete and which
^Johnson, A. W., and Yost, P. H., Separation of Church 
and State in the United States, p. !j.9.
5Johnson, P. E., American Education and Religion, p. 3.
12
they cannot counteract. The public school presents the 
church with a generation of youth whose minds have been 
cast in a secular mold,,. You can educate every child In 
America in the subjects taught In our public schools and 
yet our democracy may go down,,. The last stand of democ­
racy will be In the realm of the people’s faith,,. Democ­
racy Is Christianity’s gift to the world. And when Chris* 
tlanlty fails, democracy falls. The only solution Is to 
open public schools to Include teachings of religion.6
While it is recognized that the ancient Greeks conceived 
of democracy before the Christian movement began, present-day 
democracy contains much of the Christian tradition. Some 
scholars even contend that present-day democracy Is based on 
religion and to separate the two would be a mlstake. While 
this position Is not entirely defensible, it deserves considera­
tion. In 19U2 seven Princeton University professors Issued a 
statement contending for a spiritual basts of democracy, in the 
following words;
Democratic institutions and cultural activities 
rest on the assumption that man, while a part of nature, 
is a spiritual being and that his highest good should be 
defined in terms of spiritual values. The major problem 
which confronts us at this time, therefore, is not mere­
ly the defense of democracy and Its culture, but a deeper 
understanding of and commitment to the spiritual concep­
tion of man upon which democracy Is based.7
In 1903 a substantial body of laymen, religious leaders, 
and educators became concerned about the Insignificant posi­
tion assigned to religious education within the public
^Hav. C. I.., The Blind Spot In American Public Education,
— *—*— — — * —"—**— ***— *******— —*^*— **— *— *— *—* —*— ******—****— — ***—**—****—**— **M*WM#r
p. 28.
Thayer, V. T., HeliRlon In Public Education, p. 103.
7
13
schools*^ This group held fast to the conviction that public 
education free from sectarian control was fundamentally right 
In the realization that separation of church and state meant 
religious liberty. However, it was held that religious educa­
tion was too valuable an influence to be entirely disregarded 
by the public school. The attempt to resolve this difficulty 
resulted in efforts to promote a cooperative arrangement 
whereby church and public school, each remaining independent 
in its own sphere, would provide to public-school children 
some sort of religious education experience. A plan was de­
vised whereby the public school schedules of children were so 
arranged that the public school could "releasethem to attend 
classes in religion. This germ idea proved the beginning of 
the significant movement of released-time for religious educa­
tion.
In beginning the study, it was the author*s belief that 
the released-time program enabled the church to make a distinct 
contribution to the cardinal principle of character develop­
ment in the American public-school system. Further, it was 
held that released-time could provide religious instruction on 
a sound educational basis. Finally, the author believed that
®Thla group, known as the "Religious Education Associa­
tion," was organized in 1903. It was an interdenominational 
group composed of Protestant, Roman Catholic, and Jewish 
leaders. The Association was designed to combine the talents 
of religious leaders and professional educators. See Cope,
H. F., Week-Day Religious Education, pp. 6-8.
as the released»tlme program recognized that religion was a 
week-day experience of concern along with school work, play, 
and other week-day activities. It would continue to expand In 
Its outreach*
14
Purposes of the Study
The purposes of the study were four-foldt
I* To reveal, in juxtaposition, the historical movements 
that created a favorable environment enabling the 
birth and Impetus of the movement known as released- 
time,
2* To reveal and clarify the philosophy or rational
foundation that gave meaning and direction to the re- 
leased-time movement*
3* To find and analyse some of the legal pronouncements 
and ramifications of the program, at the state and 
federal level, and to determine the present legal 
status and charter of operation,
4* To provide a source of Information for educators,
clergy, and laymn in clarifying purposes, plan of op­
eration, and goals of the program of released-tlme*
Procedure of the Study
The procedure followed In the study consisted of several 
steps the first of which Involved extensive reading In the 
broad fields of education and religion* The next step specifi­
cally consisted of reading in the specialized area of released- 
tlme, A tentative bibliography was prepared by consulting all 
the available bibliographical aids. The Cumulative hook Index 
and the Reader1S Guide proved Invaluable In this endeavor.
After all available materials were noted a rough outline was 
prepared, incorporating what were considered salient features 
of the released-tlme program.
The next step then consisted of a perusal of books, 
magazines, pamphlets, and periodicals in an effort to locate 
pertinent information. This information was recorded on note 
cards which were organized according to topical entries. The 
material was then sifted for information by a process of com­
parison and analysis, and then the Information deemed illu­
minating to the subject was selected for inclusion.
Direct mail inquiries were sent to the department of 
education of each state that has taken legislative action re­
garding the released-time program,9 These letters elicited a 
fruitful response and copies of legislation were received from 
each state Involved, Again, a bibliography of week-day reli­
gious education on released-time, compiled by the Department 
of Week-Day Religious Education of the Rational Council of the 
Churches of Christ in the United States of America, proved in­
valuable, Finally, a sampling of letters to various city 
church councils with active released-time programs produced 
some pertinent Information,10
The title of this work. Some Aspects and Implications 
of Released-Tltae for Religious Education, indicates a *10
^See Appendix A (pp. 169-177) for listing of states. 
Appendix B {pT 176) for letter sample,
10See Appendix C (p, 179) for letter sample.
15
16
concentration of endeavor# The emphasis of the study is fo­
cused on three areas of the released-time plan: (I) histori­
cal, (2) philosophical, and (3) legal# There are several 
reasons for this specific concentration:
1. It was recognised rather early that the subject of 
released-time was much too broad to lend Itself to 
an attempted complete analysis. It was readily 
recognized that it would be necessary to focus on 
certain segments of the movement#
2. There were certain limitations in available materi­
als that eliminated portions of the program as pos­
sible research areas.
3# Some Investigation had already been conducted in 
certain areas of released-time work, as indicated 
in the list of recent studies, and there was no wish 
to duplicate the efforts of other Investigators.
Iw Last, the areas of history, philosophy, and legal 
ramifications of released-time have maintained the 
author^ abiding interest# A genuine interest was 
sustained in locating the background, motivational 
factors, and present-day charter of operation for 
the released-time program# The subject was doubly 
interesting in that it enabled a denominational in­
terest and an academic pursuit to be fulfilled in 
one and the same effort#
The scope of the study has had to be strictly limited 
with very little attention given to the quality of the re­
leased-time program, except as it might be discussed inciden­
tally in connection with suggestions for improvement of the 
program. The reasons for this limitation include the lack of 
materials available in this particular area and the difficulty 
of achieving an objective evaluation. Since each community is 
an autonomous group in arranging a released-time program.
there are wide variations of practice and quality in these 
programs. Such matters as time schedules for releasing stu­
dents, types of programs offered by various communities (de­
nominational programs, interdenominational programs, or com­
munity programs), and the diversity of plans for financing 
these programs, vary with each community. It would be ex­
tremely difficult to make accurate statements regarding pro­
gram quality In the light of fragmentary reports and incon­
clusive evidence that is presently available, As there is a 
wide divergence of practice in the mechanical aspects of the 
program, and as the pursuit of this point would not substan­
tially contribute to the author's purpose, it was eliminated. 
The study was not intended to cover Informal, church-sponsored, 
week-day religious activities such as Youth for Christ or Bible 
Clubs, These were outside the scope of the author's purpose 
and as such were not included.
Studies in the Field
Several general studies of the released-tlme movement 
have been published in past years. A discussion of activities 
and problems entitled Week-Day Religious Education was edited 
by Cope in 1922. This book, published under the direction of 
the Religious Education Association, contains a survey and a 
series of studies concerning various aspects of the week-day
17
church school. The studies include aims, types of programs, 
and problems faced by the movement. The material formed the 
basis for discussion in the 1922 annual meeting of The Reli­
gious Education Association.
Forsyth wrote a book entitled Week-Day Church Schools 
that was published in 1930. The publication contains materi­
als regarding objectives, financing, organization, equipment, 
and curriculum for the new program. Forsyth made an effort to 
establish some high standards for the movement.
Weekday Classes in Religious Education by Davis, con­
tains a survey made by the United States Office of Education 
In 194-1. The study seeks to reveal the current practices for 
releasing children for week-day religious education during 
school hours. State provisions for week-day religious educa­
tion are cited.
The Research Division of the National Education Associa­
tion published a booklet in 1956 entitled The State and Sectar­
ian Education. This publication reviews the constitutional, 
statutory, and judicial bases which define relationships be­
tween church and state with respect to education. The publica­
tion provides an excellent source for summary material of the 
church-state controversy. A section of the booklet concerns 
Itself with the excusing of pupils for religious Instruction 
during school hours.
18
19
Shaver wrote a book entitled The Weekday Church School 
that was published In 1956» The book describes the organiza­
tion and administration of the week-day church school, its re­
lationship with other educational agencies of the church and 
community, ways of securing support, and standards set for Its 
success.
In addition to the studies reported In foregoing pub­
lications, a number of graduate studies have been made con­
cerning released-tlme. These studies have, for the most part, 
concerned themselves with the program as it existed in certain 
specific areas of the United States, such as Virginia, Texas, 
New York, and New Jersey, Several additional studies have 
been made concerning certain selected phases of the released- 
tlme program, A graduate thesis by McClure entitled Weekday 
Roll Ious Education at the High School Level was written in 
1951, The purpose of the study was to discover the approxi­
mate extent of week-day religious education at the high school 
level and to analyse current practices of organization, A 
condensation of the thesis by McClure has been published by 
the National Council of Churches of Christ in the United 
States of America, A thesis by Reid entitled Historical and 
Analytical Survey of Weekday Religious Education was written 
in 1951• Retd surveyed early practices In the field of re- 
leased-tlme and the stages of historical progress, Riggs 
wrote a thesis on the subject of released-time entitled
20
Standards of the Weekday Church School. This research paper 
arranged a series of checks for the evaluation of the program. 
The paper is concerned first with a brief history of the move­
ment of released-time and then serves to emphasize the need for 
certain definite standards to insure a quality program. Sug­
gested Procedures for an Evaluation of the Weekday Church 
School Series of the United Lutheran Church in America was 
written by Gilbert in 1955* This paper undertakes to arrange 
certain procedures for checking the validity of a denomination­
al series of released-time materials.
As previously indicated chapters two, three, and four 
are concerned respectively with historical background, philos­
ophy, and legal aspects of released-time. At this point con­
sideration will be afforded the historical background of re- 
leased-tlme as presented in chapter two.
21
HISTORICAL BACKGROUND OF RELEASED-TIME
The movement of releaaed-tlme for religious education 
did not spring Into full-flowered existence as an Isolated 
phenomenon, A well-defined series of events and circumstances 
preceded the movement and provided fertile ground for Its 
growth. The following material Is organized to afford con­
sideration of two areas of historical meaningI (I) The Seed­
bed of Released-Tlme, and (2) More Recent Aspects of Released- 
Time ,
CHAPTER II
The Seedbed of Released-Tlme
With the advent of the secular public school a vacuum 
was evident in the religious training of American youth. Ef­
forts were made to fill this vacuum with some type of reli­
gious training. The impetus of the released-tlrae program can 
partially be traced to the early American move from sectarian 
to secular education.
From sectarianism to secularism. The change from sec­
tarianism to secularism in the public schools of America Is 
fraught with historical significance. To appreciate the 
background for this move it is necessary to consider the 
frame work of early colonial education in terms of the Chris­
tian tradition of education.
22
Of the various Western-*- approaches to education, the 
Christian tradition can point to the longest continuous his­
tory. This ancient tradition has been the sacrosanct of the 
Roman Catholic Church for lf?00 years and promoted by the 
Protestant denominations for over J4.OO years.^ The early co­
lonial settlers who sailed to the shores of America brought 
with them some fairly well-defined and concrete ideas for the 
conduct of education In this Christian frame of reference.
The Puritan settlers of New England represented the Calvln- 
lstlc concepts of the Protestant Reformation. These people 
deeply believed In the priesthood of all believers and the 
capacity of each Individual to know and understand the will 
of God. A necessary prerequisite, however. Indicated that It 
was essential that each person be taught to read and under­
stand the Bible. As early Catholicism had restricted the use 
of the Scriptures to the clergy, Protestantism now committed 
Itself to the task of universal literacy for purposes of 
Bible reading.-^ Thus Protestantism emerged during the early 
colonial period as supporting and championing Increased edu­
cational opportunity.
^By "Western" is meant European and American approach­
es to education as contrasted with the Oriental approaches to 
education.
P
Lee, G. C., Education In Modern America, p. 72.
^Cubberley, E. P., Public Education In the United 
States, p. 13.
23
During the colonial period education had a pronounced 
religious fervor. In the school curriculum moral and spirit­
ual truths were constantly emphasized, and many schools be­
came in essence the servants of the church. The common ele­
mentary school curriculum consisted of reading, writing, 
arithmetic, prayers, singing of hymns, and catechism.^ The 
character of the early colonial school Is attested to by the 
instructions given a New Amsterdam teacher, Pletersen. In the 
year 1661« "He shall teach the children and pupils the Chris­
tian prayers, commandments, baptism. Lord's Supper, and the 
questions with answers of the catechism....Membership in 
the Established Church was required of the master of a school 
In Charleston, South Carolina In 1712, as brought out by 
Knight and Halil
That the person to be master of the said school 
shall be of the religion of the Church of England, and 
conform to the same, and shall be capable to teach the 
learned languages, that Is to say, Latin and Greek 
tongues, and to catechize and Instruct the youth in the 
principles of the Christian religion, as professed In 
the Church of England.&
The sectarian nature of colonial education is further wit­
nessed In an advertisement announcing the opening of King's
^De Young, C,, Introduction to American Public Educa­
tion. p. 16$.
5
Knight, Edgar, and Iiall, Clifton, Readings In Amer­
ican Educational History, p. 16.
6Ibld. p. 29.
(now Columbia) College in 1754» The advertisement indicated 
the eminent position of religion In the curriculum as follows*
24
The chief Thing that Is aimed at In this col* 
lege. Is, to teach and engage the children to know God 
In Jesus Christ, and to love and serve him In all So­
briety, Godliness and Righteousness of Life, with a 
perfect Heart and a willing Mind, and to train them In 
all virtuous Habits, and all such useful knowledge, as 
may render them creditable to their Families and Friends, 
Ornaments to their country, and useful to the publick 
Weal In their generations#'
As most of the early American colonists had sailed from 
lands where church and state were not separated, it is entire­
ly natural that this would be reflected In the American edu­
cational scene# The various settlements of Immigrants re­
flected the religion and education of the countries from 
which they migrated# One quirk In the colonial system was 
that many of these people in seeking freedom of religion for 
themselves were not willing to extend the same privilege to 
others of differing beliefs# The union of church and state 
that developed In the colonies was often fed by a critical, 
narrow, suspicious attitude toward others of different 
faiths#® The germ idea regarding the eventual separation of 
church and state was finding fertile soil in the minds of 
thoughtful leaders even at this time# 7
7Ibld.. p. 82.
D
uNational Education Association Research Bulletin.
Vol. XXXIV'j >ro# 4, December 19f>&, p# 170.
25
The American tradition of public responsibility for ed­
ucation was initiated by "Puritan Massachusetts" which led the 
other colonies in this regard. Colonial education was at 
first a voluntary movement on the part of local communities. 
However, with the passing of time it became evident that the 
voluntary efforts would not be sufficient to insure the degree 
of literacy desired by Puritan precept* Thus the colony of 
Massachusetts^ enacted the first legislation regarding educa­
tion in America known as the Massachusetts Law of I6I4.2* This 
law directed the officials of each town to determine period­
ically if parents and masters were attending to their educa­
tional duties and if children were being taught as directed. 
This law, ordering that all children should be taught to read, 
is noted as a distinctive Calvinistic contribution to the 
Western World,*0 The famous Massachusetts Law of 1647» com­
monly called the "Old Deluder Satan, Act," was enacted by the 
"Puritan colony" of Massachusetts to cover some gaps evidenced 
in the Law of 1642, This historic piece of colonial legisla­
tion stands as a milestone of educational progress in Amer­
ica,** It not only ordered establishment of a school system
Q
The colonial legislature of Massachusetts was at this 
time subordinate to the will of the church,
0Cubberly, E, P,, Public Education in the United 
States, p* 17*
**It being one cheife project of the ould deluder, Sa­
tan, to keepe men from the knowledge of the Scriptures, as in
26
but asserted the right of the colony to require communities, 
under penalty of a fine to comply.
In colonial life it soon became evident that harmony 
could not be achieved without general recognition of certain 
basic human rights. Public education struggled to become non- 
sectarian and to release itself from denominational shackles, 
Cubberley (1919) traced the early separation of church and 
state in terms of the disintegration of the New England town. 
The early colonial legislature placed the schools under the 
civil government because the taxes for their operation were 
received by civil government statute. Originally the civil
former times by keeping them in an unknowne tongue, so in 
these latter times by perswadlng from the use of tongues, yet 
so at least the true sence and meaning of the orlglnall might 
be clouded by false glosses of saint seeming deceivers, that 
learning may not be burled in the grave of our fathers in the 
church and commonwealth, the Lord assisting our endeavors*,.
It is therefore ordered, that every town©ship in this 
jurisdiction, after the Lord hath increased the number to 50 
householders, shall then forthwith appoint one within their 
towne to teach all such children as shall resort to him to 
write and read®, whose wages shall be paid either by the par­
ents or masters of such children, or by the inhabitants in 
gonrall, by way of supply, as the major part of those that 
order the prudentials of the towne shall appoint; provided, 
those that send their children be not oppressed by paying much 
more than they can have them taught for in other townes; and 
it Is further ordered, that where any towne shall increase to 
the number of 100 families or householders, they shall set up 
a grammar schools, the master thereof being able to instruct 
youth so farr as they shall be fitted for the university, pro­
vided, that if any towne neglect the performance hereof above 
one yeare, that every such towne shall pay 5 pounds to the 
next school® till they shall perform© this order, Cubberly,
E, P,, Readings in the History of Education, p, 299*
27
and religious government were one and the same, but with the 
erection of a town hall separate from the meeting-house, a 
small wedge was inserted. The discussion of school affairs 
then took place in the town hall Instead of the church, and 
town taxes were voted for the maintenance of the building in­
stead of church monies. The power to certificate school mas­
ters passed from the church to the town authorities early in 
the eighteenth century*^ Gradually church control of the 
schools gave way, and the secular communities began to assume 
their responsibility for public education.
The movement for separation of church and state had 
crystalized somewhat with the adoption of the Federal Con­
stitution in 1788. Freedom of worship was defined among the 
basic human rights in the following words! "Congress shall 
make no law respecting an establishment of religion, or pro­
hibiting the free exercise thereof.n Following the adoption 
of the Federal Constitution most state constitutions provided 
for the separation of church and political government and most 
of them eliminated any diversion of public funds for sectarian 
purposes. New Hampshire, in 1792, was the first state to 
adopt a constitutional provision prohibiting sectarian in­
struction.^ The New Hampshire constitution still contains 12
12Cubberly, E. P., Public Education in the United 
States, p. !4.5.
^De Young, 033. cit., p. 16$.
28
provisions which show a decided religious bias.*4
The move from the sectarian school to the secular 
school was a gradual process that proceeded unevenly in many 
parts of the country. However# as necessity in a democratic 
society gradually compelled the society to provide education 
for its children, sectarian differences made it increasingly 
evident that the education must be non-sectarian in nature. 
Cubberly pointed out that in order to eliminate a heterogene­
ous society and to guarantee religious freedom, the move to­
ward the secular school was important, as indicated in his 
statement!
Differences of religious belief and a sound re­
gard on the part of the State for Individual freedom 
in religious matters, coupled with the necessity for 
centralization and uniformity, rather than hostility to 
religion as such, lie at the bottom of the movement to­
ward the secular school.^5
A gradually decreasing emphasis on the Christian tenets 
was coupled with a general waning religious interest. The 
schools experienced an increased emphasis on secular material 
and the "New England Primerw with its Shorter Catechism was 
being laid aside.
New Hampshire provision adopted in 1784» and still 
a part of the current constitution, authorizes the public sup­
port of Protestant teachers of piety, religion, and morality. 
National Education Association Research Bulletin, Vol. XXXIV, 
Ho. 4, Decerabor 19$6, p. 1^2. ~
1<
Cubberly, E. P., Public Education in the United 
States, p. 173.
29
The Massachusetts Act of 1827 marshalled something of 
the process that had long been underway In the move from sec­
tarianism to secularism In the public schools* This Act de­
clared that School Committees should "never direct to be used 
or purchased In any of the town schools any school books which 
were calculated to favor the tenets of any particular sect of 
Christians*"^ Perhaps no one did more to established In the 
minds of the American people the conception that education 
should be nonsectarian and free than did Horace Mann* A vio­
lent attack was launched from both press and pulpit against 
the Massachusetts Board of Education, and Mann as the Secre­
tary to the effect that "the public schools are Godless 
schools*" The charge was leveled that the Board was trying 
to abolish the Bible from the schools, to do away with correc­
tion and to counteract the religious instruction of home and 
church* Mann contended that the Bible was a valuable charac­
ter guide but should be read In school without comment*
Also, he urged that any attempt to decide what creed or doc­
trine should be taught would spell the doom of the common 
s c h o o l * in response to a Reverend Smith who attacked the 
Board and Mann in a sermon entitled, "The Ark of God on a New 
Cart," Mann wrote a reply* He expressed his ideas concerning *17
1^Cubberlv. E* P*. Public Education in the United 
States, p. 175.
17Xbld.
30
sectarianism in the following words $
It is easy to see that the experiment would not 
atop with having half a dozen conflicting creeds taught 
by authority of law in the different schools of the same 
town or vicinity* Majorities will change in the same 
place* One sect may have the ascendency today; another 
tomorrow* This year there will be three Persons in the 
Godhead; next year but one; and the third year the Trin­
ity will be restored to hold its precarious sovereignty 
until it shall be again dethroned by the worms of the 
dust it has made. This year, the everlasting fires of 
hell will burn to terrify the impenitent; next year, 
and without any repentance. Its eternal flames will be 
extinguished, to be rekindled forever, or to be quenched 
forever as it may be decided at annual town meetings, 
This year the ordinance of baptism is inefficacious 
without immersion; next year one drop of water will be 
as good as forty fathoms* Children attending the dis­
trict school will be taught one way; going from the 
district school to the high school they will be taught 
another way,.,,
Mann was strongly convinced that education should be 
adapted to democratic and national ends rather than religious, 
As he was a Unitarian, and the newly created State Board of 
Education was liberal in religion, a wordy battle raged for 
some time. Eventually, after a dismal attempt to abolish the 
Board of Education failed, a majority of the people of the 
state conceded. Mann was Justified in his stand. Other states 
followed the example of Massachusetts and their state con­
stitutions provided for the separation of church and state 
and most forbade any diversion of public funds for sectarian I
I ft
x Cubberly, B* P,, Readings in the History of Educa­
tion, p. 575»
purposes* By 1875» the schools of the nation were almost en­
tirely secular In nature* In this year President Grant In 
addressing the Army of the Tennessee at Des Molnea maintained 
that no public education funds should be diverted for sectar­
ian education, as indicated In his statements
The free school Is the promoter of that Intelli­
gence which Is to preserve us.*** Encourage free schools 
and resolve that not one dollar appropriated for their 
support shall be appropriated to the support of any 
sectarian schools*.•• Leave the matter of religion to 
the family circle, the church, and the private school 
supported entirely by private contributions. Keep the 
church and state forever separated*!1?
