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prayer to the public schools. Many districts adopted a “moment of silence” instead. Historically, Catholic activists had sought to make the public schools as secular as possible, thus diminishing Protestant dominance . But in the wake of the Engel ruling, Catholic and even Jewish leaders expressed dismay that a “simple and voluntary declaration of belief in God by public school children” was being outlawed. They saw the efforts to remove all reference to God from schools as deeply troubling.37 