The lines of separation were fairly well drawn at this 
time, and the principle of separation of church and state was 
looked upon as the natural outgrowth of the American system of 
government* However, religious leaders were actively formula­
ting new plans for the inculcation of sectarian education 
which would not conflict with the established principle of 
secular public education. Various movements In the process 
of Inception were to serve as forerunners of the released- 
tirae program*
Forerunners of the released-tlrae program. The movement 
of released-time for religious education was preceded by a 
number of organizations designed to infuse American Society
^National Education Association Research Bulletin,
Vol* xxxrv, tfo. I)-, December, 1956, p. 175%
31
32 .
with new religious vitality* These organizations served as 
valuable forerunners of the released-tlme program. Their 
specific purpose was to bolster the decline in religious life 
that was apparent near the end of the nineteenth century*
The role of religion in the history of our nation has 
been marked by periods of spasmodic growth and increase fol­
lowed often by periods of waning interest* This waning in­
terest was attributed by some to the new interest in science 
that was awakening within the public school system. The ideas 
of men like Darwin, Spencer, Huxley, and others served to ac­
cent conflicts between religion and science during the nine­
teenth century* As a result of these and other factors, there 
was a decline in religious life toward the close of the cen­
tury and the churches suffered numerous losses, Beardsley in­
dicated the trend of the religious decline in the following 
wordsI
The churches for the most part were at a stand­
still; their growth for the time being seemed to be 
arrested, accessions to membership were less numerous, 
while revivals, became less frequent and less power­
ful* In 1889, the Methodist Episcopal Church, one of 
the most aggressive religious bodies in the country, 
actually suffered a net loss of 21,934 members and 
probationers* A recognition of these conditions on 
the part of the churches led to speedy and earnest 
efforts to overcome them,***20
20Beardsley, P, G,, A History of American Revivals.
P. 79.
With the widespread reading of Darwin1a Origin of 
Species published in 1859» the conflict between science and 
religion reached a new climax. White, in his History of the 
Warfare of Science with Theology in Christendom wrote! 
"Darwln1S Origin of Species had come Into the theological 
world like a plow Into an ant-hill. Everywhere those thus 
rudely awakened from their old comfort and repose had swarmed 
forth angry and confused. Reviews, sermons, and books light 
and heavy came flying at the new thinker from all sides."21 
The writings of scientists and philosophers of this era had 
great effect upon the masses who were already the victims of 
a rushing tide of secularism.
The dawn of the twentieth century provided new hope in 
the field of religion and a germ of new life. The early years 
of the century witnessed a form of fundamentalistlc "revival­
ism" which swept the country. Hen like Moody and Finney 
stirred the masses with their eloquent, soul-searching ser­
mons. The churches were stirred to new life and missionaries 
were again sent to the foreign fields with righteous zeal.
The Student Volunteer Movement (1890-1915) called almost 
10,000 young people into missionary training.
21White, A. D., History of the Warfare of Science With 
Theology in Christendom, Vol. I, p. Toquoted Tn Twenty Cen­
turies ofT^duco-tlon by Edgar Knight, p. 454*
33
In reaction to the "revivalism" which was sweeping the 
land, there arose a form of religion labeled "liberalism" 
which attempted to attack the problem in what was considered 
a more constructive manner. Ministers began speaking about a 
"Social Gospel" that took decisive steps in seeking to remedy 
sotM of the existing social evils of the era. All of these 
religious forces did much to produce the various movements of 
the time, and the unity of church work achieved during this 
era is a story in itself.
The advent of the Sunday school idea in this country 
coincided with the emergence of the public education system 
and church-state separation. The movement had its beginning 
with Bailees in England (1780) and appears to have been born 
out of the humanitarian!sm which characterized England at this 
time. After being transplanted in this country. Instruction 
in the 3 R's was eliminated and the Sunday school inherited 
the job of religious education which formerly had been part of 
the public school curriculum. The rise of the Sunday school 
movement in this country provided a welcome haven for those 
who could no longer depend upon the support of religious 
teaching in the schools. The movement was hampered at first 
by a marked degree of disorganization of materials and methods 
of presentation as indicated in the following statement*
Prior to 1872, the situation regarding the cur­
riculum among the Protestant churches was chaotic.
35
The curriculum consisted for the most part of random 
passages from the Bible and of the catechisms of the 
several denominations, and the method was almost 
wholly ,Tieraorlter. Some semblance of system was intro­
duced by James Gall1s series of Bible stories with ex­
planations and questions in 182$, by Albert Judson1S 
series covering the Bible in five years in 1827*..
Order was brought out of this chaos when in 1869 the 
National Sunday School Convention appointed a committee 
prepared a series of lessons designed to cover the entire 
Bible in a seven-year cycle (later reduced to six), al­
ternating between the Old and New Testaments, and de­
signed for all ages in the Protestant Sunday schools,,,22
The advent of the International Uniform Lesson and the 
Improved International Uniform Lessons did lend stature to the 
movement and raised the quality of instruction. The lessons 
learned in the organization of the Sunday school program have 
been a valuable asset in arranging the program of released-time 
education, and Indeed, the Sunday school has proven a valuable 
big brother.
The arrival of the Vacation Church School (1894) on the 
religious education scene contributed additional time and op­
portunity for expanding the Sunday school experience,This 
movement came into being during the twilight years of the 
nineteenth century but received its main impetus in the early 
twentieth century. The proponents of the program determined *23
^2Bower, W, C,, and Hayward, P, R«, Protestantism 
Paces Its Educational Task Together, p. 67.
23 The movement la variously referred to as a Vacation 
Bible School, See Forsyth, N, P,, Week-Day Church Schools, 
p. 19.
to capitalize on the summer vacation time of children and en­
roll them in a daily school of religious education. The 
schools began spontaneously in different states and in dif­
ferent denominations. A vacation school was held in Hopedale, 
Illinois, in 1891*. for a four-week period and five days a 
week. The school had an enrollment of forty pupils who were 
divided Into four separate divisions for purposes of In- 
structlon.2^
Vaughn, a Congregational minister in Blk Mound, Wis­
consin, started a Vacation Church School about 1900. A Mrs. 
Stafford, who taught in this school for a long period of 
time, wrote a book about the experiment. She stated that a 
great many of these schools were conducted successfully.
The school that started the organized movement, however, was 
held in Hew York City in 1901 by Bovllle, the executive sec­
retary of the Baptist Mission Society of the c i t y . 2 5  Prom 
this juncture the movement spread quite rapidly and gained 
new acceptance in many denominations. The Vacation Church 
School is recognized as a distinct forerunner of the re- 
leased-time program in that it demonstrated that time, in 
addition to the Sunday period could be used effectively for
2Jj-Bower and Hayward, og. cit., p. 167.
2^Ibld., p. 168.
36
37
religious education#2^
A number of other types of religious organizations 
had their origin in the early twentieth century era, seeking 
a practical approach to social problems uncurbed by secular 
education. Sot only were the seeds of the weekday church 
school planted In this era, but the beginning of the century 
witnessed also the expansion of the "Young MentS Christian 
Association;" (lOijll.) "The Blble-Studyfor-Credit Movement;"2? 
(1910) "The Pastor1S Communicant's Classes;" (1913) "Pre- 
School Chapel Services;" (1917) and "The Community Training 
School;" (1918), However, even at this time there was evi­
dently a growing dissatisfaction on the part of many Chris­
tian leaders with the quality and scope of religious educa­
tion* In comparison with the professional and scientific 
approach that was evident In public education, the religious 
education then promoted by the churches was deemed Inadequate, 
From technological and Industrial change a new type of culture 
was emerging with which religious education was not keeping 
pace. The new developments In the psychology of teaching and 
learning were recognized as potentially effective tools for 
the religious education field as well as the secular. The 
contrast in approach and methodology was pronounced at this
2^Natlonal Educational Association Research bulletin, 
Vol, XXXlV, p. 1$9, December,
2?MoClure, L, V,, Weekday Religious Education at the 
High School Level, p. 6,
38
time with experimentalIam and scientific method observed In 
the public school as compared to the uncritical approach to 
religion evident In religious education. As a result, a num­
ber of religious leaders with vision formed the Religious Edu­
cation Association In 1903, In order to promote an up-to-date 
religious education program In keeping with the time. The 
Association numbered among Its membership educators from the 
Protestant, Roman Catholic and Jewish churches. The express 
purpose of the organization as declared In the constitution 
was stated In the following words$28
To Inspire the educational forces of our country 
with the religious Ideal, to Inspire the religious forces 
of our country with the educational Ideal, and to keep 
before the public mind the Ideal of Religious education, 
and the sense of Its need and value.*9
The movement was graced with the leadership of men like 
Harper, President of the University of Chicago, and Coe of 
Teachers College, Columbia University. The Association was 
designed to combine the talents of religious leaders and pro­
fessional educators. The organization stated Its objectives 
as follows*
The continuing objectives of this association 
seem clearly to have been three In particular. From Its *29
2^Lee, og. cit.. p. l}-86.
29Brubacher, J. S., A History of the Problems of Edu­
cation. pp. 314-7-3 .^0, quoted~~ln Education In Modern America, 
by Gordon Lee, p. lt-86.
39
inception this organization has labored to define and 
formulate a more relevant, more functional religious ed­
ucation curriculum, At the same time it has been en­
gaged in the search for more effective methods and 
techniques by which the religious instruction might be 
carried on. Finally, and encompassing the other two, 
the Religious Education Association considers its pri­
mary over-all responsibility to be that of ensuring 
religious education a real, functioning, central place 
in the total educational experience— and at all
The results of these labors, abetted by like- 
minded but unaffiliated interests of diverse sorts, are 
to be seen in two of the most significant, and at the 
same time most controversial, features of contemporary 
American education* the released-time religious educa­
tion program and the insistent demand that religious
made an Integral part of the public school
It has been evident that through the years religious 
groups have sustained a vital, growing interest in the conduct 
of education. This vital interest, in the early twentieth 
century, gave birth to the experiment of released-time for re­
ligious education. The time was opportune for the Inception 
and formative years of the released-time program.
The formative years of released-time (1905-1930), In 
the formative years the road leading to the establishment of 
released-time for religious education was paved by certain 
early pioneers who deserve a word of credit. The original 
Initiation of the movement may be attributed to Wanner of New 
York, who rendered notable service both by conducting week-day
levels.
^®Lee, op, cit,, p, 1|.S7,
classes and by constantly advocating their general acceptance. 
Through a series of public addresses and printed publications, 
especially his book entitled Religious Education and the Pub­
lic School, he aroused mild interest In the plan.^l
Wenner made public his plan at the Interfalth Confer­
ence on Federation held in Hew York City In 190$. He contend­
ed that public schools unduly monopolized the child's time and 
that the churches were entitled to their share of it. The 
public schools should "release" a portion of time for educa­
tional work on the part of the church. The Federation, in re­
sponse to Wenner1s proposal, urged that upon the request of 
parents, children be excused from public school on Wednesday 
afternoon so that the churches could provide a "Sunday school 
on Wednesday." Also, it was stipulated that the plan was to 
be carried out on church premises and under church authority. 
If children did not desire to attend this church school, they 
were to continue in their normal class schedule in the public 
school. To eliminate competition school authorities were re­
quested not to schedule alluring activities during these per­
iods. Although the proposal aroused considerable Interest, 
it was another decade before the plan became a part of the
^ ope, H. F., Week-Day Rellrdoua Education, p. 6.
32
"“Frankfurter, Justice, "McCollum v. Board of Educa­
tion." Supreme Court of the United States 90*11-12, October,
1947.
40
ia
public school system.
Another early pioneer of the movement was Miller, Sec­
retary of the Reformed Church in the United States. He issued 
a pamphlet in 1908 on the subject of week-day church schools 
and the publication attracted wide attention, stimulating many
experiraents.33
While a few schools of week-day religious education 
were established as early as 1909,3U the first major operation 
of this type for elementary schools was begun in Gary, Indiana, 
in 1913. The Church of Jesus Christ of Latter-Day Saints, with 
headquarters in Salt Lake City, Utah, reported that pupils were 
released from public hi^h school classes to attend "seminaries" 
as early as 1912.35
The experiment pattern that was begun in Gary, Indiana, 
in 1913, represents the establishment of a plan for elementary 
week-day religious education which has been followed exten­
sively throughout this country.3& The plan as developed in 
Gary, Indiana, was the result of cooperative efforts of an 
alert school superintendent and a group of ministers within *3
33cope, 0£. clt.. p. 6.
3 -^Ibld.. p. 7.
-^McClure, on. clt., as quoted from Announcetaent of 
Program, p. 13, by the Iatter-Day Saints Dept* of Education.
3&Shaver, E. L*, The Weekday Church School, p. 19.
the oity. A dedicated group of church leaders within the city 
met to consider ways of Improving religious education oppor­
tunities* In a comparison between the effectiveness of the 
public schools and the Sunday schools, they noted the relative 
inefficiency in dispensing moral and spiritual truth through 
the existing religious agencies. In their discussions, the 
Importance and value of religion In its relation to life and 
experience was expressed, along with the fear that the chil­
dren were not obtaining a sufficient amount of religious In­
struction* These people wished to do something to solve this 
problem, and thus they started to explore various possibili­
ties.3?
The city superintendent of schools, Wirt, was convinced 
too, that religious education was an important factor In the 
child's normal development. Hayward wrote concerning super­
intendent Wlrtl "The Weekday Church School was nurtured In 
the heart of a superintendent of schools who sensed the kin­
ship of religion and e d u c a t i o n . Wlrt suggested to the 
leading ministers of the city that children might be released 
to attend religious classes if the churches of the city co­
operated and provided them. With the help of their denomina­
tional boards, several of the churches accepted his offer and 
In 1914 these classes were actually underway. The religious
3?Mlller, M. C., Teaching; the Multitudes, p. 28.
38ghaver, B* L., The Weekday Church School. p. I.
teaching was conducted on church premises and the public 
schools had no hand in their conduct.39 Superintendent Wlrt 
sought to rotate the schedules of the children during the 
school day so that some were In class, others In the library, 
and still others on the playground. The schedules were ar­
ranged so that they could be "released" for religious classes. 
The public schools were not obligated to supervise the choice 
of teachers nor the subject matter which they taught. They 
did not assume responsibility for attendance, conduct or 
achievement of the child In the released-tlme program. The 
arrangement did not interfere with public school class sched­
ules, for the time would otherwise have been a play period for 
the child, nor did It truly affect the activities or feelings 
of the children who did not wish to attend. Under the Gary 
program In 1914-*1915# 619 pupils left the public schools for 
the church schools one period per week.^
The schools were at first conducted by separate denom­
inations but in 1918 five of the Protestant denominations 
united and a Community Board of Education was organized. The 
objective of the Board was to coordinate the system of week­
day schools. Later, Abemethy took over the leadership of 
the schools and by 1922 the Gary system had grown from three
-^Blau, Joseph, Cornerstones of Religious Freedom In 
America, pp. 235-236.
^Frankfurter, op. clt., pp. 12-13.
43
aschools and an enrollment of 800 to eight schools and an en­
rollment of 3,100.a The movement did not lose much time In 
spreading to other areas where It was adapted to local condi­
tions. The Religious Education Association was substantially 
In favor of this new organization. The 1922 convention of the 
Association was devoted to a critical appraisal of the move­
ment and noted the following developments!
To provide a factual basis for the discussions# 
a survey of the movement# financed by the Comralttee on 
Social and Religious Surveys, was undertaken by the 
Survey Committee of the association, under the direc­
tion of Erwin L. Shaver then of Hendrix College....
At the conclusion of eight sessions devoted to 
discussions of the survey and specific problems present­
ed by special papers, a Committee on Findings embodied 
the consensus of the convention. The committee found 
In the weekday movement a challenge to an achievement 
that traditional religious education through the Sun­
day School had failed to attain as well as a profound 
faith that the challenge would be met. It affirmed as 
the aim of the weekday church school not mere Instruc­
tion In dogmatic or ecclesiastical content but more 
adequate living of children In society. It concluded 
that the curriculum should be built around the exper­
iences of children In dally social life.4%
Shaver, In his search for information regarding the re- 
leased-tlme schools for the Religious Education Association 
noted that there was a serious lack of definiteness or aim 
regarding reasons for the formation of these new classes. As
IjlBower and Hayward, op. clt., p. 17$.
^Ibid., pp. 176-177.
ft result. In 1922, there was a great diversity of courses be­
ing offered in the week-day church schools. The most common 
arguments offered for more religious education and the new 
schools included spiritual Illiteracy, post-war Immorality, 
and new adjustments in religious ideals. An actual look at 
some of the objectives and aims of the schools reveals that 
they were Bible-centered and that the curriculum usually re­
volved around this concept. In response to a request from the 
Comlttee on Program of the Religious Education Association, 
Betts, a prominent religious educator, prepared the following 
list of aims of week-day religious education*
1. To meet the universal need and increasing de­
mand for dynamic religion to act against the widespread 
immorality and deterioration of ethical standards char­
acteristic of the present.
2. To give religion its rightful place in the 
whole scheme of the ChildtS development and education 
and so Insure Its presence as a working principle in 
later life and character.
3. To secure the time and frequency necessary for 
lodging the religious information, for training the re­
ligious attitudes, and for establishing the religious 
habits and skills required to vivify and spiritualize 
the ethical virtues by religious motives.
4. To secure for the teaching of religion such ed­
ucational standards as will command the respect of the 
pupil and place the religious aspect of his education on 
a par with other phases.
5. To bring under the Influence of religious in­
struction many who are at present untouched by the agen­
cies of the church. 6
6. To build into our national life and Ideals the 
basic biblical and ethical concepts, underlying
Christianity and oomaonly accepted by all denominations 
as the foundation of Christian character and good olti* 
senshipe
7* To unite the churches in a great common task, 
thereby helping to break down the barriers of extreme 
denominational ism and disunity which now Interfere with 
religious work and progress,
8, To help the church to see that if it is to ful­
fill Its destiny it m e t  change its emphasis and become a 
teaching instead of a preaching church,
9, To join hands with all other educational agen­
cies of the church, seeking to correlate aims and activ­
ities at every point possible to the end that, though 
the agencies may be many, the program of religious in­
struction offered the child by the church shall in the 
end be one,43
As early as 1925 various authors were writing about 
"Life-centered Objectives'1 for the new church school program^ 
It was revealed that the objectives that stem from life's per­
sonal needs and the needs of democracy and the church would 
not encompass all of the proposed purposes. The objectives of 
such a religious education would need to include the develop­
ment of Christian attitudes toward race relationships, Chris­
tian understandings of the importance of use of money and 
property and other related fields, ^
In Collecting data for the 1922 Convention of the Reli­
gious Education Association, Shaver sent out questionnaires
4^Cope, 0&, clt,, pp, 70-74.*
4^ Forsyth, N, F,, Week-Day Church Schools, pp, 27-36,
4$ibid., pp, 52-53*
to various school systems In the Atlantic seaboard states.
Out of 3 2 4  schools reporting, 2 9 0  gave the date of establish­
ment, and while It Is known that many other schools existed at 
this time who did not report, the return Is worthy of tabula­
t i o n . ^  Table I Indicates the yearly Increase of releaaed- 
tlme programs to and Including the year 1922#
47
THE GROWTH OP RELSASED-TIME PROGRAMS BY 1922*T A B L E  I
YearYear
Total
This table has been taken from the book by H
the Department of Vacation Church Schools with Evans as di­
rector* The new department was confronted with a task of 
leadership for released-time programs existing in twenty- 
eight different states, as indicated in Table 2*
TABLE 2» THE LOCATION OP RELEASED-TIMB PROGRAMS BY 
STATES (1922)*
O • % Mo. of
State Programs State Programs
Arkansas 2 Nebraska 2
California I New Hampshire I
Canada I New Jersey 10
Connecticut k New York 54
Illinois North Dakota I
Indiana Ohio 61
Iowa 5 Oklahoma I
Kansas 2 Pennsylvania 9
Maine I South Dakota 6
Maryland k Texas 6
Massachusetts 2 Utah 27
Michigan 20 Vermont I
Minnesota 24 Virginia I
Missouri I Wisconsin
Total W
Ls table has been taken from the 
Cope entitled Week-Day RellKious Education, p. 14#
Some of the denominations established special depart­
ments to supervise and promote the week-day work. The legal 
aspects of religious education came into view in 1927* The 
legal problems centered in the release of pupils on public 
school time, the use of public school buildings, and the 
granting of credit for religious instruction. The legal de­
cision handed down in 1927 affirmed that the program was not 
a violation of the principle of separation of church and 
state, and that the classes could continue recognizing the
parent1s right to guide the destiny of his ohild*^? This 
court decision, in White Plains, New York, brought to light 
that the practice of released-time existed in twenty-three 
other states even in 1927«^® At this point consideration will 
be given to the more recent aspects of the released-time pro­
gram.
More Recent Aspects of Released-Tlme
The early momentum gained by the released-time program 
was projected into the 1930*s, The program reflected trying 
economic conditions, however, the later legal barriers were 
to prove even more formidable* Released-time was destined to 
emerge from both tests successfully.
The progressive years (1930-19U7)* The years 1930 to 
19^7 can properly be termed progressive years although the 
mushroom growth that the released-time program enjoyed in the 
1920*8 was somewhat abated in the early 1930*8. In 1933 the 
United States Office of Education reported that the program 
was in operation in thirty-five states . W h i l e  the number
^9People v Graves, 219 N.Y.S. 189, aff*d 156 N.E, 663
(1927).
^9Dr. E. L* Shaver1S survey of 1922 indicated that 
there were twenty-eight states at that time that had programs 
of week-day classes for religion.
^National Education Association Research Bulletin,
Vol. XXXlV, Mo. December 1956, p. 172.
5o
of schools continued to Increase, the pace was slowed and a 
number of existing systems closed their doors on the program. 
The depression that had struck the nation caused a shift from 
paid to volunteer personnel in other systems. This proved to 
be only a temporary setback, however, for soon the plan was 
again taking new ground. Shaver reported that four hundred 
communities in thirty states were enrolling some two hundred 
and fifty thousand pupils in week-day schools during the early 
part of the depression. In 1942, the Department of Week-Day 
Religious Education of the International Council of Religious 
Education Issued statistics showing that the program was oper­
ating in eighteen hundred communities in forty-six states and 
that a million and a half pupils were attending week-day church 
schools. Thus the program that had started so unheralded some 
thirty years before, had by this time become almost nation­
wide in scope,^
The Department of Week-Day Religious Education was set 
up independently of the Department of Vacation Church Schools 
in the year 1942, and Shaver was appointed as the director. 
Considerable progress was made in interdenominational coopera­
tive courses of studies which were in the process of produc­
tion, These "cooperative” courses were the result of dedi­
cated work on the part of a number of denominational workers
52shaver, E, L,, The Weekday Church School, pp, 20-21,
In closely coordinated labor«53 The new Department of Week­
day Religious Education developed definite standards, recon­
structed some of the local programs, and prepared a new cur­
riculum guide# The problem was no longer primarily that of 
promoting the movement but of giving It guidance and direc­
tion# However, the movement was about to pass from popular 
acclaim to a careful scrutiny by the United States Supreme 
Court#
From limelight to x-ray (19^8-1952). Although the le­
gal aspects of the released-tlme program are to be considered 
separately, two Federal Supreme Court rulings are worthy of 
mention at this juncture# Obviously a situation as contro­
versial as this was destined ultimately to be tested in the 
courts. In 19^8 the Supreme Court of the United States ruled 
invalid the released-tlme program as operated in Champaign, 
Illinois# The court case is commonly referred to as the 
"McCollum Case." The released-tlme program in Champaign con­
sisted of one period each week set aside for religious instruc­
tion during which teachers came to the public school and uti­
lized school facilities In instructing the pupils# The pro­
gram was ruled unconstitutional on three counts. First, pub­
lic school buildings were utilized for sectarian Instruction
^ Weokday Church School Texts Cooperative Series# 
1928-1959, edited by the Cooperative Publication Association, 
St. Louis, p# 2#
51
52
which waa contrary to federal and state constitutional provi­
sions. Second, the school board's cooperation in the project 
was ruled Illegal* Third, the public school machinery that 
was constructed to insure compulsory attendance was being used 
to aid sectarian instruction.
The foregoing decision cast a legal haze over the move­
ment that was not clarified until 1952. In the wake of the 
1948 decision a number of programs ceased to exist. The 
Champaign Case decision reduced the number of communities in 
which programs were operating by twenty percent and the num­
ber of pupils enrolled by ten percent. There was a consider­
able rebound in enrollment however, when it became clear that 
the banning of the Champaign program did not mean the banning 
of all types of p r o g r a m s . 5^4 A second major hurdle for the 
movement was encountered in the city of New York,
The released-ttrae plan of New York City was reviewed 
by the Supreme Court in 1952. The court case is commonly re­
ferred to as the nZorach Case,” In the New York plan pupils 
were excused from school at certain periods of the week to 
attend religious education classes in their churches. All 
costs of the venture were assumed by the churches involved 
and no expenditure of public school funds was involved. The
^Shaver, E. L.,nWeekday Religious Education Secures 
Its Charter and Faces a Challenge," Religious Education, p. I4, 
January-February, 1953*
53
Supreme Court ruled this plan legal and thus provided the 
present base of operation* Now that the movement lias received 
the legal green light the door has been opened to Increased 
expansion and opportunity.
The program f o r s ahead. Before the Champaign court 
case regarding released-tlme was pronounced in I9I4.8, the In­
ternational Council of Religious Education claimed that 
2,000,000 public school children In 2200 communities were en­
rolled In released-tlme classes. In 19l|8 the Research Divi­
sion of the National Education Association made a wide can­
vass of the program by sending $100 questionnaires to local 
superintendents of schools in all parts of the nation. On 
the basis of 2639 replies the Association estimated that about 
700,000 elementary and secondary school pupils were enrolled. 
Inasmuch as almost half of the questionnaires were not re­
turned, It is possible that the total number of released-tlme 
programs would be many more than Indicated.
The tremendous growth of the movement In the 19$0,s is 
attested In the following quotation, "Programs of one kind or 
another are in operation In over 3,000 communities in !4.$ 
states and are enrolling approximately three million children
55Butts, P. R., The American Tradition In Religion.
p. 199.
of all faltho."^ This 1956 report of progress by the Nation­
al Council of Churches was followed in 1958 by a statement 
from Goddard, director of Week-day religious education for the 
National Council of Churches* Mrs* Goddard estimated that 
four million children of all faiths were released from public 
schools once per week to attend religious education classes 
during the year 1958*57
As an indication of the growth experienced in the re- 
leased-tlme movement at the start of this decade, the program 
of Indianapolis, Indiana, serves as a good example * In the 
program there, the enrollment in the week-day classes of re­
ligion for pupils in the fourth and fifth grades had increased 
from 2,618 in 19^6 to 11,511 in 1951* During the same period 
the budget for this project increased from $30,000 to $82,875» 
In this city cooperative week-day church school system, chil­
dren representing 112 different religious bodies were en­
rolled*^
An important facet in the total program is the attitude 
of public school personnel toward the plan. The adjusting of
^Kellogg, Wendell, nReleased-Tlme Plans Strong Pro­
gram," National Councll Outlook, p* 6, September, 1956* Sea 
also Shaver, I?* L*. Remember t;he Weekday to Teach Religion 
Thereon, p. 6*
57Goddard, A* L*,"Pour Million Children Attend Re- 
Ieased-Time Classes," Telescope Messenger, p* 5» April, 1958»
'^Shaver, E* L., Weekday Church School, p. 30*
school schedules and participation In the plan could not help 
but evoke some crystallzed feelings. In a survey conducted by 
the Research Division of the National Education Association It 
was revealed that the attitude of public school personnel was 
very much In favor of the program. In returns from 703 school 
systems, 82 percent of the teaching staff registered approval 
whereas only 18 percent registered disapproval,59 This report 
Indicated something of the mutual respect and cooperation 
that has graced the movement’s relationship with public schools 
even since Its Inception,
The First National Conference of Weekday Religious Ed­
ucation was held at Oberlln College, Oberlln, Ohio, In 1956,
The conference afforded an opportunity to appraise six ad­
vance studies, conducted to gather pertinent information on 
released-tlme. The conference also afforded an opportunity 
to focus attention on common problems. It was revealed that 
a wide variety of practices exist In the conduct of the total 
program of week-day religious education. The prevailing pat­
tern of organization Is interdenominational or community-wide; 
however, many schools are operated by individual denominations 
or churches. Although splendid progress was indicated in the 
development of good curricula a great deal remains to be done
'^ The Status of Religious Education In the Public 
Schools, National Education Association, Washington, D.C,,
19l*9, p, 12.
In the field. The conference indicated that while it la gen­
erally assumed that practically all week-day teachers are pro­
fessionally trained and serving full time such is not actually 
the case. Over twenty-five percent of the systems studied In 
the conference use volunteer teachers, and a higher quality of 
teaching was felt to be a pressing n e e d . T h e  financial pic­
ture revealed a similar divergence of practice, ranging from 
systems using teachers and facilities comparable to that of 
the public schools to other systems operating on meager bud­
gets and using volunteer teachers. The conference Indicated 
that while no uniform organized effort Is particularly pro­
moting the establishment of new schools, they are springing 
up In many parts of the c o u n t r y W i t h  good leadership, de­
nominational and community support, the future of the week-day 
church school looks bright indeed.
A brief look at two separate systems will, perhaps, 
clarify some questions regarding the organizational patterns 
that exist in different parts of the country. The program 
of week-day church schools has been a common occurrence In *61
6Opindlay College in Findley, Ohio, has initiated a 
program for training teachers for teaching release-time class­
es. Seei Holland, D. T., "Shared Time and Juvenile Delin­
quency, " Vital Speeches, pp* lj.05-4.08, April 15» 1957»
61HcKown, 5, H., Coordinator, "A Look at Week-Day 
Church Schools," Religious Education, pp. 4--21, January- 
Pebruary, 195&*
56
27
Cincinnati, Ohio, for nearly thirty years. The program was 
Initiated in I92I4. by the Hamilton County Council of Religious 
Education, now the Department of Religious Education of the 
Council of Churches of Greater Cincinnati. There are sixty- 
three week-day church schools included in the program and 
their operation involves contacts with seven different boards 
of education. Community interest has been maintained by the 
organization of neighborhood committees responsible for their 
promotion and financing. This is accomplished through 
churches, church organizations and voluntary gifts from par­
ents. General supervision of the program is delegated to the 
Director of Religious Education. The salaries of the super­
visor and the secretary are provided through the central bud­
get of the Council. The complete system is composed of twelve 
full-time and seven part-time teachers. In order to qualify, 
a teacher must have training equivalent to that required of 
public school teachers and a religious background that will 
equip her for guiding children in Christian living. The sal­
ary range for these teachers is from $2,^00 to $3#000
Most of the children involved in the Cincinnati re- 
leased-time program are from grades three to six, although a 
few first and second grade classes are included. About 80
^2Hanna, E. M., MPatterns of Weekday Religious Educa­
tion,” International Journal of Religious Education, p. I*,
n.d.
percent of the children who have opportunity avail themselves 
of these classes and the enrollment figures for 1954 stood at 
11,516* About thirty-five percent of the 11,516 have no other 
church contact. All of these classes meet In churches near 
the public schools and the courses of study deal with mater­
ials selected from the Cooperative Series of week-day church 
school texts.63
The program of releaaed-tlme In Rochester, New York, 
started in 1920 and has continued operation without interrup­
tion. Since 19l}l* the program has been the charge of the 
Federation of Churches of Rochester and Vicinity. The class­
es are offered to both elementary and high school pupils and 
In 1954 instruction was given to some of the grades in twenty- 
nine schools in the city. Elementary classes are held on a 
partially staggered program of release as New York law stipu­
lates that the children may be released either at the begin­
ning or end of a school session. The teachers for these 
classes are regarded as semi-professional. Some are employed 
by the Federation of Churches to teach only one or two hours 
per week. Most of the elementary classes are taught by a 
corps of "contract teachers" who teach from five to eleven 
classes each week. Thetr salary begins at -$2.50 per class 
session and advances to $3.75 per class session with salary 6
58
6^Ibld.. p. I.
Increases based on number of years service and professional 
training. Qualifications for these teachers Include Chris­
tian conviction, training in education and religion, and abil­
ity to understand and work with c h i l d r e n .^4
Classes are held in church facilities near the school 
and pupils are escorted by the religious education teacher. 
Lack of adequate space is named as the greatest factor limit­
ing expansion of the program. Approximately thirty percent 
of the pupils who attend are from unchurched homes. High 
school students are released the last period on Monday for 
their instruction. The program is directed, financed, and su­
pervised by the Federation of Churches of Rochester and Vicin­
ity. Hew classes are added each year and the program has 
grown consistently since its beginning.^
The vitality of the released-time program for religious 
education has proven adequate to legal testing and financial 
problems. The ten-point standard propounded in 1943 by the 
Department of Week-Day Religious Education is still a guiding 
light for the movementI
I. A year of planning before launching the pro­
gram. *6
0lfComey, Lillian, "Patterns of Weekday Religious Edu­
cation,n International Journal of Religious Education, p. I,
n.d.
6^Ibld.
59
60
2. All religious groups working closely to­
gether.
3» Parents accepting their responsibility for 
the school and supporting It In every way,
4, Cooperation with the public school system 
without using Its building or machinery,
5, A representative and reliable week-day church 
school board continuously on the job,
6, A course of education In religion as well 
planned and Implemented to Its purposes as the courses 
In the public schools are to theirs,
7, Teachers as well trained for teaching reli­
gion as the public school teachers are for their work,
8, A supervisor— trained, experienced, and re­
ligious— working with every school,
9, An expenditure per pupil (In proportion to 
the teaching time) equal to that for his public school 
education,
10, The spirit as well as the letter of the law 
preserved In all relationships,66
The foregoing ten-point standard contains an Item re­
garding the qualifications expected of a teacher employed In 
released-tlme work. The teacher Is to be as well-trained for 
the task of teaching religion as the public school teacher Is 
prepared to teach secular materials. The teacher of a reli­
gion class Is expected to possess the same qualifications as 
good public school teachers, with additional emphasis upon 
religious experience and acceptable personality traits. This
^Shaver, E, L., Remember the Weekday to Teach Reli­
gion Thereon, p. 16.
goal has not been achieved but strong measures have been taken 
In this direction. It is recognized that these qualifications 
can only be maintained as these teachers are paid a salary 
equal to the public school teacher. Shaver reported that many 
released-tlme programs have set this mark for their standard 
s a l a r y , However, in some released-tlme systems like Chica­
go, Illinois, the teachers are volunteer and are paid only a 
token amount by the local church council or the local church.
The adequate scheduling of released-tlme classes has 
proven to be a problem In certain areas. Once the program 
has been accepted, then the public school authorities must 
decide whether to use a staggered or simultaneous schedule 
of excusal. If the simultaneous schedule is employed, all 
children whose parents so request it are excused at the same 
time. If the staggered schedule la used the children of 
several grades are excused at different times of the day, so 
that all through the day and week classes In religion are 
meeting. The use of a staggered schedule makes possible the 
employment of full-time professionally trained teachers of 
religion. If the simultaneous schedule Is used it is diffi­
cult to conduct classes on a widespread basis because of the 
large number of teachers required for a short span of time,^
^7shaver, E, L,, The Weekday Church School, p, 67,
68Ibld,. p, 42.
61
62
It would appear that a movement like released-tlrae, 
which fosters an Interdenominational type of cooperative ef­
fort, would encounter severe difficulties in planning an ac­
ceptable curriculum. However, one of the unique features 
of released-time programs has been the ready acceptance of 
curriculum materials developed cooperatively by participating 
denominations. Experience has demonstrated that the selection 
and use of curriculum materials has not proven to be a great 
obstacle to the program,
As the Sunday school program met a specific need In 
eighteenth century England, the proponents of released-tlme 
believe this program meets a need today, At present the em­
phasis of the movement appears to be focused upon a definite 
quality of Instruction rather than a quantity of enrollment.
Summary
The Puritan settlers of New England were proponents of 
the Calvlnlstlc conceptions of education. They spearheaded 
the move for literacy In America with the belief that each 
Individual had the ability to know and understand the will 
of God, as contained in the Bible, To understand and accept 
spiritual responsibilities as contained In the Bible, each 
child was to be taught how to read. Many of the early schools
69Ibld.. p, 47.
63
established in America reflected this religious moralistic 
type of education and were sectarian schools.
The move from sectarian education to secular education 
was a gradual process that preceded unevenly In many parts of 
America, As the society sought to provide education for its 
children, sectarian differences made it evident that the edu­
cation must be non-sectarian in nature. However, with the 
elimination of sectarian instruction and the emergence of the 
public school religious leaders noted a need for additional 
religious training,
A number of religious organizations came into existence 
near the beginning of the present century to supplement agen­
cies engaged in the work of religious education. These move­
ments provided valuable lessons of organization and philosophy 
which were later included in the released-time program. Re­
ligious leaders were awakened with the conviction that time 
other than Sunday could be effectively utilized for religious 
education.
Manner, a religious educator of New York City, has been 
credited with the idea that sparked the released-time movement. 
The first program on the secondary school level was initiated 
by the Church of Jesus Christ of Latter-Day Saints, Salt Lake 
City, Utah, in 1912, The first full-scale released-time pro­
gram on the elementary school level was founded in Gary, In­
diana, in 1913, The experimental pattern that was used in
Gary, Indiana, represents the establishment of a plan for ele­
mentary releaoed-time classes copied extensively throughout 
the nation.
The Federal Supreme Court of the United States has ren­
dered two notable decisions regarding released-tlme programs.
In the McCollum Case, the Supreme Court ruled the released- 
tlme program of Champaign, Illinois, unconstitutional. The 
I9I4.Q decision ruled the program Invalid because: (I) school 
property was utilized, (2) compulsory education laws aided 
the program, and (3) the school board cooperated and encour­
aged the plan. This decision closed the doors of many re- 
leased-time programs and caused the modification of many 
others.
In the Zorach Case, the Supreme Court ruled the re- 
leased-tlrae program of New York City constitutional. The 1952 
decision revealed that the pupils involved were released from 
school to attend classes in the church of their choice.
The released-tlme program has grown from the 619 pupils 
enrolled in Gary, Indiana, in 1913 to approximately ij., 000, OOO 
pupils enrolled in 1956. In recent years the emphasis of the 
released-tlme movement has been upon the development of a 
quality program.
At this point consideration will be afforded the philos­
ophy of released-tlme as presented in the following chapter.
65
CHAPTER III
THE PHILOSOPHY OF RELEASED-TIME
At this juncture the question Is posed; What is the 
philosophy behind released-time? Since all rational processes 
and disciplines in every department of intellectual activity 
depend upon the possession of the philosophic spirit, so the 
program of released-tlme Is dependent upon a logical philo­
sophical foundation. The purpose of this chapter Is to pre­
sent findings regarding the philosophy which governs the or­
ganization and expansion of the movement. As noted in the 
preceding chapter, the frame of reference Is predominately 
that of the Christian religion since the concept of released- 
tlme arose from this background. The following material Is 
organized to afford consideration of; (I) A Dilemma of Thwart­
ed Spiritual Need, and (2) The Church and Released-Tlme.
A Dilemma of Thwarted Spiritual Need
Although the United States is a nation founded on reli­
gious principles whose departments of civil government tradi­
tionally follow religious practices, a widespread religious 
Illiteracy is noted throughout the nation.1 In assessing the 
responsibility of the various agencies dedicated to molding
1Hay, C. L», The Blind Spot in American Public Educa­
tion. p. vil.
66
the lives of children the public school can scarcely escape 
implication. However, the natural limitation caused by church- 
state separation poses a dilemma on this point.
The moral and spiritual needs of children. Perhaps only 
the rationalist, humanist, or atheist would deny that children 
have moral and spiritual needs, As "we are a religious people 
whose Institutions presuppose a Supreme Being”2 there is recog­
nition of the need of children for a moral and spiritual in­
terpretation of life that would equip them for a place in our 
complex society. This need is attested to by* (I) the offi­
cial pronouncements of various government and education con­
ferences, (2) the voice of educators, parents, and religious 
leaders, and (3) the tremendous surge of criminal behavior 
among the young.
In 1930 the White House Conference appointed by Presi­
dent Hoover published its report on Child Health and Protec­
tion, The 19 points enumerated in the "Children's Charter” 
were the findings of intensive committee study under the as­
tute leadership of Wilbur, Secretary of the Interior, In rec­
ognizing the rights of the child as the first rights of citi­
zenship, the White House Conference pledged itself to the 19 
alms for the "Children of America," The very first aim listed 
by the Conference was, "For every child spiritual and moral
2Zorach v, Clauson et al., 343 U.S, 314 (1952),
training to help him stand firm under the pressure of life."3 
In 1932 the United States Office of Education issued a 
statement to the effect that the need of moral and spiritual 
instruction for children was very evident. The statement also 
indicated that the need was not being met, as shown in the 
following!
67
The need for more religious instruction as a 
guide for the control of human conduct has been ex­
pressed in surveys and studies. They show that a 
negligible amount of a child's time comes under the in­
fluence of the churches and that only a small proportion 
of the children throughout the country have even brief 
contact with church Influence. They also show changes 
in family life wherein parents tend to disregard reli­
gious education or to throw upon the churches or the 
community the chief responsibility for youth's religious 
training.^
The 1940 White House Conference on "Children in a De­
mocracy" emphasized again the spiritual need of children. The 
section on "Religion in the Lives of Children" indicated that 
these spiritual needs were not being met, as shown in the 
statement!
Despite the various efforts made by church groups 
to educate children in religion, the religious needs of 
many children are imperfectly met at the nresent time. *
^Moehlman, A, B., School Administration, pp. 46-49.
^•"Week-Day Classes in Religious Education," United 
States Office of Education Bulletin 3*1» 1941*
68
It has been estimated that approximately one-half of the 
children and youth In the United States receive no reli­
gious Instruction outside the home,5
The Hldoentury White House Conference on Children and 
Youth stated in a "Pledge to Children" the following, "We will 
provide you with all opportunities possible to develop your 
own faith In God*"^
A number of individuals could be summoned from the ranks 
of educators, religious leaders, and parents who would testify 
to the apparent need of children for moral and spiritual guid­
ance. The following statement indicates a trend of thinking 
In terms of this needs
In view of the unquestioned intelligence and the 
unusual sensitivity of the leaders of the effort to 
achieve a new education. It Is surprising that they 
Ignore religion. Religion has no place in their philos­
ophy, their plans, or their strategy. They design to in­
troduce the child to the complete culture, but they leave 
out of their reckoning one of the most basic aspects of 
all the historic cultures; they wish to educate the whole 
child, but they refuse to consider one of his most fun­
damental 'needs.Y
The historian Wells, In his Outline of History,made a 
statement regarding spiritual need: "Education is the prepara­
tion of the Individual for society; and his religious training 5*
5Ibld., p. I.
6wPledge to Children," national Council of Churches of 
Christ In the^United States of America Bulletin, p. I.
?Hay, og. cite, p. 66.
is the core of that preparation*"^ This contention is substan­
tially agreed with by those who maintain that to give children 
an intellectual subject-matter diet without a firm moral and 
spiritual foundation is to build on a foundation of sand. The 
ultimate result of the process indicates that the higher the 
monument the more complete will be its collapse. Children 
have a definite need of moral and spiritual inculcation to 
face the vicissitudes of life.^
Another area of thought which Indicates need for moral 
and spiritual guidance is noted indirectly in the wave of crime 
and juvenile delinquency which has swept the country. While no 
valid statistical analysis is available to indicate positively 
that the influence of religion serves as a deterrent to anti­
social behavior, it is the author*s belief that this is actual­
ly the case.
The topic of juvenile delinquency has been bantered about 
by everyone from the neighborhood grocer to the heads of state. 
The charge is frequently made that juvenile delinquency results 
from the omission of religious influences in the lives of chil­
dren and can only be checked if steps are taken to remedy the 
situation. One individual indicated the need of children for 
religious orientation in the following terms: 89
8Ibid.. p. 65.
69
9Ibld.. p. 66.
70
A good Catholic can never be a bad citizen. 
Likewise, neither can a good Protestant or a good Jew 
fail in his civic or moral obligation. If as one 
authority has said, there are hundreds of thousands of 
•spiritually hungry and spiritually naked* children in 
New York City alone, then a challenge exists that must 
be met promptly and fully. These children, to be good 
citizens, are in desperate need of religious orienta­
tion. 10
The crime statistics compiled in various surveys in 
this country are appalling. Hoover, Director of the Federal 
Bureau of Investigation, has indicated that the United States 
is in the midst of an ever-increasing crime wave. Statistics 
reveal an almost continuous succession of yearly crime in­
creases since the conclusion of World War II. Homicides, 
rapes, assaults, robberies, burglaries, car thefts, and all 
manner of crime categories have increased in number from 1946 
to 1956. Bireau statistics reveal that increases in seven 
categories brought a record 2,$63,l50 major crimes in 1956.
This denotes an increase of 13*3$ above 1955* One comparison 
is noted in the increase from I,685*203 major crimes in 1946 
to 2,563,150 in 1956. This is an increase of major crime in 
one decade of some 40$« It is noted that young people, partic­
ularly young males in the 15 to 35 age range, commit most of 
the crimes in the United States.
To pinpoint the extensiveness of crime, it has been 
pointed out that in 1953 crime cost every family in the United
IOThayer, V. T., Rell Pd on in Public Education. p» 102.
!!"Crime in the United States," Life. September 9# 1957.
States about $5>00w This was #$00,000,000 more than Americans 
spent on education, religious activities, and charity in 19$3,12
In the belief that adequate moral and spiritual train­
ing constitutee a bulwark against juvenile delinquency, many 
individuals are inclined to Interpret the crime statistics as 
reflecting a basic failure In filling the religious vacuum in 
the lives of young people, as indicated In the following state­
ment; rtThe courts are filled with youngsters and grown-ups who 
are not really to blame because they lack proper moral traln- 
ing#«*13 The outbreak of crime among the young is considered a 
natural conclusion in the absence of positive moral and spirit­
ual guidance. The threat is voiced that unless children re­
ceive adequate moral and spiritual training they will grow up 
"with no knowledge of God and His rules of conduct, practically 
pagans, potentially dangerous citizens, candidates for the 
prison c e l l , T h e  Division of Christian Education of the 
Protestant Council of Bew York City informed the people of Hew 
York a few years ago that $00,000 children of that city who 
were receiving no religious education, "are a menace to society, 
to themselves, to our country, and our country's future, *1
^Holland, D, T,, "Shared Time and Juvenile Delinquency," 
Vital Speeches 23;4<>$, April 1$, 19$7*
1^Hay, o£. clt,. p, 10,
^  Johnson, Ee P,, American Education and Religion, p. 21*
1^Ibld,
71
72
Although the home and church are considered primarily 
responsible for the Inculcation of moral and spiritual truth, 
it becomes Increasingly difficult for the public school to 
completely disavow any obligation in the area* However, the 
public schools are secular and thus limited In the teaching of 
religion.
Limitation of the nubile school* In the face of the 
apparent need of children for moral and spiritual guidance the 
public schools are limited by the fact that they are secular* 
The public schools are maintained as secular schools because* 
(I) limitation serves as a safeguard against discrimination of 
religious minorities, (2) encourages religious liberty, and 
(3) allows the church and state to operate Independently under 
the assumption that the best end of each Is served In this 
manner*
A great deal of criticism has been heaped upon the pub­
lic schools because they are secular. One report Indicated 
that according to most bishops and many Protestant ministers 
the public schools are "secular,M "materialistic," and "God­
less."16 No debate Is needed on the Issue of whether or not 
the public schools are secular for they are admittedly secular 
and this position was achieved only through many years of ded­
icated labor* To some the word "secular" carries a connotation 1
1^Noll, J. P*, Our National Enemy Number One; Education 
Without Rall--Ion, p. 3#
73
of something sinister or unclean whereas It simply Implies an 
Institution engaged In dedicated work of neutral character, as 
the courts or the presidency*^?
The accusation that the public schools are "Godless” Is 
not new* Since as early as 1836, when Mann was Secretary of 
the Massachusetts State Board of Education, the same cry was 
raised* However, the charge that the public schools are "God­
less" Is rather vague* Public schools are composed of build­
ings, administration, faculty, and students* Certainly the 
Inanimate school buildings could not be termed "Godless." The 
students could scarcely be labelled "Godless" for they repre­
sent homes in America that boast an all-time high of over 100 
million church members* Certainly school administrators and 
faculty would resent the title "Godless" for as employees of 
the state they are guided by the established principle of sepa­
ration of church and state* Further, many of these capable 
people are Sunday school teachers, church youth leaders, choir 
members, and serve on a multitude of church committees*
Perhaps the title "Godless" was meant to be directed 
toward the public school curriculum* However, much of the 
school curriculum has Its roots in the historic religious 
backgrounds of the many people In the United States* The moral 
and spiritual values taught Indirectly and directly In our
^Rogers, V* M*, "Are the Public Schools1 Godless?" 
Christian Century, pp« 1065-1066, September 11, 1957*
7k
public schools stem from those religious backgrounds and in­
clude such commendable traits as charity, respect for others, 
honesty, integrity, and a wholesome worth of the Individual 
person# It is true, however, that the moral and ethical 
values are often what religious leaders would deem superficial 
in comparison with the spiritual needs that the public school 
either disregards or glosses over#
It seems apparent that those who criticise the public 
schools as Godless and irreligious are pursuing an educational 
program which includes the teaching of religious belief# Van 
Dusen, president of Manhattan1S Union Theological Seminary, 
desires a return to religion in the public schools not merely 
as a course in Itself but as the guiding principle of the 
whole educational process# He contends that religion is the 
keystone of the educational arch In the following wordsI
Every aspect of the philosophy and structure and 
spirit of education cries for radical remaking##.. No 
longer is religion the keystone of the educational arch, 
but rather one stone among many#•#• Our educational 
system has lost what had been its principle of coherence 
and its instrument of cohesion#### It was not the in­
tention of the Pounding Fathers to rear up "a nation 
without religious faith, or (build) a system of educa­
tion for that nation*e youth without implicit, and 
probably explicit, recognition of God as the ground of 
Truth..,# It has been aptly said* They were seeking to 
provide freedom of religion, not freedom from religion.
1^Van Dusen, H. P,,
pp. 78-80, May 14, 1951*
"Replace the Keystone," Tltae
7$
Bailey, the Florida State Superintendent of Public In­
struction, proposed a state-wide plan in 1955 to the effect 
that religious training be given in the public schools, Bailey 
argued that it is "impossible to teach democracy in a Godless 
a t m o s p h e r e . e c h o e d  the words of Jarman, a former school 
superintendent, who had expressed a similar conclusion about 
the need for religious training, Jarman, too, contended that 
democracy without religion was an Impossibility, as expressed 
in his statement!
American people are becoming more and more secu­
larized. Unless this is stopped by including religious 
education in public schools, secularization will destroy 
American democracy, since democracy itself is an applica­
tion of the basic truths of Christianity. Youth, there­
fore, must be reintroduced to their great social herit­
age, religion.* 20
The New York Board of Regents arrived at a similar con­
clusion in its report of 195k* In its statement the need of 
instruction in certain religious tenets was stressed as not 
inconsistent with the spiritual heritage of America. The 
statement included the following plea for religious instruction 
In the public schools!
^Miller, W. L, "The Fight Over America1S Fourth 1R 1,* 
The Reporter, p. 21, March 22, 1956*
20Jarman, B. H., "Religious Education and the Public 
School," School and Society 67lkkwk6» January 17# 19U8*
76
Theso troubled times call for the teaching of 
•Piety and Virtue* in the schools, and that dependence 
upon Almighty Ood so clearly recognized in the Declara­
tion of Independence, the Constitution of the United 
States**.and the pronouncements of the great leaders of 
our country*21
Former IIayor Kenny of Jersey City proposed that lessons 
about Protestantism, Roman Catholicism, and Judaism be given 
to children in the public schools of the city. This and the 
proceeding proposals are manifestly impossible, for the public 
schools cannot teach relifdoua beliefs* Public schools can 
teach moral and ethical values without fear of provocation, 
but religious belief Is a different matter* The first move In 
this direction would violate the basic principle of freedom of 
religion and embroil the schools in sectarian differences. In 
this type of situation it is questionable whether the public 
schools could serve their basie function or even long survive*
As sectarian religious education is prohibited in the 
public schools by law, the concept of teaching a general course 
in religion has been proposed. It is readily apparent that a 
course of this type would not fulfill the results desired by 
the various denominations. It has been argued that the courses 
would have to be so general that the specific spiritual needs 
of the various children could not be adequately met* This ap­
pears to be the consensus of Catholic and Jewish bodies in Hew 21
21Miller, W, L,, "The Fight Over America's Fourth 1H 1,n 
The Reporter, p* 21, March 22, 1956*
York City where the plan was proposed, A diluted course in re­
ligion was rejected by various New York groups on the grounds 
that the ultimate purpose of inculcating desired religious be­
lief could not be achieved, as indicated in the following 
statement!
77
Religions would have to be watered-down in order 
not to be objectionable to some. The liberal Catholic 
magazine Coraionweal said it doubted whether a "religion 
of the least common denominator" could fill the reli­
gious vacuum in the schools} the New York Civil Liberties 
Union predicted that the result would be a "vague the­
ism)" the New York Board of Rabbis said, "some teachers 
are bound to become missionaries for their own religious 
convictions,••• Other teachers will, no doubt, become 
advocates of a watered, meaningless *publlc school reli­
gion, * glossing over differences among religious groups 
which stem from vitally Important convictions,,,(making) 
little more than a collection of platitudes and tru­
isms,"2%
An evident point in the total controversy is that the 
public schools are not Godless in that administration and fac­
ulty are concerned about teaching the religious heritage of 
moral and spiritual values, A review of the flood of litera­
ture on the question Indicates evidence of great concern. 
School officials and faculty are, for the most part, well 
aware of the spiritual needs of children. However, the area 
of religious faith and belief is so circumscribed by contro­
versy and government decree that the public school is inclined 
to maintain an "off-limits" policy, As a result the religious
78
needs and beliefs of school children are relegated to an In­
significant background position. This tendency Is viewed with 
alarm by religious leaders and others who are aware of the 
mounting secularism of the age. The American policy of church- 
state separation has been Interpreted by some teachers to ex­
clude even the mention of religion In the public classroom.
It Is only a step from avoidance to Irrelevance, Johnson, 
professor of Education at Columbia University, has stated that
"what the public school ignores will In the end be Ignored b%
»21those It educates.”
Thus a rather unique dilemma la revealed. The moral 
and spiritual needs of children are recognized In various gov­
ernment and education publications, In statements by educators 
and religious leaders, and. Indirectly In the wave of anti­
social behavior among the young. In enlisting the aid of 
various agencies to help meet the need the public school comes 
under close scrutiny. However, the spiritual and moral needs 
of children are met by the public school with rather cool re­
serve. Various statements Indicate that the philosophy of the 
secular public school prevents the education of the "whole 
child."2^ There Is a basic Inability of the public school to
23Johnson, E. F., "Religion and Public Education, A 
Major Force In History and Contemporary Life," Vital Speeches, 
p. 334, March I, 1950.
2^Fallaw, Wesner, "On Educating the Whole Person," 
School and Society, p. 101, April 3# 195^*
79
take an active role In religious instruction because the doc­
trine of church-state separation and various state laws pro­
hibit sectarian Instruction in the public school. In searching 
for a practical solution to the problem, the Christian Church 
has evolved several religious agencies, among which are the 
Sunday school movement and the releaeed-time plan.
The Church and Released-Time
As the public school is neither equipped nor designed 
to teach religious matters, there is a resultant gap in the 
educational program, for which outside provision needs to be 
made. Long before the released-tlme plan was proposed, the 
Sunday school assumed major responsibility for religious educa­
tion. This agency was readily adopted by American churches as 
a possible answer to the secular public school. However, it 
was later recognized that because of inherent limitations the 
Sunday school could, at beat, provide a limited answer to the 
religious needs of children*
The inadequacy of the Sunday school. The inadequacy of 
the Sunday school Is attested to by the Christian church 
itself. It is clearly recognized by the Christian church that 
the pittance of time devoted to this religious school is not 
sufficient to Instill the desired measure of spiritual know­
ledge. Hulford, an authority on public school board
80
administration, mentioned that it has been established that a 
child attending Sunday school spends an average of only 12 
hours a year in religious training*^ The Sunday school, as 
the Protestant church’s only educational agency, has proven 
Inadequate to the herculean task of providing necessary spir­
itual guidance to the children of the nation. This is not to 
say that the Sunday school has not done an excellent Job as 
far as it was able* Countless Individuals owe most of their 
basic Christian knowledge to dedicated ministers and teachers 
who were Sunday school teachers. However, it is readily rec­
ognized that there are gaps in this religious educational en­
terprise that demand constructive thinking.
Some of the basic inadequacies pointed out in the Sun­
day school include antiquated teaching techniques, untrained 
leadership, poor lesson continuity, and a limited outreach.
In reviewing the contemporary character of the Sunday 
school. Bower commented to the effect that the movement was 
more charismatic than educational in nature, As a result of 
its sectarian, denominational affiliation, vast numbers of the 
nation’s children have remained untouched, as shown in the 
StatementI *2
2^Mulford, H, B,, "As Public Schools Default on Reli­
gion,w School and Society 6l|.*i|J43, December 21, 1914-6,
2^Fallaw, Wesner, nIe the Sunday School Doing the Job?" 
Protestant Church Building and Equipment, p. 9, November, 1959.
81
The temper of the movement was pletlatlc rather 
than educational In any fundamental and scientific 
sense# It has throughout remained a lay movement, the 
teaching of religion having been committed to consecrat­
ed but untrained persons who were otherwise profession­
ally or vocationally engaged. Its educational objectives 
have for the most part been concerned with the teaching 
of the Bible as an authoritative revelation of divine 
truth# While the public school addressed itself to the 
total child population of the nation, and to Increas­
ingly larger numbers of Its youth, the Sunday school 
followed the sectarian organization of American Prot­
estantism# As a result, it has ministered for the most 
part to the child and youth constituencies of the sev­
eral denominations leaving more than half of the total 
childhood and youth of the nation untouched#2'
Disturbed by a decided lack of religious knowledge on 
the part of college students, Jarrell, a Yale professor, made 
a study of Sunday school literature. Hls findings Indicated 
that there was little continuity in lesson planning and little 
defense or explanation of religious faith.^G
Shrader, an Episcopalian minister, leveled serious 
charges against the Sunday school in words Indicating a need 
for a major overhaul In method of operation. He contended 
that the program that existed In many areas was faltering In 
the task of religious education, as shown in the statementI
Although there have been great changes In the 
past 10 years, the U# 3# Protestant Sunday school Is 
often nothing more than a glorified baby-sitting *2
27Bower, W. C., The Church at Work In the Modern World, 
pp* 111-112#
2oJarrell, H. H., "Sunday Schools Don't Teach,"
Atlantic Monthly, pp. 5>7-3>9» December, 1950#
62
service, or a place where children listen to grotesque 
stories and memorize verses, or a Sunday morning social 
hour characterized by a considerable amount of horse­
play.*.. Some parents, I know, ask nothing more of 
Sunday school than that it keep their children occupied 
and out of the way for one hour a week. For such parents 
the American Sunday school is unquestionably fulfilling 
its function. But for parents who ask something more of 
Sunday school— — an introduction to Christianity, an edu­
cation in the life and principles of the church, a prepa­
ration for Christian living— there is much cause for
dissatisfaction.29
Shrader cited Morton, a leading New England figure in 
religious education, to substantiate his contention of Sunday 
school inadequacies. Morton had written that the Sunday school 
was doing a questionable job of character building. She ex­
pressed her concern for low Sunday school morale in the follow­
ing terms*
The chances are the director of religious educa­
tion faces a job that commands little respect on the 
part of either church or community, for the reputation 
of church schools across the country is pretty low.
The director knows and the people know that the ’good 
old Sunday school* broke about as many young Christians 
as it built.™
Shrader caused a storm of controversy with his article 
that produced outspoken protest to its implications. The ed­
itors of Christian Century replied that in spite of Inherent 30
2^Shrader, Wesley, wOur Troubled Sunday Schools,M Life 
p. 100, February 11, 1957.
30Ibld.. p. 101.
weaknesses in the Sunday school the people of America were the 
recipients of great spiritual advantage because of its program. 
Thousands of ministers and laymen have freely contributed of 
their time and effort to provide the only spiritual training 
many individuals have received.31 The implication that only a 
few American churches were interested in revising their educa­
tional programs was unfounded because there has been a move In 
this direction by nearly all denominations.
Religious leaders have been encouraged in the fact that 
Sunday school data of 1954 Indicated the enrollment was de­
cidedly increasing. The National Council of Churches of Christ 
in America reported that nearly 38 million pupils were enroll­
ed in Sunday and Sabbath schools. This represents an increase 
of almost 13 million over 1947 and constitutes a rate of in­
crease more than double that for the populatlon.32
A further source of encouragement to religious leaders 
has been the public support rendered the movement by certain 
persons In official capacity. Hoover, the Director of the 
Federal Bureau of Investigation, has written a pamphlet in 
which he stated that the Sunday school was one of the best 
answers to juvenile delinquency. Some judges have thought so 
highly of the Sunday school that they have sentenced juvenile
31«The Trouble With the Troubled," The Christian Cen- 
tury» p. 318, March 13# 19S7e
^dlShrader, on. cit., p. 101.
33
delinquents to "attend Sunday school every week for a year."33 
It la apparent, however, that the Sunday school by 
Itself cannot fully supply the needs of children for spiritu­
al guidance. Its outreach is limited and it is beset with in­
ternal difficulties. In searching for some educational agency 
to supplement the work of the Sunday school the plan of re- 
lea sed-tlme was discovered*
Released-time bridges the gap. Released-tlme bridged 
the gap between the limitations of the public school in teach­
ing religious belief, and the inadequacies of the Sunday 
school in meeting the spiritual needs of children.34 In ac­
cepting the fact that the Sunday school was an inadequate 
means of meeting the need, religious leaders agreed that some 
means of reaching the child during what he considered his 
"business hours" had to be devised. It was believed that if 
religion were more closely associated with the public school 
it would tend to receive more serious consideration as being 
relevant, important, and not just a Sunday affair. Such a 
program would not infringe on anyone’s religious liberty, as 
the Individual was free to participate or abstain. The plan 
would not involve public support of religious activities and, 
since all denominations would be welcomed as participants, no
85
preferential status for particular churches would result.
Through released-tlme a unique opportunity Is presented 
to bring the work of the church and school together In the 
life of the child. The teacher of a released-tlme class can 
add a religious Interpretation to the work of the public 
school beyond what Is possible for the most dedicated public 
school teacher. In released-tlme classes In religion the con­
tributions of the church In the history and work of the world 
are seen alongside the rest of the story of mankind, not only 
as an historical fact but as a reflection of the mission and 
purpose of the church, Released-tlme for religious education 
helps to satisfy the need for Identifying religion In the 
child's mind with week-day as well as Sunday Iife.-^
Usually the released-tlme program is educationally far 
more efficient than the Sunday school because the quality of 
teaching In released-tlme classes is comparable to that found 
In the public schools, As teachers of released-tlme classes 
are usually paid, the churches can demand proper training and 
thorough preparation for each session. Thus the program can 
provide religious instruction and experiences on as sound an 
educational base as the public school teacher can provide.
The problems of irregular attendance faced by the Sun­
day school, caused by bad weather, indifference, conflicting
"^Goddard, A, L., "Week-Day Church School-A Bridge,M 
International Journal of Religious Education, p* 12, May, 1958,
86
interests, or poor clothing are almost eliminated in the re- 
leased-time program. There is much more punctuality and regu­
larity of attendance in the released-time plan. The program 
is regarded almost as an "extra-curricular” activity of the 
school life.
It is also true that the released-time program reaches 
many children who never enter the door of a Sunday-school 
class. Miller, Executive Secretary of the Virginia Council of 
Churches, reported that less than half the children aged six 
to sixteen are enrolled in Sunday schools of this country, 
after three centuries of separate denominational effort. This 
is in contrast to released-time classes in which 95 per cent 
of the pupils who have opportunity to participate have en­
rolled.-^ The released-time program is a religious agency of 
effective outreach as indicated in the following statement:
Neither the Sunday school, the vacation church 
school, nor the young peopled societies, nor all these 
combined, reach as high a percentage of the total youth 
group In a great many communities as does the weekday 
church school.37
The use of religious instruction as a possible deterrent 
to juvenile delinquency has been mentioned earlier in the
-^Miller, M. C., ttlReleased-Time1 Seen More Effective 
Than Sunday Schools,” Telescope-Messenger, p. 6, March, 1958.
3?Thayer, V. T., Religion in Public Education, p. 88.
chapter. The observations of various individuals would tend 
to substantiate this contention, Juage Fawcett testified that 
in the thirty years in which he presided in the Supreme Court 
in Brooklyn, there were only two boys who came before him for 
sentencing who at the time were attending organized religion 
classes,3^
A publication issued by the Division of Christian Edu­
cation of the Protestant Council of New York City cited the 
need for released-time classes as a curb for juvenile delin­
quency, as follows!
87
What is the situation in religious literacy in 
New York City? There are 1,200,000 children receiving 
education in public, parochial, and private schools. 
Only 700,000 of these children are receiving any or­
ganized spiritual nurture. The remaining 500,000 
children are a menace to society, to themselves, to our 
country and our country’s future. Spiritual Illiteracy 
must be abolished for the sake of the children and for 
the sake of the nation, Released-time for Religious 
Education is the next best step we know in stamping 
out the spiritual illiteracy in our c h i l d r e n * 3 9
Shaver notes that seientifically-aeeurate measurements 
of the behavior of children enrolled in released-time classes 
are as difficult to secure as they are in the case of other
f
character-building agencies— the public and private schools, 
the youth agencies and even the churches. But there are *39
The Case for Releaaad-Tlme,1' Education, p, 372, 
February, 1951,
39
Thayer, V, T,, Religion in Public Education, p, 86.
68
otrong convictions that each of these makes for a better ccm- 
munlty and for a higher type of personal and social conduct,^0 
Judge Glasser of Garfield County, Enid, Oklahoma, is convinced 
that released-tiiae Ie an aid in curbing juvenile delinquency, 
as noted in hls statement:
Juvenile delinquency in the County,«*waa becoming 
progressively worse each year until a noticeable correc­
tion in the pattern was observed among a group level of 
youngsters who were members of the first class to partic­
ipate in the Associated Church program for releaaed-time 
teaching. Therefore, the only reasonable conclusion to 
be derived from such an analysis was that Christian edu­
cation, ,,had caused the noticeable decline in unlawful 
behavior characteristics of those youngsters who par­
ticipated in the program when compared with the activ­
ities of the older children who did not so participate,
I am firmly convinced that releasing children from 
academic instruction in the public schools for one hour 
each week to enable the students to receive Christian 
education, which the majority of the students would not 
otherwise receive, is the greatest step the community has 
taken in answer to the problem of juvenile delinquency,4-1
In the plan of released-time an effort Ie made to in­
tegrate religion in the total learning experience of the child 
in a manner not detrimental to the principle of church-state 
separation. The proponents of the program believe that this 
particular experience will make a unique contribution to the 
education and experience of children and enable them to in­
terpret their everyday experiences in a moral and spiritual
^Shaver, Erwin, Week-Day Church School, p# ILO,
^1Ibld.
89
atmosphere. In the recognition that religion is a week-day 
experience of concern along with school work, play, and other 
week-day activities, the program Is conceived as a bridge be­
tween the school and the church, helping to Integrate into the 
life of the child the sometimes divergent teachings of the two 
institutions.
There are genuine problems in attempting to evaluate 
the released-tirae program as to real results. While a judg­
ment on the over-all success or effectiveness of the program 
Is almost impossible (by reason, among other things, of the 
varying objectives sought by different communities) some trends 
are observable. It is the general conviction of religious 
leaders and educators^'- that the released-tirae program is mak­
ing good. In those communities where the recommended standards 
have been followed, it is a most effective school of religion. 
Shaver noted that the program has proven to be an effective 
agency in reaching a great number of children with no church 
affiliation.^ Then, too, the plan has brought about a close 
relationship between the three agencies most responsible for 
the Chlld1S education— the home, the public school, and the 
church.Wi Although one of the most common criticisms of the *4
^2Larson, J. L., nA Superintendent Looks at the Weekday 
School of Religion," Religious Education, p. I, January, 1956.
^Shaver, Erwin, Week-Day Church School, p. 138.
44IMd.
90
releaaed-tlme program is that it is devisive, investigation 
indicates excellent interdenominational cooperation, respect, 
and appreciation both for differences and common goals
Aside from these direct contributions to the religious 
education of American children, the released-time movement 
has made significant concomitant contributions. It has served 
to keep alive the importance of religion in all education. It 
has spurred and encouraged educational leaders to place a 
larger emphasis upon religion in the public schools. Uninten­
tionally, it has caused America to face the need for a more 
accurate Interpretation of the First Amendment, defining the 
points at which church and state shall be separate and those 
at which they may cooperate for the common good.^  Ttiis last 
point will be further elaborated upon in the following chapter.
The ultimate objectives of Christian education and thus 
of released-time are worthy of consideration at this point.
The objectives of Christian education. The National 
Council of Churches, Division of Christian Education, has of­
ficially adopted two statements regarding the objectives of 
Christian education. These statements, "The Goals of Christian 
Education of Children," and "Objectives of Christian Education" 
embody the vital principles sought in the released-time program.
^Harris, Elizabeth, "Protestant Weekday Religious Edu­
cation in Boston," Education, p. 383# February, 1951«
^Shaver, Erwin, Week-Day Church School, p. UA#
91
The "Objectives of Christian Education" are listed as 
follows%
I. Christian education seeks to foster in growing 
persons a consciousness of God as a reality in human expe­
rience, and a sense of personal relationship to him.
2# Christian education seeks to develop in grow­
ing persons such an understanding and appreciation of 
the personality, life and teachings of Jesus as will 
lead to experience of him as Savior and Lord, loyalty 
to him and his cause, and will manifest itself in daily 
life and conduct.
3. Christian education seeks to foster in growing 
persons a progressive and continuous development of 
Christlike character.
4. Christian education seeks to develop in grow­
ing persons the ability and disposition to participate 
In and contribute constructively to the building of a 
social order throughout the world, embodying the ideal 
of the fatherhood of God and the brotherhood of man.
5>. Christian education seeks to develop in grow­
ing persons an appreciation of the meaning and impor­
tance of the Christian family, and the ability and dis­
position to participate in and contribute constructively 
to the life of this primary social group.
6. Christian education seeks to develop in grow­
ing persons the ability and disposition to participate in 
the organized society of Christians— the Church.
7. Christian education seeks to lead growing per­
sons into a Christian interpretation of life and the 
universe; the ability to see in it God's purpose and 
plan; a life philosophy built upon this interpretation.
8. Christian education seeks to effect in growing 
persons the assimilation of the best religious expe­
rience of the race, pre-eminently that recorded in the 
Bible, as effective guidance to present experience.47
^Shrader, og. cit.. p. 104.
92
These objectives, were formally adopted in 1930 by the 
International Council on Religious Education, and were later 
adopted by the Division of Education of the Rational Council 
of Churches. The objectives form the core of the philosophy 
of Christian education*
In considering the specific contributions of the re- 
leased-tirae movement to the foregoing Christian education 
goals Shaver notes the following*
I* The weekday church school, in furnishing more 
time for Christian education, allows for a stronger 
teaching impact and a greater likelihood of progress to­
ward these goals* Among others a "consciousness of God" 
and an "appreciation of Jesus," by this additional time 
provision, are deepened and lead to a clearer under­
standing and a closer personal relationship*
2. The opportunity for repetition which weekday 
church school sessions give fulfills an important educa­
tional principle. Christian character growth requires 
repeated practice under guidance*
3* The holding of the classes on the weekday not 
only reinforces the Sunday teaching, but because of the 
time factor strengthens the importance of religion in 
"daily life and conduct."
4* The relationship of the weekday church school 
to the public school allows for significant correlation 
of the study of religion with public school studies* The 
closer this correlation, the greater the development of 
a consistent and integrated "Christian interpretation of 
life and the universe*"
5* The school atmosphere characteristic of most 
weekday religious education is a helpful complement to 
the equally valuable church atmosphere provided by other 
agencies of Christian education* This tends to 
strengthen the pupils* respect for the study of religion.
93
6* The nature of the weekday church school In Its 
organization and pattern makes It possible to reach a 
high proportion of children unrelated to the church and 
lead them to "participate In the organized society of 
Christiana— — the Church*"48
In a comparison of the goals of Christian education with 
those of general education Shaver noted the limitations of each 
as shown In the following list*
I* The weekday church school allows for the In­
clusion of the positive teaching of religion and the 
Bible In the Chtld1S everyday education, which cannot be 
done In the public school*
2* Similarly Christian teaching which emphasizes 
personal conEoitraent and church membership, not possible 
In public education, can be carried on with freedom.
3* The weekday church school, to fulfill Its ob­
jectives completely, can and should supplement the social 
studies taught In the public school by giving them a 
Christian Interpretation and motivation*
4« Likewise, the weekday church school can and 
should complement the physical science studies of the pub­
lic school by Insisting that underlying scientific laws 
and facts are the purposes of a wise and beneflelent 
GrOd*
5* The literature of the Bible and other religious 
literature taught in the weekday church school are a 
needed supplement to and natural enrichment of the lit­
erature studies program of the public school.
6* The weekday church school teaching program- 
affirming faith In the fatherhood of God as well as in 
the brotherhood of man— gives both motivation and con­
tent for the teaching of spiritual values In the public 
school, without which these values may not be dis­
tinguished from community ethics.49
^Shaver, Erwin, Weekday Church School, pp. 6-7* 
^9Ibld., p. 8.
9k
In the foregoing liots of goals it is evident that 
there are certain well-defined aims of released-tlme. How 
effectively these aims are being realized is difficult to as­
certain. It remains to be seen whether released-tlme can fully 
accomplish all the purposes of its organization.
Summary
The need of children for moral and spiritual guidance 
is attested to by* (I) various education and government con­
ference statements, (2) the voice of educators and religious 
leaders, and (3) the increase in criminal activity among the 
young people of America.
In assessing the position of various agencies respon­
sible for teaching moral and spiritual truth the public school 
comes under close scrutiny* However, the limitation caused by 
church-state separation poses a dilemma on this point and pro­
hibits the secular public school from teaching sectarian be­
lief. The public schools are maintained as secular schools 
because; (I) limitation serves as a safeguard against dis­
crimination of religious minorities, (2) encourages religious 
liberty, and (3) allows the church and state to operate in­
dependently under the assumption that each can best function 
in this manner. Thus the secular public school is unable to 
fully meet the need for religious orientation.
The Sunday school as the only fully established Protes­
tant educational agency is not sufficient in itself for the 
task of Imparting spiritual guidance for the nation's children. 
Only about half of the nation's children are enrolled in Sun­
day school and these receive an average of only about 12 hours 
of religious instruction a year. Thus as the principle means 
of spiritual education the traditional Sunday school is sadly 
inadequate.
The program of released-time for religious education 
is proposed by religious and education leaders as a possible 
solution to the dilemma. The proponents of the plan believe 
that the public schools should not monopolize the full five 
days of the school week, but a reasonable portion of this 
week-time should be made available to the churches for reli­
gious education. It is proposed that by this means the work 
of the Sunday school could be bolstered and effectively supple­
mented, Within the framework of acceptable standards the 
church contends that it can complement the work of the public 
school and not violate the church-state separation principle.
By means of released-time the church proposes to bridge the 
gap between school and church, integrating secular and sectar­
ian knowledge in the life of the child.
In concluding the chapter the aims of Christian educa­
tion are noted as the aims of the released-time program. The 
leaders of the released-time plan maintain that the program
95
will effectively aid In the achievement of the goals of Chris­
tian education*
At this juncture attention will be focused on some 
legal aspects and Implications of released-time as contained 
in the following chapter.
96
97
CHAPTER IV
SOME LEGAL RAMIFICATIONS OF RELEASSD-TIME
A picture of the released-time program would be incom­
plete without a description of the legal gantlet the plan has 
encountered. This chapter will seek to provide insight con­
cerning state and federal court decisions and the resultant 
action precipitated by these decisions. The following mater­
ial is organized to afford consideration of, (I) Early En­
tanglements in Litigation, and (2) United States Supreme Court 
Decisions,
Early Entanglements in Litigation
The released-time movement has had to meet severe tests 
to establish and maintain its standing in the religious educa­
tion world. The early entanglements in litigation produced 
some notable findings and provided thoughtful attention to 
problem areas in the released-time plan.
A hazy court focus. Early legal cases were hampered by 
a hazy court focus regarding the line of separation that mark­
ed the boundary between church and state.I Countries with 
established state churches preclude any difficulty in the 
separation of secular and religious education. One main 1
1Cope, H, F., Week-Day Religious Education, p, 15>5>.
98
source of authority is responsible for both types of educa­
tion and they can utilize the same buildings, facilities, and 
instructors if they wish. When, however, the church is sepa­
rate from the state, the difficulties of establishing bound­
aries for each Is involved. This is clearly reflected in the 
problems of separation between religious and secular educa­
tion. While the state can benefit from the character develop­
ment involved in the influence of religion, the churches are 
fully aware of the advantages of secular knowledge gained by 
their members, Zollman reports that there is no clear line 
of demarkatlon that clarifies fully the boundaries of church 
and state, but rather a broad zone or area.2 For example, 
while some states forbid the reading of the Bible in the pub­
lic schools, others require that it be read daily.3 Then too, 
the sectarian atmosphere of the public school is permeated 
during the observance of certain religious holidays with carol 
music, religious dramatization and ceremonies which involve
2Carl Zollman was an attorney at Milwaukee, Wisconsin, 
and author of American Civil Church Law and Church and School 
in the American taw. Cope, op. clt., p. 155V
3Louisiana, Illinois, and South Dakota courts hold 
that Bible reading in the public school violates the reli­
gious freedom of non-Christians. On the other hand Alabama, 
Arkansas, Delaware, Florida, Georgia, and Idaho require that 
a portion of the Bible be read daily, and a number of other 
states authorize its reading. See* National Education As­
sociation Research Bulletin. Number I4., pp. 1^5-196, Decemoer,
1555%
a definite religious climate#^ A careful study of these and 
other related practices of eo-mingling of religion and educa­
tion reveals that the courts are not consistent in views re­
garding these practices* Of course many practices exist sim­
ply because they have never been challenged in the courts* 
However, it is evident that a sharp legal focus on these and 
other related Issues is clearly missing in many areas of this 
country* Separation of church and state is proclaimed on one 
hand as an absolute and complete deletion of any religious 
connections,5 while on the other it is said to give allowances 
for some permissible governmental sanction.&
It is apparent that separation of church and state mean 
different things in different areas and that the principle is 
constantly being challenged* Thus it can be readily under­
stood that an idea as novel and controversial as released-time 
for religious education would encounter some difficulty In be­
coming a legal entity and in becoming established in various 
parts of the country* Several of the state court decisions on 
released-time are worthy of consideration at this point*
^American Council on Education, The Function of the 
Public Schools in Dealing; With Religion, p, I*
^Bryson, J* R., wHending the Breach in the Wall of 
Separation," Christian Century 6$i65l# June 30, 19^8*
^Lardner, L* A*, wHow Far Does the Constitution Sepa­
rate Church and State?” American Political Science Review 
!45$ 130, March, 19$1,
99
141116
State court decIalong. Perhaps the earliest state 
court decision bearing Implicitly on the released-tlme program 
was handed down some ^br years ago In Mount Vernon, New York.? 
The program was ruled illegal on the basis that It violated 
the compulsory attendance law of the state. In order to elim­
inate any abuse of the privilege of leaving the school while 
it was in session, the Mount Vernon schoolboard adopted a plan 
for controlling attendance records. In order that parents 
might indicate their choice of church they wished their chil­
dren to attend, the school printed preference cards. Other 
cards were supplied to the Instructor at the church In order 
that the child's attendance might be reported. These cards 
were all printed in a public-school shop during school hours, 
however, the Mount Vernon Committee on Week-Day Religious Ed­
ucation paid all costs involved. The schoolboard attempted 
to walk the line of separation between church and state with­
out violating the compulsory attendance law or the constitu­
tional provision against aid to sectarian education. That 
they failed In this attempt is evident in the 1925 court de­
cision which declared that the plan ran counter to the com­
pulsory attendance law; and too, having the cards printed In 
the public school was an illegal aid to sectarian education.®
?Steln v. Brown, 211 N.Y.S. 822 (1925).
^National Education Association Research Bulletin. Vol. 
XXXIV, No, I4., p. 199, December, 19^6.
100
101
The Judge summarized the Mount Vernon ease In the following 
words I
The fact that no particular denomination was fa­
vored or Intended so to be by this action of the board 
of education does not affect the question,.«• I find 
nothing whatsoever In the Education Law authorizing 
either the board of education, the state commissioner 
of education, or the education department to change, 
limit, or shorten the time of attendance.... Educa­
tion Law...prescribes the Instruction required In pub­
lic schools. Religious Instruction is not one of them. 
Consequently It would be unlawful and unauthorized for 
a board of education to substitute religious Instruc­
tion In the school in place of the instruction required. 
To permit the pupils to leave the school during school 
hours for religious Instruction would accomplish the 
same purpose, and would In effect substitute religious 
instruction for the Instruction required by law.9
In 1927 another case involving released-ttme was put 
before the New York courts. This case. Involving the program 
of White Plains, New York, revolved around the fact that the 
cards that were used In reporting preference and attendance 
were not furnished by the school. Thus the only clear con­
nection with public funds or property involved was the scant 
time of the teacher In issuing and receiving cards, excusing 
pupils, and determining if the parents1 wishes were being 
carried o u t . T h e  suit was brought challenging the released- 
tlme program by Lewis, president of the American Free Thinkers 
Society, on the charge that the principle of church-state 9
9Stein v. brown, 211 N.Y.S. 622 (1925).
^National Education Association Research Bulletin.
Vol. XXXIV, No, i | p. 199, December, 1956.
102
separation was being violated. However, the legal validity 
of the program was established by a unanimous court decision 
to the effect that the general compulsory attendance laws did 
not require every child to be In school every hour of each day 
the schools were in session, and the church-state relationship 
was not being violated. Since the children were dismissed for 
religious instruction when no recitations were scheduled, it 
was deemed completely legal. The court record contained these 
words t
It is natural that parents should wish their 
children to have religious instruction at any favor­
able opportunity. It is not thought wise that it 
should be given directly in the school. But, when 
the children are assembled, they may be sent else­
where. We are told that in 23 other states there 
are In force methods similar to those employed here.
The commissioner and local authorities have adopted a 
benevolent policy. In which the interests of both par­
ents and children are considered. They recognize that 
all education Is not acquired in the schools; that, ex­
cept for subjects legally prescribed, the parents may 
select the studies their children shall pursue; that it 
is the right of parents to direct the destiny of their 
children and guide them along paths of filial duty, as 
well as in those of obligation to the state,...and that 
ft belief in religion is not foreign to our system of 
government.H
The foregoing court decision mentioned "23 other states” 
where a similar plan of religion classes operated in 1927.
In 1958 state laws permitting absence for religious 1
11People v. Graves, 219 H.Y.S. 189. Aff*d 156 N.E. 663
(1927).
103
Instruction were found to exist In only 13 s t a t e s I n t e r ­
estingly enough, local-school authorities have approved and 
allowed the operation of released-tlme programs regardless of 
the existence or nonexistence of state laws and In most states 
the plan has proceeded unchallenged.
The released-tlme plan of Loa Angles, California, was 
challenged In court by a taxpayer who asserted the state con­
stitution was being violated In that It prohibits aid to a 
religious sect. Church preference cards and publications de­
scribing the program were printed with school monies. Public 
school teachers kept attendance records; however. It was as­
serted that the pupils were not under the control of the pub­
lic school during their absence for sectarian Instruction, 
Pupil transportation to the religious schools was underwritten 
by the Los Angeles Interfalth Committee, In the decision 
handed down In 1947 the court asserted that the plan was valid 
as there was no appropriation of public money In support of 
any particular sect and there was no religious Instruction 
within the public school system,^ This decision Is clearly 
at variance with the Mount Vernon, New York, decision of 192$ 
which stated quite a different opinion. *S.
^These states are! California, Indiana, Iowa, Ken­
tucky, Massachusetts, Maine, Minnesota, New York, Oregon,
S. Dakota, Pennsylvania, W. Virginia, New Mexico. See ap­
pendix of this thesis for copy of state laws.
^Gordon v. Board of Education, 178P. (2nd) 488 Calif,,
(1947).
One of the moat Important legal cases regarding re- 
leased-ttme had Its beginning in Champaign, Illinois, in 1945 
when McCollum (Mrs. John P. McCollum) filed suit against the 
program. McCollum, who termed herself a "rationalist," claim­
ed that the action of the Champaign Board of Education in per­
mitting released-time was in clear violation of the First and 
Fourteenth Amendments of the Federal Constitution. As the 
plan operated in Champaign, children from grades four to nine 
inclusive received thirty minutes of religious instruction 
each week. This plan had been in operation since 194 0  when 
the Champaign Council on Religious Education was formed by 
cooperating Protestant, Catholic, and Jewish Bodies. This 
collective group was given permission by the Champaign Board 
of Education to offer classes in religion to the grades In­
dicated. Although the teachers for the program were employed 
by the Council on Religious Education, their status as quali­
fied teachers was sanctioned by the school superintendent, and 
the content of their curricula was controlled by him.^4 
Church preference cards were distributed to parents that they 
might indicate if they wished their child to attend these 
courses, and if so, in which group they would prefer he be en­
rolled. These cards, and a twenty-five cent charge for ma­
terials (crayons, paper) were returned to the school by the
^Tll. ex rel. McCollum v. Board of Education, 333 U.S. 
207 (1948).
104
chlld#^ Actually, only three class sections were conducted, 
taught by Protestant teachers. Catholic priests, and a Jewish 
rabbi. The Jewish rabbi shortly discontinued his class as It 
did not function as well as the others, No academic credit 
was given for these courses,
At first It was assumed that all children would par­
ticipate in the program and thus no provision was made for 
any alternative. But Mrs, McCollum, wife of an associate 
professor In the Department of Horticulture, University of 
Illinois, did not enroll her son, James Terry, when he entered 
the fourth grade. During the last half of his fourth-grade 
year he was enrolled In the Protestant class, James Terry was 
transferred to another school when he entered the fifth grade 
and was not enrolled in any religion class. Due to overcrowd­
ed conditions James was sent to ait in a music room and once 
In the hall during the religion classes. When Mrs, McCollum 
complained to the school authorities about this procedure, 
James was thereafter sent to another fifth grade classroom to 
study during the alloted periods. As a culmination of this 
situation, McCollum started proceedings for the court case.
She stated In expressing her stand that she was not fighting 
against religion but against a constitutional violation as in­
dicated in the statement!
io5
^MeCollun, V, C,, One Woman's Fight, pp. 17-18,
106
One of the moat common misapprehensions about the 
entire McCollum case is that I was waging an all-out 
fight against religion. Nothing could have been farther 
from the truth* I had no desire to attack formal reli­
gion nor any wish to convert anyone to my particular 
theological bias* My objection was on constitutional 
grounds, and my action was one I could have brought with 
equally firm convictions had I been a member of any of 
the 250-odd sects flourishing in this country,* 1”
In the actual court proceedings the plaintiff was aid­
ed by a Unitarian minister, Schug, and was represented by a 
Chicago lawyer. Chapman, Chapman, who was recommended by the 
Chicago Civil Liberties Committee (independent), was retained 
by the Chicago Action Council, an organisation which had been 
set up to oppose released-tlras. These sponsors announced 
that they were raising #10,000 to present this case to a 
higher court if necessary.^ Associated with the defense In 
this case was the Chicago Federation of Churches and the 
Illinois Church Federation,
During the course of the trial Mrs, McCollum charged 
that her son James (his teacher referred to him as a problem 
child) had been ridiculed by classmates for not attending the 
week-day classes, Mrs, McCollum's father, Cromwell, a pro­
fessed atheist of Rochester, New York, and president of a Free 
Thinkers Society testified for the plaintiff, He defined
16Ibid., pp. 10-11.
1^Fey, H. E., "Test Legality of Release-Time,1 Chris­
tian Century 6211099# September 26, 19*4.5#
107
religious worship as !,a chronic disease of the Imagination 
contracted in childhood*"^ Shaver reported that one of the 
high-lights of the trial occurred when James Terry McCollum 
was asked why he wished to enroll in the religion classes#
He frankly replied that he enjoyed the class and wished to 
learn more about religion. Hla reply as recorded Indicated 
an Interest in the program as shown In his statementt
I was Interested in this class In religious ed­
ucation. I wanted to take it..,. I do not like arith­
metic and spelling very well, I like religious educa­
tion a lot better. I recall that Miss Chapin brought 
to school a lot of different papers and things, and some­
times the kids passed one on my desk. I was also inter­
ested in the little ornaments she brought from China and 
different places,... I wanted to hear Miss Chapin's 
opinion.... One of the reasons I liked to take the reli­
gious education course was because I was anxious to know 
the way they taught them.... I kind of want to know a 
little more about religion. I do not know much about 
it.,.. After I took the course when I was in the fourth 
grade I wanted to learn still more. I enjoyed the work 
over there.19
The McCollum counsel in a rather wordy wind-up of the 
case labeled the released-time plan one of "religious fascism" 
that was designed as a pressure-type program to get more chil­
dren into religion.2® The Chicago attorney. Chapman, based
l®nTo Highest Court," Newsweek 26t8f?, September, 1914-5.
^Abstract of Record in the case of McCollum v. Board 
of Education of School District 71, in Circuit Court of Cham­
paign County, pp. 228-230. See: Shaver, B. L., The Week-Day 
Church School, pp, 16-17.
20nTo The Highest Court," 0£. cit., p. 85.
108
his Ollent1S case on the following summary of the Champaign 
program*
An establishment of religion Is grafted on to 
public school education, church and state become united 
In the classroom, worship Is established In the lives 
of lndlacrlmlnatlng Infants, religion la regimented, 
public education la controlled and censored privately 
by sectarians and pupils are taught what to believe; 
proselyting Is practiced among little children of ra­
tionalists and humanists and of parents desirous of 
avoiding churches and religions and of parents belonging 
to denominations too small to employ their own private 
teachers for said public schools; and public schools be­
come fields for private missionaries and for rivalry of 
religious sects.21
The defense for the case argued that the board of educa­
tion had the right to retain the program because*
I* The board of education had only acted within Its 
legal discretion In granting permission for vol­
untary religious education within the schools.
2. No Infringement of state and federal provisions 
had been made by the program because the pro­
hibition of an establishment of religions In the 
first amendment is not hostile to religion as such.
3. The law forbidding the use of public funds for a 
sectarian purpose was not violated by the program 
since It was not sectarian and no public funds were 
used.
Also, the defense maintained that no coercion or pressure was 
placed on any child who did not wish to attend the classes, 
unless the very existence of voluntary courses could be
21Fey, 0£. clt., p. 1099.
109
construed as constituting pressure.22 On January 26, 194.6, 
the Sixth Illinois Circuit Court denied the petition for a 
writ of mandamus and declared the existing program legal. In 
this decision the three judges Involved stated that no con­
stitutional or statutory rights of McCollum were violated by 
the Champaign system of released-tlme as shown In their sum­
mary statement:
What It all amounts to Is that the pupils who 
take religious education use a thirty-minute study 
period which otherwise would have been devoted to study 
for recitation In their regular classes; that on this 
released-tlme they study religious education; while 
those who do not take religious education simply 
have a thirty-minute study period while waiting for the 
pupils In religious education classes to rejoin them 
for the regular secular study.23
The decision was next appealed to the Illinois State 
Supreme Court which affirmed It on January 22, 194-7.^ Thus 
by Illinois Law school boards were empowered to permit the use 
of public-school buildings for religious purposes. The pro­
ceedings at Champaign were centered In one main question con­
cerning the relation of voluntary classes In religion to cur­
rent Interpretations of the state constitution. The summary
22Ibld.. p. 1099.
2^nCourt Upholds Religious Teaching In Schools," Chris­
tian Century 63:163, February 6, 194-6.
2^People v. Board of Education of School District No.71 
N.Be (2nd) 161 (Til. 194-7).
n o
of this deliberation is contained in the following court re­
cord;
Does either the Federal or the state constitu­
tion, or both, in their guarantee of religious freedom 
prohibit voluntary religious classes in the public 
schools under the plan as described in this record?
•••Such classes do not violate the conscience of any 
individual or group so long as the classes are conducted 
on a purely voluntary basis. Freedom of religion as in­
tended by those who wrote state and Federal constitutions 
means the right of an individual to entertain any de­
sired religious belief without Interference from the 
state.
Our government very wisely refuses to recognize 
a specific religion, but this cannot mean that the gov­
ernment does not recognise or subscribe to religious 
Ideals. To deny the existence of religious motivation 
is to deny the inspiration and authority of the con­
stitution Itself.25
Perhaps the recognition of religion as a force in law 
and national life was as significant as the decision itself on 
the Champaign program. However, the issue at stake in the 
Champaign case did not rest here. The next logical step for 
the unplacated plaintiff was an appeal to the Supreme Court of 
the United States.
United States Supreme Court Decisions
In recent years the Federal Supreme Court has heard two 
separate oases of released-time programs. The Champaign,
2^Mulforti, H. B., "The Illinois Atheist Case," School
and Society 65*67* June 21, 1947*
Ill
Illinois, or McCoIIlub Case was decided by the court In 1948« 
The New York City, or Zorach Case was decided by the court In 
1952« The decision In each case reflected a substantial ma­
jority In the court.
A lepel "red IlRhtn (Vgehtl McCollum case). On March 
6, 1948» the Supreme Court of the United States ruled the 
Champaign, Illinois, plan of religious education unconstitu­
tional. The court thus granted McCollumfS petition that the 
schoolboard be ordered to adopt and enforce regulations pro­
hibiting all religious education In the Champaign school dis­
trict.
The announcement of the decision was tendered In four 
separate opinions: (I) the official opinion of the court,
(2) a concurring opinion by Plrankfurter and signed by Jackson, 
Rutledge, and Barton, (3) a concurring opinion with certain 
reservations by Jackson, and (4) a dissenting opinion by Reed. 
The Supreme Court decision was a majority vote of eight to one 
against the Champaign schoolboard. The opinion was referred 
to the Illinois Supreme Court which directed the Circuit Court 
to take the final legal action.
Justice Black, in presenting the official court opinion 
stated McCollumfS petition as follows:
Appellant's position for mandamus alleged that 
religion teachers, employed by private religious groups, 
were permitted to come weekly Into the school buildings 
during the regular hours set apart for secular teaching.
112
and then and there for a period of thirty minutes sub­
stituted their religious teaching for the secular edu­
cation provided under the compulsory education law*
The petitioner charged that this public-school reli­
gious group program violated the First and Fourteenth 
Amendments to the United States Constitution*^
The essence of the Supreme Court1S official opinion re­
volved around three main pointsI
I* Public tax-supported buildings were utilized for 
purposes of teaching sectarian education*
2* Compulsory attendance laws aided the program*
3. The schoolboard cooperated in arranging and perpet­
uating the plan.
Declaring this program unconstitutional the court maintained*
The foregoing facts show the use of tax-supported 
property for religious instruction and the close coopera­
tion between the school authorities and the religious 
council in promoting religious education. The operation 
of the state's compulsory education system thus assists 
and is integrated with the program of religious instruc­
tion carried on by separate religious sects* Pupils 
compelled by law to go to school for secular education 
are released in part from their legal duty upon the con­
dition that they attend the religious classes. This is 
beyond all question a utilization of the tax-established 
and tax-supported public school system to aid religious 
groups to spread their faith* And it falls squarely 
under the ban of the First Amendment*27
Here not only are the state's tax-supported pub­
lic school buildings used for the dissemination of re­
ligious doctrines. The State also affords sectarian groups
2^Ill. ex rel. McCollum v. Board of Education, 333 U.S. 
212 (1948)
^Ill. ex rel. McCollum v. Board of Education, 333 U.S* 
209 (1948)
113
an Invaluable aid In that it helps to provide pupils for 
their religious classes through use of the state's com­
pulsory public school machinery. This is not separation 
of church and state. The cause is reversed and remanded 
to the State Supreme Court for proceedings not incon­
sistent with this opinion.2o
Anticipating something of the stormy controversy that 
would unquestionably accompany the decision. Justice Black em­
phatically denied that the McCollum decision was hostile to 
religion. It was his opinion that the end of both church and 
state would best be served by the decision as shown in his 
statement!
The First Amendment rests upon the premise that 
both religion and government can best work to achieve 
their lofty aims if each is left free from the other 
within its respective sphere.29
As the official opinion of the Court was stated in very 
general and complex terms. Justice Jackson was moved to write 
a separate concurring opinion in which he expressed some res­
ervations. While he agreed that the issue was clearly uncon­
stitutional, he also believed that the Court was granting more 
of McCollum's petition than deserved to be granted. Justice 
Jackson expressed concern in the fact that the McCollum com­
plaint was also leveled against any influence whatsoever that
28lll, ex rel, McCollum v. Board of Education 333 U.S, 
212, (19148).
Supreme Court Bans Released Time." Christian Centurv 
65! 294, March 17, 1948.
could be labeled anything but secular in the instruction of 
the public schools, He mentioned that without the influence 
of religion the study of fine arts would be in essence 
".,,eccentric and Incomplete, even from a secular point of 
view."30 McCollum was not only petitioning for an end to the 
released-time program, but also for an end to every form of 
teaching which suggests there is a God, She wished the elim­
ination of all Bible teaching} the elimination of scripture 
recitations as "The Lord Is my shepherd, I shall not want,,,." 
Justice Jackson was not willing to concede that the Court 
should agree to all of this, as Indicated In his statement*
114
Tills court is directing the Illinois courts 
generally to sustain plaintiff's complaint without ex­
ception of any of these grounds of complaint, without 
discriminating between them, and without laying down 
any standards to define the limits of the effect of 
our decision.
Nearly everything in our culture worth trans­
mitting, everything which gives meaning to life is 
saturated with religious influences derived from 
paganism, Judaism, Christianity— both Catholic and 
Protestant— and other faiths accepted by a large 
part of the world's peoples. One can hardly respect 
a system of education that would leave the student 
wholly ignorant of the currents of religious thought 
that move the world society for a part in which he is 
being prepared,31
3°I11, ex rel. McCollum v. Board of Education, 333 U.S, 
236 (1948).
^1ltThe Concurring Opinions," Christian Centurv. on. 731t- 
737, June 15, 1949.
H 5
Justice Jackson also expressed concern that the Supreme 
Court was In danger of becoming na super-board of education 
for every school district In the nation,1'^ 2 as emphasized In 
his statement*
So far as I can see this Court does not tell the 
State court where It may stop, nor does It set up any 
standards by which the State court may determine that 
question for Itself#.*. If we are to eliminate every­
thing that Is objectionable to any of these warring 
sects or Inconsistent with any of their doctrines, we 
will leave public education In shreds*
It must be expected that, no matter what prac­
tice prevails, there will be many discontented and pos­
sibly belligerent minorities* We must leave some flexi­
bility to meet local conditions, some chance to progress 
by trial and error**•*33
Near the conclusion of his concurring opinion Justice 
Jackson gives judicial Insight regarding the difficulty of 
judging a case of this nature* He concedes that the Constitu­
tion does not define In precise terms the boundary between the 
secular and the religious in education, as shown In his state­
ment*
It Is idle to pretend that this last (case) is one 
for which we can find in the Constitution one word to 
help us as judges to decide where the secular ends and 
the sectarian begins in education* Nor can we find 
guidance in any other legal source* It is a matter on *3
^2Lee, G. C., Education in Modern America, p* 573»
33Ibid.
which we can find no law but our own prepossessions*^
A second, separate, concurring opinion was written by 
Justice Frankfurter and signed by Justices Jackson, Rutledge, 
and Barton, In this opinion the question arose regarding the 
great variety of released-tlme programs that were currently 
In operation In the United States, The four Justices made no 
pretense of casting judgment on programs other than the 
McCollum case, although It is clear that programs that were 
similar would be affected In the same way, as Indicated In 
the following statement!
116
We do not consider, as Indeed we could not, school 
programs not before us which, though colloquially charac­
terized as *released-tlme," present situations differing 
In aspects that may well be constitutionally crucial. 
Different forms which "released-tlme" has taken during 
more than thirty years of growth Include programs which, 
like that before us, could not withstand the test of the 
Constitution; others may be found unexceptionable, We 
do not now attempt to weigh in the Constitutional scale 
every separate detail or various combination of factors 
which may establish a valid "released-tlme" program,35
It was evident that programs duplicating the Champaign 
released-tlme plan would probably suffer a similar fate at 
the hands of the Court, Frankfurter pinpointed the problems 
of religious differences among children and the Indirect
3^111. ex rel. McCollum v. Board of Education, 333 U,S. 
238 (1948).
3^111, ex rel, McCollum v. Board of Education, 333 U,S. 
231 (1948).
117
pressure exerted by the school system to Induce children to 
attend In the following words;
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,,,, As a re­
sult, the public school system of Champaign actively 
furthers Inculcation In the religious tenets of some 
faiths, and the process sharpens the consciousness of 
religious differences at least among some of the chil­
dren committed to Its care. These are consequences not 
amenable to statistics. But they are precisely the 
consequences against which the Constitution was direct­
ed when It prohibited the Government common to all from 
becoming embroiled, however Innocently, In the destruc­
tive religious conflicts of which the history of even 
this country records some dark pages.36
Justice Frankfurter attempted to clarify the Court1S 
position on separation of church and state with the statement 
"Separation Ie a requirement to abstain from fusing functions 
of Government and of religious sects, not merely to treat 
them all e q u a l l y . "37 Again, Frankfurter stated, "Separation 
means separation, not something e l s e ."38
Justice Reed stood alone on the McCollum case with the 
only dissenting vote. He found It difficult to extract from
3&I11. ex rel. McCollum v. Board of Education 333 U.S. 
227 (191|8). See also; "The Released-Tlme Decision," Rational 
Education Association Journal 37;209-210, April, 1948*
37in. ex rel. McCollum v. Board of Education 333 U.S.
227 (1948).
3®I11. ex rel. McCollum v. Board of Education 333 U.S.
23 1  (1948).
the official court opinion a conclusion that could justify the 
charge of "unconstitutional," The Court had referred a num­
ber of times to a remark by Thomas Jefferson in the effect 
that the First Amendment "erected a wall of separation between 
church and state," Justice Reed1S reply to the repeated use 
of this reference was that "a rule of law should not be drawn 
from a figure of speech,"39 it was Justice Reed1S contention 
that this was exactly what was happening.
Justice Reed also contended that the government was 
not being consistent in ruling the Champaign plan illegal 
while other questionable practices flourished under govern­
mental blessing. The Champaign released-tlme plan was only 
a "by-product of organized society" and no more to be con­
demned than the following practices
1, Chaplains in House and Senate,
2, Chaplains in the armed forces,
3, Veterans receiving training for the ministry 
at government expense in denominational schools,
4* Opening exercises in public schools which in­
clude Bible reading and the Lord's prayer,
5, Chaplains at naval and military academies where 
a "number of religious activities are carried on,"
6, Exemption of churches from property tax,
^"The Dissent of Mr, Justice Reed," Christian Century 
pp, 760-763, June 22, 1949,
National Education Assoclatlon Bulletin, Vol, XXXIV, 
No, 4» p* Aol, December, !^$6,
118
119
7. New York practice of dismissing pupils from 
public school for Instruction by churches.M
Justice Reed expressed what he considered governmental 
inconsistency in the statement: "While casting out the mote
at Champaign the government has left several beams in its own 
e y e . As actual worship services have always been permitted 
on government property (Church attendance on Sunday is com­
pulsory at both Naval and Military Academies), Reed contended 
that the use of school buildings for non-sectarian religious 
education should not be condemned as "an establishment of re­
ligion."
In considering the aftermath of the Federal Supreme 
Court’s decision on the McCollum case, two areas of thought 
deserve exploration. First, an interpretation of the decision 
is relevant to the material at hand with a reflection of the 
opinions registered by various groups regarding the decision. 
Second, the subsequent course taken by the releaaed-time pro­
gram will be briefly traced with a few words indicating how 
the decision affected the total program.
First then is the consideration of an Interpretation 
regarding the Federal Supreme Court’s decision in the McCollum 
case. The central core of the decision was the Court’s 1
1^ nDissent of Mr. Justice Reed," op. clt., pp* 760-763.
^2nThe Champaign Case," Christian Century 65*308-309.
ringing reaffirmation that church and state are separate In­
stitutions in this country* The "wall" separating these two 
Institutions must be kept "high and impregnable*" This de­
cision made explicit two specific doctrines in the constitu­
tional separation of church and state*
I* Neither federal or state government can give aid to 
one or all churches, or give preferential treatment 
to one church over another,
2* State or federal aid for religion Is unconstitu­
tional even if all groups are aided equally.
In the minds of the eight concurring judges the program of re- 
leased-tlme as It existed in Champaign disclosed an actual 
union of the civil law with the operation of the churches.
The Court described specifically an actual interlocking of 
functions between church and state, a union that was clearly 
Illegal, The pupils Involved In the program were clearly 
under the authority and discipline of the public school system 
while being Instructed by teachers In religion. Thus the 
churches actually utilized the authority, facilities, and tax 
money that maintained the system to give religious instruc­
tion.
Hie Federal Supreme Court decision did little to quiet 
debate on the issue and It was followed by a storm of contro­
versy. Perhaps the greatest criticism was based upon the 
justices* interpretation of the First and Fourteenth Amend­
ments. Violent disagreement erupted from the Court's use and
120
121
Interpretation of the phrase "an establishment of religion," 
Many historians and experts on constitutional law asserted 
that the authors of the Constitution were referring to the es­
tablishment of a national church by law,43 If this were true, 
of course, the Champaign plan of religious education was cer­
tainly not violating an "establishment of religion,"
A group of Roman Catholic bishops meeting In Washing­
ton, D, C,, stated emphatically their views on what the First 
Amendment limited. In their opinion the Amendment forbade an 
official church established by law and also any discrimination 
between religious groups, as shown In the following statement*
The founding fathers, said the bishops, were God­
fearing men who knew that "national morality cannot long 
prevail in the absence of religious principle." They 
never Intended to prevent "free cooperation" between 
government and organized religion. Any contrary inter­
pretation Is "an utter distortion of American history and
Among the flurry of articles that were published on the 
Champaign released-ttme Issue was a thought-provoking work by 
0*Nelll on the subject of the First Amendment*
The First Amendment was designed to (and did) leave 
the total responsibility for legislation in respect to "an 
establishment of religion," however defined, exclusively 
In the hands of the states. It contained no doctrine *4
^Morrison, C, C,, "Church, State, and Constitution," 
Christian Century 65*876, September I, 1948•
44nCorrosive Influence," Time 52*82, November 29, 1948,
122
whatsoever as to how the states should discharge their 
responsibility,...
The McCollum decision Is a revolutionary decision 
...denying to the people of Illinois the precise freedom 
which the First clause of the First Amendment was de­
liberately designed to preserve to them. That clause 
was written in answer to a number of petitions from var­
ious states asking that the Constitution make explicit 
that Congress could not give one religion legal prefer­
ence over all other religions, neither Madison nor Jef­
ferson ever, anywhere, wrote a sentence which taken in 
its context gave any other meaning to the "establishment 
of religion" clause in the First Amendment.45
Whether "released-time" for religious education 
continues in Illinois or elsewhere, is of trifling im­
portance compared to the question of whether the Jus­
tices of the Supreme Court shall pass on constitutional 
questions in the light of the language and meaning of 
the Constitution or in the light of their private phi­
losophies of religion and education.4&
Another interesting reaction to the McCollum decision came 
from the lawyers and experts on constitutional law. Interest­
ingly enough many of this group disapproved the decision on 
the basis that it was an imprudent Interpretation in the light 
of the Constitution. It was believed that the Court was set­
ting a precedent in new areas of jurisdiction without due con­
sideration for the over-all effect on the nation, as shown in 
the following editorial*
45oiNeill, J. M., "The Supreme Court on Separation of 
Church and State," The Commonweal 69*466-468, February 18, 
1949,
OfNelll, J. M., Religion and Education Under the Con­
stitution, p. xl.
123
Altogether the Court demonstrated In the McCollum 
case most of the errors which beset those who would lay 
down general rules without a critical experimental per­
iod of hesitation and doubt, the drawing of tentative 
lines, and taking stock of the salutary experience of 
our communities and people.47
The International Council of Religious Education adopt­
ed a "Statement of Policy" following the McCollum case In 
which their official position was clearly stated. In advising 
Its Protestant constituency, the stand was taken that re- 
leased-tlme programs should not make use of public school 
facilities or aid. At the same time however, the statement 
affirmed the right of parents to have their children excused 
for religious education during the regular school day. Al­
though the particular device as practised in Champaign was 
abandoned, the premise of released-time was still as sound as 
ever.
Givens, Executive Secretary of the National Education 
Association in 1948# Indicated that the decision did not elim­
inate the responsibility of public schools in the area of 
character development, as indicated In his statement2
In our opinion, this decision of the Supreme 
Court in no way voids the responsibility of the public 
schools to Inculcate those moral and ethical princi­
ples which are the essence of the good life. One of 
the Important objectives of public education has been, 
and always will be, to Inspire In youth a deep
4 /'"Undefined and Shifting Lines of Decision," editor­
ial, American Bar Association Journal 34:1029, November, 1948.
124
appreciation for the basic spiritual and.religious 
values which give meaning to existence.
A great deal of confusion disrupted the thinking of ed­
ucators, churchmen, and parents in the months following the 
Federal Court decision. The immediate practical application 
of the decision caused much concern. The National Education 
Association pointed out that ’released—time as an abstraction 
cannot be considered by any court." The Federal Court was 
trying the program as it existed in Champaign and "clearly 
invalidated only those (plans) essentially similar."49 The 
program of released-time suffered a distinct set-back by the 
McCollum decision. Shaver estimated that 20 percent of the 
communities offering released-time prior to the McCollum case 
had eliminated their programs, and there was a nation-wide loss 
of ten percent in pupil enrollment.#0 However, by 1951 re­
leased-time for religious education, held off school grounds 
but during school hours, had completely recovered. The stage 
was set for the second Federal Court test on the issue of re­
leased-time known as the "Zoraoh case," *49
4^"The Released-Time Decision," o£. cit., pp. 209-210.
49
National Education Association Journal. Vol XXXIV,
No. 4«, p. 201, December, 1956.
-j0Shaver, E. L., "Three Years After the Champaign 
Case," Rellfdous Education 66*34# January, 1951.
125
A le&al ngFe&n Ilght1' (Zorach case). The Federal Su­
preme Court placed Its stamp of approval on the New York sys­
tem of released-time April ZQ9 1952, thus providing the legal 
basis for present-day programs. This decision served as the 
culmination of a rather lengthy series of court cases In which 
the courts favored the right of parents to send their children 
to released-time classes. The New York program had been under 
attack by the American Civil Liberties Union and other groups 
who declared the plan "undemocratic because it is divisive, 
stigmatizing, coercive, and hostile to the atmosphere of de­
mocracy which should pervade the public s c h ool.However, 
the Supreme Court in a six to three decision declared the plan 
constitutional and sufficiently different from the McCollum 
case so that the First Amendment was not violated.
The appellants, Zorach and Gluck, were taxpayers and 
residents of New York City. They were parents of public 
school children who "regularly attended Protestant Episcopal 
or Jewish schools for religious instruction at times other 
than the hours in which public schools are in session."^
These parents challenged the state law permitting released- 
time contending that in essence the program was not different 
from that involved in the McCollum case. However, a Supreme 52
^"Constitutionality of Released-Time," School and So­
ciety 72tlt46, December 30, 1950.
52
Shaver, E. L., Three Years After the ChampaiKn Case.
P. 27, ----
126
Court majority maintained that the New York plan differed In 
decisive points from the McCollum case In that*
I* New York school buildings were not utilised by the 
religion classes.
2. Upon parental application the students left the
school buildings to attend their own church program.
3# The public school assumed none of the expense In­
volved In the program#
Justice Douglas delivered the Court opinion In the 
Zoraeh case and In doing so reiterated the position of the ap­
pellants. Zoraoh and Gluck maintained that the state compul­
sory attendance law was operating as a coercive influence in 
forcing children to attend the released-tlme program, as sum­
marised by Douglas*
Their argument, stated elaborately In various 
ways, reduces itself to this* The weight and Influ­
ence of the school Is put behind a program for reli­
gious instruction; public school teachers police It, 
keeping tab on students who are released; the class­
room 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- 
tlme" program, like the one in the McCollum case, 
would be futile and Ineffective. The New York Court 
of Appeals sustained the law against the claim of un- 
constitutionality*^
In rendering a decision in the Zorach case the Supreme 
Court considered again the meaning and limitations implied in
^Zoraoh v. Clauaon et ale, 343 U.S. 312 (19$2).
the First Amendment. The Interpretation given In connection 
with this case lacked the definiteness regarding the church- 
state controversy which had characterized the McCollum case.
In the Court opinion of the Zorach case little was said re­
garding the "high and impregnable wall" that supposedly sepa­
rates church and state* The Court reaffirmed the fact that 
separation must be complete regarding Interference with the 
"free exercise" of religion and an "establishment of religion" 
However, the Court also mentioned that the First Amendment 
does not completely separate church and state but defines the 
specific instances where an Interlocking of functions could be 
considered unconstitutional. Thus the Court opened the door 
to a new concept of thinking regarding the church-state con­
troversy. This new element Involved the notion that the state 
may accommodate Its public Institutions to the religious needs 
of the people. Justice Douglas refers to this concept in his 
comments concerning the First Amendment *
127
There cannot be the slightest doubt that the 
First Amendment reflects the philosophy that Church 
and State should be separated. ...The First Amend­
ment within the scope of Its coverage permits no ex­
ception; the prohibition is absolute. The First 
Amendment, however, does not say that in every and 
all respects there shall be a separation of Church 
and State. Rather It studiously defines the manner, 
the specific ways, in which there shall be no con­
cert or union or dependency one on the other. That 
is the common sense of the matter. Otherwise the 
state and religion would be aliens to each o t h e r -  
hostile, suspicious, and even unfriendly. Churches 
could not be required to pay even property taxes.
128
Municipalities would not be permitted to render police 
or fire protection to religious groups* Policemen who 
helped parishioners into their places of worship would 
violate the Constitution* Prayers in our legislative 
halls; the appeals to the Almighty in the messages of 
the Chief Executive; the proclamations making Thanks­
giving Day a holiday; "so help me God" in our court­
room oaths— these and all other references to the 
Almighty that run through our laws, our public rit­
uals, our ceremonies would be flouting the First 
Amendment* A fastidious atheist or agnostic could 
even object to the supplication with which the Court 
opens each sessionI "God save the United States and 
this Honorable Court,"
We would have to press the concept of separa­
tion of Church and State to these extremes to condemn 
the present law on constitutional grounds. The nul­
lification of this law would have wide and profound 
effects* A Catholic student applies to his teacher 
for permission to leave the school during hours on a 
Holy Day of Obligation to attend a mass* A Jewish 
student asks his teacher for permission to be ex­
cused from school for Yom Kippur. A Protestant 
wants the afternoon off for a family baptismal 
ceremony. In each case the teacher, in order to 
make sure the student is not a truant, goes further 
and requires a report from the priest, the rabbi, 
or the minister* The teacher, in other words co­
operates in a religious program to the extent of 
making it possible for her students to participate 
in it. Whether she does It occasionally for a few 
students, regularly for one, or pursuant to a sys­
tematized program designed to further the religious 
needs of all the students does not alter the charac­
ter of the act,54
In the Zorach case the Federal Court assumed a theistlc 
position in regard to our institutions and national way of 
life* This stand by the Court gave meaning to the interpreta­
tion rendered in this case. To many who felt that great
^-Zorach v. Clauson et al,, 343 U.S. 312-314 (1952).
129
injustices had been wrought in the name of separation of 
church and state this Court position was comforting* Justice 
Douglas noted this theistlc position in the following state­
ments
We are a religious people whose Institutions 
presuppose a Supreme Being* We guarantee the freedom 
to worship as one chooses* We make room for as wide 
a variety of beliefs and creeds as the spiritual needs 
of man deem necessary* We sponsor an attitude on the 
part of government that shows no partiality to any one 
group and that lets each flourish according to the 
zeal of its adherents and the appeal of its dogma.
When the state encourages religious instruction or 
cooperates with religious authorities by adjusting 
the schedule of public events to sectarian needs, it 
follows the beat of our traditions* For it then re­
spects the religious nature of our people and accomo­
dates the public service to their spiritual needs.
To hold that it may not would be to find in the Con­
stitution a requirement that the government show a 
callous indifference to religious groups. That 
would be preferring those who believe in no religions 
over those who do believe. Government may not finance 
religious groups nor undertake religious instruction 
nor blend secular and sectarian education nor use sec­
ular institutions to force one or some religion on any 
person. But we find no constitutional requirement 
which makes it necessary for government to be hostile 
to religion and to throw its weight against efforts to 
widen the effective scope of religious influence. The 
government must be neutral when it comes to competition 
between sects. It may not thrust any sect on any per­
son. It may not make a religious observance compul­
sory. It may not coerce anyone to attend church, to 
observe a religious holiday, or to take religious in­
struction. But it can close its doors or suspend its 
operations as to those who want to repair to their re­
ligious sanctuary for worship or instruction. No more 
than that is undertaken here.55
^Zorach v. Clauson et al., 343 U.S. 314 (1952).
130
The Court minority flatly disagreed with the decision 
rendered in this case and each of the three dissenting Jus­
tices wrote an opinion. These Justices maintained that any 
release of children during the hours they are compeled by law 
to attend school constitutes coercion. Thus, according to 
this line of reasoning religious sects are made the benefici­
aries of the state's power to compel children to attend the 
secular schools. Justices Jackson, Frankfurter, and Black 
were the dissenting judges In the Zorach case.
In writing his dissenting opinion Justice Frankfurter 
maintained that released-tlme in the New York system was sup­
ported by compulsory attendance laws enforced by the state.
He argued that there would be no constitutional question in­
volved if all children were dismissed from school at a certain 
time. The fact that those who did not participate in religion 
classes were retained in school was to Justice Frankfurter the 
very thing which raised the constitutional issue, as Indicated 
in his statementI
There is all the difference in the world between 
letting the children out of school and letting some of 
them out of school into religious classes. The school 
system did not close its doors and did not suspend its 
operations,... If Its doors are closed, they are closed 
upon those students who do not attend the religious in­
struction in order to keep them within the school. That 
is the very thing which raises the constitutional Is-
sue.5o
^Zorach v. Clauson ot al., 3h3 U.S. 321 (1952).
131
Justice Frankfurter also raised the issue concerning 
the possible divisiveness of released-time. In Frankfurter's 
opinion the fact that Protestants, Catholics, and Jews attend­
ed different classes only served to accentuate religious dif­
ferences, Thus the public school was in the position of being 
an active ally to this questionable end result, as Indicated 
in Frankfurter1 a statement*
The deeply divisive controversy aroused by the at­
tempts to secure public school pupils for sectarian in­
struction would promptly end if the advocates of such in­
struction were content to have the school "close its doors 
or suspend operations"— that is, dismiss classes in their 
entirety without discrimination Instead of seeking to use 
the public schools as the instrument for security of at­
tendance at denominational classes.
The unwillingness of the promoters of this move­
ment to dispense with such use of the public schools be­
trays 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,57
In registering his dissenting opinion Justice Jackson 
criticised the majority judgment in that the factor of "co­
ercion" was overlooked. Actually the issue was not overlooked 
as the Court majority maintained that the record of the case 
as it came from the New York courts precluded consideration of 
the coercion factor. In comparing the McCollum case with the 
Zoraeh case, Jackson noted that the differences were "trivial.
^Zorach v, Clauson et al*, 3I4.3 U.S, 321 (1952),
almost to the point of cynicism, magnifying its nonessential 
details and disparaging compulsion which was the underlying 
reason for i n v a l i d i t y , He argued that when the state com­
pelled a child to attend public school and then released part 
of this time to him if he would attend religious classes it 
was a clear case of coercion, as indicated in his statement:
132
The greater effectiveness of this system over 
voluntary attendance after school hours is due to the 
truant officer who, if the youngster fails to go to 
church school, dogs him back into the public school­
room- Here schooling is more or less suspended during 
the "released-time” so the nonreligious attendants 
will not forge ahead of the church-going absentees.
But it serves as a temporary jail for a pupil who will 
not go to church. It takes more subtlety of mind than 
I possess to deny that this is governmental constraint 
in support of religion. It Is as unconstitutional, in 
my view, when exerted by indirection as when exerted 
forthrlghtly,59
Jackson expressed added concern that the supposed rtWalln 
separating church and state was in danger of genuine distor­
tion by the majority Court decision, He concluded that the 
clarity expressed in this regard in the McCollum decision was 
becoming muddled in the sweeping generalities formulated by 
his "evangelistic brethren,” This in turn opened the door to 
many differing views regarding the exact position of the "wall"
between church and state,
—
National Education Aosoclation Research Bulletin- 
No, 4» Voi. XXWV, p, 203, December, 1^5^•.
^Zorach Clauson e£. a^,, 343 U.3, 324 (1952),
133
Justice Black, the third member of the dissenting min­
ority, was the individual who wrote the Court opinion in the 
McCollum case. His dissenting opinion in the Zorach case re­
volved around the concept that he could see "no significant 
difference between the invalid Illinois system and that of 
New York here sustained...."^0 In reviewing the New York plan 
of released-time. Justice Black discerned the element of co­
ercion as had his fellow dissenting Justices.
Black also expressed his disapproval of the majority 
opinion as regards the latitude of interpretation given the 
First Amendment. Separation of church and state meant reli­
gious liberty and Black feared that if the state became in­
volved in even so much as cooperation with religious agencies 
this freedom was endangered. He read into the Interpretation 
that if the state "cooperates" with religious agencies it was 
In essence "exalting the orthodox" to the detriment and "der­
ogation of unbelievers."^ Thus he conceived of the state as 
abandoning its neutral position for a course of open favorit­
ism to religion and thereby forfeiting the freedom of unbe­
lievers. In his dissenting opinion Black wrote that the state 
could best serve society by not serving religious movements 
with gestures of cooperation, as indicated in his statement! 60
60Zorach v. Clauson et al., 343 U.S. 318 (1952),
6lZorach v. Clauson et al., 343 N.S. 319 (1952).
134
Under our system of religious freedom, people have 
gone to their religious sanctuaries not because they 
feared the law but because they loved their God. The 
choice of all has been as free as the choice of those who 
answered the call to worship moved only by the music of 
the old Sunday morning church bells. The spiritual mind 
of man has thus been free to believe, disbelieve, or 
doubt, without repression, great or small, by the heavy 
hand of government. Statutes authorizing such repression 
have been stricken. Before today, our judicial opinions 
have refrained from drawing invidious distinctions be­
tween those who believe In no religion and those who do 
believe. The First Amendment has lost much if the reli­
gious follower and the atheist are no longer to be ju­
dicially regarded as entitled to equal justice under 
law.
State help to religion injects political and 
party prejudices into a holy field. It too often sub­
stitutes force for prayer, hate for love, and persecu­
tion for persuasion. Government should not be allowed, 
under cover of the soft euphemism of "co-operation," to 
steal Into the sacred area of religious choice.62
The Issues raised In the foregoing dissenting opinions 
cannot easily be dismissed, for a rather ominous note is 
sounded by each of the three Justices. It Is indeed a matter 
of general concern If the established principles of church- 
state separation are violated. The charge of "coercion" by 
the state, whether direct or Indirect, If true is not in the 
best Interest of all Americans* Then, too, the accusation 
that the released-time program creates dlvlaivenese Is worthy 
of additional investigation.
If the New York program of released-time was actually 
aided by state "coercion," then the principle of separation
orach v. Clauson ejb al.. 343 U.S. 319 (1952).
of church and state was violated; for coercion involves an in­
terlocking of the functions of state with that of religious 
bodies* However# the fact that six of the nine Supreme Court 
Justices agreed that the New York program did not violate the 
First Amendment is worthy of note* These Justices interpreted 
the First Amendment as specifically forbidding$ (I) inter­
ference with the free exercise of religion and (2) an estab­
lishment of religion. Other than these two specific points, 
the majority opinion pointed out that the First Amendment did 
not say that in every respect church and state should be sepa­
rate. Justice Jackson, one of the dissenting Justices in the 
Zorach case, stated in his opinion on the McCollum case that 
"it is a matter on which we can find no law but our own pre­
possessions."^ This being the case the minority charge of 
"unconstitutional" rests not upon precedent in the annals of 
law but simply upon the convictions of the Justices Involved 
in their private interpretations of the First Amendment.
A second accusation against released-time was leveled 
by Justice Frankfurter when he charged that attempts to secure 
public school pupils for these classes aroused a "deeply di­
visive" c o n t r o v e r s y . ^  Unfortunately Frankfurter did not 
elaborate on the "divisive controversy" which supposedly stems
0^Ill. ex rel. McCollum v. Board of Education 333 U.S. 
238 (1948). ------
^Zoraoh v. Clauson et al. 343 N.S. 321 (1952).
135
136
from the released-tlme program* Undoubtedly the element of 
divisiveness is present in schools where tact and good Judg­
ment are lacking in dealing with this program. It is supposed 
by some that when the pupils of a certain school march off in 
different directions for religious instruction, then for the 
first time pupils sense a difference regarding various reli­
gious faiths. This difference flings open the door to preju­
dice, mistrust, and suspicion. However, it is Indeed naive 
to imagine that children are not well aware of religious dif­
ferences at an early age. Perhaps if there is a predisposi­
tion toward prejudice the feeling can become accentuated un­
less proper orientation has been a part of the child's train­
ing, Harris has worked with the Boston, Massachusetts, system 
of week-day church schools and contends that the released-tlme 
program has served to increase understanding and sympathy as 
indicated in her statement;
As a matter of fact the pupils in any school usu­
ally know where their schoolmates go on Sunday, or on 
Saturday or if they go to any religious meeting. They 
knew long before there was released-tlme. If one's re­
ligious affiliations must be kept secret in order "to 
insure domestic tranquility" surely there is a need for 
education in the field.
Those of us who have been closely associated 
with the program have been impressed by the better un­
derstanding and sympathy it has engendered. Instead of 
the pupils of one religious group absenting themselves 
for religious observances, pupils of all faiths have
137
gone at the same time, to their own place«65
The general public consensus encountered In reading has 
acclaimed the released-tlme movement as an Instrument of good­
will and understanding.
Summary
It Is evident that there Is no distinct line of deraarka- 
tlon that fully clarifies the boundaries of church and state. 
Rather a zone or no-man * s land exists between these two In­
stitutions as a safeguard of religious liberty.
Most state court decisions dealing with the practice of 
released-tlme have condemned the expenditure of public funds 
for purposes of aiding sectarian education. Where the element 
of state coercion was evident by means of compulsory attend­
ance laws, usually the plan was ordered discontinued.
On the Federal Supreme Court level two cases form the 
legal picture. The McCollum case was decided by the Supreme 
Court In 19l|.8 against the program as It existed In Champaign, 
Illinois. The Zorach case was decided by the Supreme Court In 
1952 In favor of the program as It existed In New York City.
In the McCollum case, religion teachers entered the 
public school and taught the children In their classrooms.
65
Harris, Elizabeth, "Protestant Weekday Religious Edu­
cation In Boston," Education 71:382-384, February, 1951.
The Supreme Court declared this plan illegal on three points;
I* Public tax-supported buildings were utilized for 
sectarian purposes,
Zm Conpulsory attendance laws aided the program,
3, The schoolboard cooperated in arranging and perpetu­
ating the plan.
Also, the public school superintendent passed upon the fitness 
of the teachers of religion; and the public school teachers 
checked the attendance records to make certain those who had 
enrolled attended the classes. In declaring the Champaign, 
Illinois, program unconstitutional the Court declared that re­
ligion could not be taught within the schools or aided by any 
form of school machinery even though all faiths were given 
equal opportunity. The Court reaffirmed that the "wall" of 
separation between church and state should be maintained "high 
and impregnable,"
In the Zorach case, issue was taken with the released- 
time program of Hew York City, Students were excused from the 
public school upon request of the parents to attend religion 
classes in the church of their choice. All costs of the ven­
ture were borne by the churches Involved in the program. In 
a six to three decision the Federal Supreme Court declared the 
plan constitutional and thus provided the present legal basis 
for the movement. In the ruling the Court announced that the 
First Amendment does not maintain that church and state should 
be separate in all respects. The Court defined the First
138
139
Amendment as demanding separation in two specific instances:
(1) no interference with the free exercise of religion, and
(2) no establishment of religion. Other than these two spe­
cific instances of separation the state may accommodate its 
public Institutions to the religious needs of the people. 
This decision in essence negates the absoluteness of separa­
tion of church and state declared in the McCollum decision. 
The "high and impregnable" wall was hammered down a few 
inches by this momentous decision.
In the following, concluding chapter, attention will 
be afforded the summary and conclusions of the thesis.
340
CHAPTER V
SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS
Sunaoary
Early In the twentieth century the religious training 
of the American child became an acute problem for Protestant- 
Isme The early colonial sectarian type of school had disap­
peared from the scene and religion was, for the most part, re­
legated to the confines of the church and the home. Early 
colonial education had been carried on as a function of the 
church. Not only were these schools controlled by the church 
and dominated by the religious motive, but the right of the 
church to dictate the teaching in the schools was recognized 
by the state. However, the prolonged battle against sectari­
anism was won by the proponents of the public school, and the 
lines of struggle were drawn against the reintroduction of 
formal religious instruction into the public school.
Despite the battle against sectarianism. The Religious 
Education Association (a substantial body of laymen, religious 
leaders, and educators) became concerned about the Insignifi­
cant position assigned to religious education within the public 
schools. There was concern lest the knowledge and skills of 
modern culture might outrun the moral and spiritual resources 
for their direction and control. It was considered that the 
remnants of religious education which remained In the public 
schools were Inadequate to Insure the desired degree of moral
character development. The Religious Education Association 
vigorously held fast to the conviction that public education 
free from sectarian control was fundamentally right, for it 
was realized that separation of church and state meant reli­
gious liberty, At the same time it was recognized that reli­
gious education was too valuable an influence to be entirely 
disregarded by the public school. The attempt to resolve this 
difficulty resulted in efforts to promote a cooperative ar­
rangement whereby church and public school, each remaining in­
dependent in its own sphere, would provide to public-school 
children some sort of religious-education experience not in­
consistent with church-state separation,
A number of early twentieth-century attempts were made 
to supplement the religious education training of children.
The original initiation of the movement called "released-time" 
may be attributed to Wenner of New York City in the year 190$, 
This man rendered notable service both by conducting week-day 
classes in religion and by constantly advocating their general 
acceptance. It was his contention that the public schools 
unduly monopolized the child's time and that the churches were 
entitled to their share of it. From this beginning the idea 
found root in Gary, Indiana in 1913 when a school superintend­
ent proposed that children might be released from public school 
to attend classes in religion if the churches of the city pro­
vided them. The churches responded, and in 1911}. these classes
were actually underway, conducted on church premises by church 
personnele The schedules of the children were so arranged 
that the public school could "release” them for attending 
classes In religion. This practice has grown from an original 
one-city experiment with an enrollment of over 600 pupils to a 
nation-wide movement with a reported enrollment of four million 
students In 1958.
A number of various patterns of releasod-tlme are In 
operation In the United States. In general, however, the most 
common pattern Involves the excusing of public school children 
from regular class schedules one period each week. During this 
period the children attend religious-education classes spon­
sored, supervised, and conducted by various denominational or 
Interdenominational groups. These classes are usually conduct­
ed In a church building away from the school premises, and en­
rollment Is voluntary. Course content ranges from strictly 
sectarian to Interdenominational presentations. No public 
school credit Is obtained for attending these classes.
In investigating the motives that prompted the released- 
tlme movement, the writer found that there were certain con­
cepts that stood out In bold relief. First, there was a fun­
damental conviction that children had moral and spiritual needs 
that were not being met. The need was attested to by: (I) the
official pronouncements of various government and education 
conferences, (2) the voice of educators and religious leaders.
242
I W
and (3) the tremendous surge of criminal behavior among the 
young. In making plans to fill the need, the proponents of 
the released-tlme program were convinced that since the public 
school was neither designed nor equipped to teach religious 
matters there was a large gap In the educational program that 
needed to be mended. To meet this challenge and yet not con­
flict with the position of the public school, some outside 
provision needed to be made. The Sunday school and religious 
education classes outside of school hours were deemed Inade­
quate means of meeting the need for additional religious edu­
cation. Only about half of the nations children were enrolled 
In Sunday school, and these received an average of only about 
12 hours of religious instruction a year. Further, It was be­
lieved that some means had to be devised to reach the child 
during what he considered were his week-day '’business hours." 
Then, too, relating this program to the week-day activities was 
considered a strong point In that the association with the pub­
lic school would lend importance to religion and make It an 
everyday reality, not just a Sunday experience.
The advocates of released-tlme believed that such a pro­
gram would not Infringe on anyone * s liberty, as the Individual 
was free to accept or reject the proposed benefits of the plan. 
No public school funds were to be diverted for the support of 
the released-tlme program. This responsibility was to be as­
sumed by the churches involved. As all denominations were
welcomed aa participants In the plan, it was believed that no 
preferential status for particular churches would result.
In attempting to evaluate the released-time program aa 
to real results, religious leaders and educators are generally 
convinced that the program la making good. In those communities 
where the recommended standards have been followed, it is noted 
as a most effective school of religion. In many communities it 
reaches more children for religious teaching than all other 
church agencies combined. Though there are no scientifically 
accurate measurements to prove that the program promotes good 
behavior in children, there are strong calculated convictions 
to that effect. The proponents of released-time believe the 
plan has served to bring about a closer relationship among the 
three agencies most responsible for the child's education— the 
home, the public school, and the church. Instead of a feared 
divisiveness In church affiliation, the movement has been graced 
with interdenominational cooperation, understanding, and, respect* 
Most state court decisions dealing with the practice of 
released-time have condemned the expenditure of public funds 
for purposes of aiding sectarian education. Two separate Fed* 
eral Supreme Court decisions have been handed down regarding 
the released-time plan. The court declared the program as it 
existed In Champaign, Illinois, In 1948 unconstitutional. In 
this program the pupils were Instructed by religion teachers 
within the public school building, Mrs. VashtI McCollum
started proceedings to have the program invalidated, and the 
court case Is commonly referred to as the "McCollum case#"
The program was ruled unconstitutional in that use was made of 
school property and facilities supplied from public tax funds. 
The use of public school machinery, tax-supported property, 
attendance checks, and time made compulsory by law, was decided 
to be a violation of the First and Fourteenth Amendments. Fur­
ther, the court was actively concerned about the question of 
whose Jurisdiction the classes were under during the period they 
were assigned to religious instruction. The facts submitted to 
the court Indicated that they were under the jurisdiction of 
the public school authorities, or, the state. Such an inter­
locking of state and church functions was ruled an establish­
ment of religion that was unconstitutional.
The McCollum case legally defined what was sectarian 
teaching in the public school. In brief, it established the 
precedent that sectarian beliefs, as doctrinal beliefs of one 
denomination, could not be taught within the school property 
or aided by any form of school machinery, even though all other 
faiths were given equal opportunity to teach their beliefs. 
Equality of opportunity did not justify the practice as far as 
the court was concerned. In the Federal Supreme Court decision 
the central point was the reaffirmation that church and state 
are separate institutions in this country and the wall between
145
thorn must be kept high and impregnable. Justice Reed, the in­
dividual with the only dissenting vote, did not believe that a 
rule of law should be drawn from a figure of speech.
The Sttprento Court decided the Zorach case in New York in 
favor of the released-time program. This 1952 decision stated 
that because the children left the public school buildings to 
be instructed in their churches, there was no illegal use of 
tax-supported buildings or equipment. In a six-to-three de­
cision the same court which had almost unanimously condemned 
the system in Champaign, Illinois, held that the New York plan 
did not infringe on the First Amendment. The majority of the 
court found that the New York program differed in essentials 
from that rejected in the McCollum case because*
1. New York1 a released-time classes were not held in 
school buildings.
2. The pupils who attended were released from school.
3. All costs, including those of various forms, were as­
sumed by the religious organizations involved.
The Zorach case not only decided the issue at hand, but 
it introduced a new element into the church-state controversy. 
The new element was the concept that the state may accomodate 
its public institutions to the religious needs of the American 
people. The decision given in the Zoraeh case negated the ab­
soluteness of the separation of church and state doctrine. 
Justice Douglas Insisted that the First Amendment did not say 
that in every and all respects the church and state should be
separate* A mutual spirit of cooperation, within prescribed 
boundaries, could be deemed beneficial to each* The Zorach 
ruling affirms that on some cases the state may adapt its pub­
lic Institutions to the religious aspirations of the people.
The decision handed down in the Zorach case gave the 
released-tlrae movement Its charter and Its present base of or­
ganization. The judgment reaffirmed the right of parents to 
determine the content and method of their children’s education.
Conclusions
Prom this study of the released-time program for reli­
gious education the following conclusions have been drawn!
I. As most released-ttme programs are supported by vol­
untary contributions, they are sensitive to periods of finan­
cial depression. The local churches In each community must 
take their responsibility for released-time teaching so seri­
ously that financing will come largely from churches without 
relying to any major degree upon non-church or general com­
munity support.
It was evident in the depression of the 1930’s that 
many released-time programs were forced to close their doors 
because of Inadequate financial support. To develop a quality 
program free from financial misgivings, a sound financial ba­
sis must be a foundation for each community that undertakes the
venture. This must be a prerequisite for a program intended 
to be comparable to the quality of instruction offered in the 
public schools of the nation,
2, Released-time appears best adapted to larger commu­
nities having a number of churches to share expenses and to 
insure continuity of administration and of financial support, 
As the leadership of released-time plans is often in the hands 
of a pastor, the time of his stay at a church is an important 
factor in the released-time program. If he is reassigned, or 
accepts another field of service, the released-time program 
can be discontinued and even discredited. Larger cities that 
have, on a ministerial basis, organized a board of Christian 
education, and who have banded together for financial support 
offer a more advantageous arrangement for the continuation and 
enlargement of the program. In each situation, however, a 
board of education must be organized to insure program con­
tinuity and quality instruction,
3, Generally, the released-time program has not brought 
about a spirit of divisiveness in the public schools, A frank 
realization of sectarian differences, with emphasis on basic 
agreements rather than differences, has served to develop re­
spect and understanding. The argument has been frequently 
projected that when pupils see their classmates going to dif­
ferent churches for instruction this tends to create prejudice 
and dislike. In actual practice however, this has not proven
148
149
true. Further, If one*s religious affiliation must be kept 
secret In order to Insure domestic tranquillity there must be 
a need for additional education In this field.
4. The released-ttme program seeks, and Is remarkably 
successful In its endeavor, to reach large numbers of rell- 
giously-illiterate boys and girls. On the average, one-fourth 
of the children enrolled In the released-tlme programs have 
had no church or Sunday school connection. In the large in­
dustrial type communities the percentage is much higher, often 
fifty or sixty per cent of the released-tlme enrollment being 
classified as having no church connections.
It has been pointed out that less than half the chil­
dren aged six to sixteen are enrolled In Sunday schools In this 
country, after three centuries of separate denominational ef­
fort. This Is In contrast to released-tlme classes in which 
95 per cent of the pupils who have opportunity to participate 
have enrolled.
5. Religion expressed In sectarian, theological, doc­
trinal, or dogmatic terms cannot be introduced into the pub­
lic school without endangering the principle of church-state 
separation. Religion expressed In these terms must be the 
responsibility of the church and the home, not of the public 
school.
6. The decisions of the United States Supreme Court In 
both the McCollum and Zorach cases have made the use of public
150
school buildings for released-fctae classes unconstitutional. 
Further, a school board may not help promote the cause of re- 
leased-time classes or take an active part through teachers or 
superintendents in the supervision of or provision for classes 
in religious education. However, the McCollum case decision 
does not prohibit the teaching of factual information regard­
ing the history of religious groups In the regular curriculum.
7. The decision rendered in the Zorach case furnishes a 
new basis for consideration of the legal aspects of the problem 
of released-tirae. Separation of church and state does not pre­
clude cooperation between the churches as free institutions and 
the state. Cooperation between church and state can properly 
be encouraged as is cooperation between government and many 
voluntary community, state, and national agencies which have 
concern for children and youth.
The Zorach decision reaffirms the right of parents to 
determine the content and method of their children’s education.
8. When properly established, the released-tlme plan can 
provide religious instruction and experiences on a sound educa­
tional basis without violating the principle of church-state 
separation.
151
Recommendations
In the light of this Investigation it Is recommended 
that further study be made of the problem of released-time In 
the following specific areas:
I* Does the released-time program have a tendency to 
place the public schools in a position of supporting only the 
dominant, the most aggressive, or the most affluent churches 
in a community?
2# Is the teaching In released-tlme classes actually 
comparable to the standards which should be met by any activ­
ity which utilizes a part of the regular school day?
3» Are the housing facilities for released-tlme classes 
comparable to public school facilities In the same community? 
(Perhaps attention should be given to the relative value of 
housing released-tlme classes in church property and non­
church property.)
4. Ia the released-tlme program, still tending to sepa­
rate religion from the rest of the school, destined to defeat 
its purpose of organization namely. Integrating religion Into 
the total learning experience of the child?
5. What steps need to be taken to insure that enough 
competent teachers are enlisted and trained for the task of 
released-tlme work? How can the challenge of this type of oc­
cupation be adequately presented to the prospective teacher?
152
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62:1085-1099, September 26, 1945.
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157
Fosdlokt Harry E», ’’Shall American School Children be Roll- 
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65*1292, December I, 1948.
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163
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110*22# August I, 1931.
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"Salvaging Released Time," Christian Century 65*405-406, May
5# 1948.
"School and the Church," Newsweek 31*84# March 22, 1948.
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SHb^ FTTWK--------------
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Centurv 65*134°, December 8, 1948.
166
Waterhouse, H, A,, "Is Released Time Worthwhile?" Cliriotlan 
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Legal References
Gordon v. Board of Education, 178 P. (2nd) 488 (California, 
1947).
Illinois ex rel. McCollum %. Board of Education, 333 U.S,
(1948)7*
People y> Board of Education, 71 N . E. (2nd) 161 (111* 1947). 
People %. Graves, 219 N.Y.S. 189, affirmed 156 N.E. 663 (1927).
167
Stein v. Brown, 211 N.Y.S. 822 (1925).
Zoraoh v. Clauson et al«, 343 U.S. 306 (1952),
168
APPENDIX
169
APPENDIX
Appendix A
State Lawa Regarding Weekday Religious Education
On Released Time
Following are the laws permitting the release of chil­
dren from their public school classes In the states where spe­
cific legislation has been enacted#
California# Pupils, with the written consent of their 
parents or guardians, may be excused from school In order to 
participate In religious exercises or to receive moral and 
religious Instruction at their respective places of worship 
or at other suitable place or places designated by the reli­
gious group, church, or denomination, which shall be In addi­
tion and supplementary to the Instruction In manners and morals 
required elsewhere In this code. Such absence shall not be 
deemed absence In computing average dally attendance. If all 
of the following conditions are compiled with:
1# The governing board of the district of attendance.
In Its discretion, shall first adopt a resolution 
permitting pupils to be absent from school for 
such exercises or Instruction.
2, The governing board shall adopt regulations govern­
ing the attendance of pupils at such exercises or 
Instruction and the reporting thereof,
3# Each pupil so excused shall attend school at least 
the minimum school day for his grade for elementary 
schools, and as provided by the relevant provisions 
of the rules and regulations of the State Board of 
Education for secondary schools.
No pupil shall be excused from school for such pur­
pose on more than four days per school month.
It Is hereby declared to be the Intent of the legisla­
ture that this section shall be permissive only.
-Section 8286 of the Education­
al Code Effective August, 1943#
Indiana. That If It Is the wish of the parent, guard­
ian, or other person having control or legal custody of any
170
child, that such child attend for a period or periods to be 
determined by the local principal or superintendent of schools 
and not exceeding in the aggregate one hundred and twenty min­
utes In any week, a school for religious instruction, conducted 
and maintained by some church or association of churches or by 
some association organized for religious instruction, and in­
corporated under the laws of this state, and which school shall 
not be conducted or maintained, either in whole or in part, by 
the use of any public funds raised by taxation; such child upon 
written request of the parent, guardian or other person having 
legal custody may be permitted to attend such school for reli­
gious instruction and such permission shall be valid for not 
longer than the school year during which it is Issued* Such 
school for religious Instruction shall maintain records of at­
tendance which shall at all times be open to the inspection of 
the public school attendance officers* Attendance at such 
school for religious Instruction shall be given the same at­
tendance credit as at the public school*
-Acts 1943 Chapter 225 
Approved March 9, 1943.
Iowa* The legislature of the State of Iowa has deemed 
it proper and advisable to encourage the attendance of chil­
dren at religious services and to attend places where they 
will receive religious Instruction* Section 299.1, Code of 
Iowa, 1950, contains the school attendance requirements of 
children. One who violates these requirements is a truant.
By the provisions of Section 299.2 of the Code there Is except­
ed from the truancy provisions by virtue of sub-paragraph 4 
thereof, any child "While attending religious services or re­
ceiving religious Instructions."
As observed by the Supreme Court of the United States, 
we are a religious people whose institutions pre-suppose a 
Supreme Being* We guarantee the freedom of worship as one 
chooses* We make room for as wide a diversity of beliefs and 
creeds as the spiritual needs of man may deem necessary* We 
sponsor a duty on the part of Government that shows no parti­
ality to any one group and that lets each flourish according 
to the zeal of its adherents*
Encouragement of religious Instruction by the State and 
its cooperation with religious authorities in the adjustment 
of the schedule of public events to sectarian needs, follows 
the best of our traditions* A contrary view must find in the 
Constitution a requirement that the Government show callous 
indifference to religious groups* Such a finding would favor 
those Krtio believed in no religion over those who do believe.
171
There Is no law of the State of Iowa which forbids such 
arrangement as Is Involved In your question administered upon 
an Impartial basis. Nor Is such an arrangement offensive to 
the Constitution of the United States or the State of Iowa,
You are, therefore, advised that it is the opinion of 
this office that the board of directors of an Iowa School Dis­
trict may make provision to excuse pupils for one hour per 
week on the written request of their parents, so that such 
pupils may attend religious Instruction given by non*school 
personnel at places which are not part of the school premises,
-Attorney General's Opinion 
August 18, 1923.
Kentucky, The boards of education of Independent and 
county school districts may provide for moral Instruction of 
pupils subject to their jurisdiction. In the manner provided 
in KRS 158, 210 to 158, 260.
The board of education of each school district may au­
thorize a complete survey of all the pupils attending the pub­
lic schools within the district and ascertain those pupils who 
desire moral instruction and have the consent of parent or 
guardian for the instruction.
The boards of education shall fix one day each week 
when pupils who have expressed a desire for moral Instruction 
may be excused for at least one hour to attend their respec­
tive places of worship or some other suitable place to receive 
moral instruction in accordance with the religious faith or 
preference of the pupils.
Each board of education may make such arrangements with 
the persons In charge of the moral Instruction as the board 
deems necessary and advisable.
A pupil attending the classes for moral Instruction at 
the time specified and for the period fixed shall be credited 
with the time spent as if he had been in actual attendance In 
school.
Any pupil who fails to take advantage of the moral In­
struction shall remain In school during the time when the in­
struction Is being given, but shall not receive any education­
al advantage over children receiving moral Instruction.
The moral Instruction shall be given without expense to 
any board of education beyond the cost of the original survey.
-Sections 158.200-158.260 of the 
1914.2 Kentucky Common School Laws.
172
Malnew An Act to Provide Moral Instruction for Chil­
dren in (Connection with the Public Schools
Whereas, one of the 1st requisites of an harmonious, 
contented, and prosperous state depends upon religious toler­
ance and understanding; and
Whereas, the civil and religious liberties which are in­
herently part of the American Constitutional system have been 
best secured and furthered by providing moral Instruction for 
pupils In connection with the public schools of this state; 
now, therefore•
Section Ie School Comnlttee May Provide For Moral
Instruction. Rie school committee ofeach 
city or town Is hereby authorized and em­
powered to provide for the moral instruc­
tion of pupils subject to the Jurisdiction 
of such committee in the manner in this act 
provided.
Section 2. Survey of Religious Affiliation May be Made.
Hie school 'committor.' of each city Or-Tovm 
may authorize and complete a survey of the 
religious affiliations of all pupils at­
tending the public schools within such city 
or town, and ascertain these pupils who de­
sire, and have the consent of parent or 
guardian for moral Instruction. On a day 
in each week, to be fixed by the board, it 
may excuse such pupils for at least one 
hour, for the purpose of attending their 
respective places of worship, or some other 
suitable place, there to receive moral in­
struction In accordance with the religious 
faith of said pupils.
Section 3. Rules and Regulations. Sach school commit­
tee Is authorized to adopt rules and regu­
lations for carrying into effect the pro­
visions of this act and to make such 
arrangement with the respective persons In 
charge of the several denominations for the 
giving of aforesaid moral Instruction.
Section I*. Credit For Time Spent at Places of Wcyshlp.
Piplis attending their severalplaces of 
worship for moral instruction therein at 
the time specified and for the period fixed 
shall be credited with the time so spent as
173
If such pupils had been in actual attendance 
at school*
Section 5, Children to Remain in School or be Present at 
Place of Worship. Any child which for any " 
reason fails to receive the aforesaid moral 
instruction shall remain in school during 
the period when such instruction la being 
given and herein provided, but such child 
shall not receive any educational advantage 
over children receiving said instruction*
Section 6* Expense. The aforesaid moral instruction 
stxall be given without expense to any city 
or town, the pupils of which receive such 
Instruction, and no city or town, or the 
school committee thereof, shall Incur any 
expense for such Instruction beyond the most 
of the original survey, herein before men­
tioned.
Section 7. Intent of Act. It is hereby declared to be 
the intent of the legislature that this act 
shall be permissive and not mandatory*
-Maine Public Laws, 1939 Chapter 278.
Massachusetts* Absences may also be permitted for re- 
ligious education at such time as the school committee may 
establishJ provided, that no public funds shall be appropriated 
or expended for ouch education or for transportation incidental 
thereto; and provided, further, that such time shall be no more 
than one hour each week* -Chapter i|23
Approved June 30, 19^ .1*
Minnesota. That it Is the wish of the parent, guardian, 
or other person having control of such child, that he attend 
for a period or periods not exceeding in the aggregate three 
hours In any week, a school for religious instruction, con­
ducted and maintained by some church or association of church­
es, or any Sunday school association Incorporated under the 
laws of this state, or any auxiliary thereof, such school to 
be conducted and maintained in a place other than a public 
school building, and in no event, in whole or in part at pub­
lic expense; provided that a child may be absent from school 
on such days as said child attends upon instruction according 
to the ordinances of some church*
-Minnesota Session Laws I9I4.I 
Chapter 169, Article XII 
Section 5 Subdivision 3# (c)
17k
New York. Lawi Section 625-B £ Absence. Absence from 
required attendance shall be permitted only for causes allowed 
by the general rules and practices of the public schools. 
Absence for religious observance and education shall be per­
mitted under rules that the commissioner shall establish.
-April 9» 1914-0.
Rules!
I. Absence of a pupil from school during school hours 
for religious observance and education to be had 
outside the school building and grounds will be ex­
cused upon the request In writing signed by the par­
ent or guardian of the pupil.
2* The courses In religious observance and education
must be maintained and operated by or under the con­
trol of a duly constituted religious body or of duly 
constituted religious bodies.
3. Pupils roust be registered for the course and a copy 
of the registration filed with the local public 
school authorities.
k» Reports of attendance of pupils upon such courses 
shall be filed with the principal or teacher at the 
end of each week.
£. Such absence shall be for not more than one hour
each week at the close of a session at a time to be
fixed by the local school authorities.
6. In the event that more than one school for religious 
observance and education is maintained in any dis­
trict, the hour for absence for each particular 
school in such district shall be the same for all 
such religious schools.
-Issued July U, 19q0.
Oregon. Any child attending the public school, on ap- 
pllcatlon of his guardian or either of his parents, may be ex­
cused from such schools for a period or periods not exceeding
one hundred and twenty (120) minutes in any week to attend
week-day schools giving instructions In religion.
-Paragraph 30—3501 Oregon School Laws 
1937 now codified as Paragraph 111- 
3011|. Oregon Compiled Laws Annotated. 
Originally passed in 1920.
Pennsylvania. Any board of school directors of any 
school district shall have the power to enter Into suitable
175
arrangement with a religious group or organization of respon­
sible citizens resident In the school district, who are in­
terested in organizing part-time weekday religious education 
for school pupila. In such cases, the board of school direc­
tors shall have power to adopt such rules and regulations for 
the release from school sessions of those pupils whose parents 
or surviving parent or guardian, or other person having legal 
custody of such pupil, desires to have them attend a class to 
receive religious education In accordance with their religious 
faith for not more than one hour a week, subject however to 
such conditions and the keeping of such records as attendance 
at such classes and other records for the inspection of school 
authorities as the board shall deem proper. No part of the 
cost and expense of such religious Instruction shall be paid 
out of public school funds.
-Section 1615, Pennsylvania School 
Laws Approved May 17, 1945.
South Dakota. A child may, on application of his par­
ent or guardian, be excused from school for one hour per week 
for the purpose of taking and receiving religious instruction 
conducted by some church or association of churches or any 
Sunday school association incorporated under the laws of the 
state or any auxiliary thereof; said time, when pertaining to 
schools in open country, may be used cumulatively each separate 
month, as local circumstances may require. The county super­
intendent of schools In common school districts and the board 
of education in consolidated and Independent school districts 
shall decide at what hour pupils may be thus excused, and in 
no event shall instruction be given in whole or in part at 
public expense.
All applications for excuse from school attendance shall 
be in writing, and if granted, a certificate shall be issued 
by the superintendent of schools having jurisdiction over the 
district in which the child resides, stating the reason for 
such excuse and the period for which it Is issued.
Any reputable citizen who is dissatisfied with the 
decision of the country superintendent or school board, as 
the case may be, may appeal the matter to the Superintendent 
of Public Instruction, whose decision shall be final.
A permanent record of all such certificates of excuses 
shall be kept by the country superintendent and by the clerk 
of the board of education of an independent district and dupli­
cates forward to the superintendent of Public Instruction at 
the time of issue, and the teacher of the school to which child
176
belongs shall be promptly notified of the Issuance of such cer­
tificate, -Sec. 277, Chapter 138, 1931, Revised
In form only as amended by Chapter
66, 1941»
West Virginia. The county board of education may ap­
prove exemption for religious Instruction upon written request 
of the person having legal or actual charge of a child or 
children: Provided, however, that such exemption shall be sub­
ject to the rules and regulations prescribed by the county 
superintendent and approved by the county board of education.
-Article 8 Section I Exemption J 
West Virginia School Law.
Hawaii. The department shall provide for the release 
of, and shall release, any pupil In any public school from 
attendance at the public school for a period not to exceed 
sixty minutes each week during the school year, on such days 
and during such school hours as the department shall designate 
for the purpose of receiving religious Instruction from the 
religious organisation of his choice when such release Is re­
quested In writing by a parent, guardian, or other person hav­
ing custody or control of such pupil. Actual attendance at 
the sessions of such religious Instruction shall count as at­
tendance at the public schools for all purposes where attend­
ance forma the basis of computation.
The privilege of such release shall be withdrawn by the 
department In case the pupil does not actually attend the ses­
sions of religious Instruction. No teacher of the public 
schools, shall participate In such religious instruction dur­
ing the school hours for which he Is employed to teach In the 
public schools, and no public funds shall be used directly or 
Indirectly for such religious Instruction.
-(L. 1929, c• 134, as. 1 - 4 )  
Section 735> of the Revised Laws 
of Hawaii, 1935.
Philippine Islands. When the Philippines became Inde- 
pendent, they included In their Constitution and New Civil 
Code, the following articles: Article XIV, Section $ - ...
Optional religious Instruction shall be maintained In the pub­
lic schools as now authorized by law. Article 359. The 
government promotes the full growth of the faculties of every 
child. For this purpose, the government will extablish, when­
ever possible:
I. Schools In every barrio, municipality and city
where optional religious Instruction shall be taught
177
as part of the curriculum at the option of the par­
ent or guardian.
•Prom the New Civil Code of the 
Philippines, July I, 1950.
The old law referred to in the Constitution as author­
izing religious instruction In the public schools reads as 
follows! It shall be lawful, however, for the priest or min­
ister of any church established In the town where a public 
school is situated, either In person or by a designated teacher 
of religion, to teach religion for one-half hour three times 
a week in the school building, to those public school pupils 
whose parents or guardians desire It and express their desire 
therefore in writing filed with the principal teacher of the 
school, to be forwarded to the division superintendent, who 
shall fix the hours and rooms for such teaching. But no pub­
lic school teachers shall either conduct religious exercises 
or teach religion or act as a designated religious teacher in 
the school building under the foregoing authority, and no 
pupil shall be required by any public school teacher to attend 
and receive the religious instruction herein permitted.
Should the opportunity thus given to teach religion be used by 
priest, minister, or religious teacher for the purpose of 
arousing disloyalty to the United States or of discouraging 
the attendance of pupils at such public schools or creating a 
disturbance of public order, or of interfering with the dis­
cipline of the school, the division superintendent subject to 
the approval of the Director of Education, may, after due In­
vestigation and hearing, forbid such offending priest, min­
ister or religious teacher from entering the public school 
building thereafter.
•Section 928, Administrative Code of 1917 
of the Philippine Islands.
178
APPENDIX 
Appendix B
Letter Sent to Statea for Releaaed-Tlme Inquiry
909 W. Olive 
Bozeman, Montana 
April 23, 1957
Mre Roy Be Slmpaon
State Superintendent of Public Instruction 
721 Capitol Avenue 
Sacramento 14# California
Dear Sirs
The 1956 edition of the National Education Association 
Research Bulletin entitled "The State and Sectarian Education" 
indicates that California has a state law permitting school 
children to be absent from school for religious instruction,
I would greatly appreciate receiving a copy of this 
legislation and other related state decisions regarding re­
ligion and public education.
The Information will be Included In a thesis I am 
writing regarding religion and public education. May I thank 
you In advance for your kind cooperation.
Sincerely yours.
James W, Zottntck
APPENDIX
179
Appendix C
Letter Sent to Selected Cities for 
Released-Tlme Information
909 W. Olive 
Bozeman, Montana 
March 22, 1958
Mlos Meta Ruth Ferguson 
Director of Weekday Church Schools 
77 West Washington Street 
Chicago 2, Illinois
Dear Miss Ferguson*
It has been brought to my attention that the Church 
Federation of greater Chicago Is sponsoring an active released- 
time program, As I am currently engaged In gathering material 
regarding released-tlme for a proposed thesis, I am very much 
Interested in your program there In Chicago,
If possible, I would greatly appreciate receiving any 
printed material you may have that Is definitive regarding the 
weekday church schools In the Chicago area, I am particularly 
Interested In learning how extensive the program Is, and the 
mechanics of Its financing and operation. May I thank you In 
advance for your kind help.
Sincerely yours.
James W, Zottntck
180
APPENDIX
Appendix D
The First and Fourteenth Amendiaenta to the Constitution
of the United States
Amondnont I,, Ccxigreas shall make no law respecting an 
establishment of religion, or prohibiting the free exercise 
thereof; or abridging the freedom of speech or of the press; 
or the right of the people peaceably to assemble and to peti­
tion the Government for a redress of grievances.
Amendment XIV (1868), Section I, Civil Rights. All 
persons b o m  or naturalized In the UnTted States, and subject 
to the jurisdiction thereof, are citizens of the United States 
and of the State wherein they reside. No State shall make or 
enforce any law which shall abridge the privileges or Immuni­
ties of citizens of the United States; nor shall any State de­
prive any person of life, liberty, or property, without due 
process of law; nor deny to any person within its jurisdiction 
the equal protection of the laws.
APPENDIX
181
Appendix E
A Statement by the Christian Education Leaders 
of Cooperating Protestant Bodies
The church has for many years recognized the need for 
supplementing the Sunday church school with other periods of 
instruction during the week# Classes have been held on Satur­
day and after regular school hours# During the past half 
century there has also been marked development in a program 
that uses an hour or more a week of "regular school time" for 
religious Instruction outside the public school building.
This has come to be known as "the weekday church school on 
released time."
After a period of uncertainty, the legal questions rela­
tive to the program of the released time church school have 
now been cleared by the United States Supreme Court. At the 
same time, the growing recognition In our churches of the im­
portance of Christian education and the Increasing concern In 
the nation as a whole for the moral and spiritual welfare of 
all our children, have combined to create a greater Interest 
In the noaslbtltties of the weekday church school with special 
attention being focused on the released time program.
We support and encourage every effort to strengthen the 
total weekday church school program* At this time we take the 
opportunity to reaffirm our faith particularly in the released 
time weekday church school as an effective instrument for 
bhristlan teaching and we assume our share of responsibility 
for its future direction.
We believe In the weekday church school on released 
time because!
It Includes the teaching of religion within the frame­
work of the child's formal education.
It emphasizes the place which religion should have In 
the weekday life of our boys and girls as well as on 
Sunday.
It greatly expands our churches' total program of Chris­
tian education.
It enrolls large numbers of boys and girls hitherto un­
reached by Christian teaching.
132
It acquaints Its pupils with the lessons of the Bible 
and with the life and work of our Lord and Savior, Jesus 
Christ.
It Is an expression of the deepest needs and the most 
earnest purposes of American citizens.
It has proved its effectiveness by many years of success­
ful experience.
We believe further that our churches should now give 
their positive approval to this Christian teaching agency and 
include weekday church schools within their total programs of 
Christian education, making them schools of the church, by the 
church, and for the church.
Too we believe that weekday church schools are neither 
substitutes for, nor in competition with other church-spon­
sored agencies of Christian education or whatever religious 
emphases may be legally included in the programs of our public 
schools.
Further, we believe that. In the weekday church school, 
especially on released time, we have found a practical way to 
include the teaching of religion In the total education of 
American children and at the same time to give deserved and 
wholehearted support to our public schools.
We also believe that our churches should raise their 
present level of financial support for Christian education to 
make possible the quality of teaching represented In the best 
weekday church school programs.
We therefore call upon our churches. Individually and 
in cooperation —
To give thorough study to weekday religious education 
on released time, that they may be well informed as its 
educational requirements. Its costs, and Its values.
To explore the possibilities of establishing such pro­
grams in the communities In which they are located.
To Initiate limited experimental centers for the pur­
pose of demonstrating how a high-grade weekday church 
school program should operate.
183
To develop— on the basis of such study, exploration, 
and experimentation-— community-wide programs of week­
day religious education on released time for all the 
communities served by our churches*
In witness of our faith in the weekday church school, 
we have hereby subscribed our names, individually and as mem­
bers of the National Denominational Executives* Section of the 
Division of Christian Education of the National Council of the 
Churches of Christ in the United States of America*
Signed by the representatives of the following churches: 
National Baptist Convention of America 
Colored Methodist Episcopal Church 
American Evangelical Lutheran Church 
American Baptist Convention 
Church of the Brethren 
Evangelical United Brethren Church 
Presbyterian Church in the United States 
African Methodist Episcopal Zion Church 
The Methodist Church 
Moravian Church in America, North 
Five Years Meeting of Friends 
Church of the Nazarene 
Church of God 
Seventh Day Baptists 
Reformed Church in America 
Moravian Church, Southern Province 
Protestant Episcopal Church 
Associate Reformed Presbyterian Church 
Cumberland Presbyterian Church 
United Lutheran Church in America 
Evangelical and Reformed Church 
Congregational Christian Churches 
Disciples of Christ 
American Lutheran Church
United Presbyterian Church of North America 
Augustana Evangelical Iaitheran Church
MONTANA STATE  UN IVERSITY  L IBRAR IES
141116D 378 
Z 781 
cop. 2
Zottnick, j.w.
An investigation tif some 
tionfi0US asPects and ImplicaT
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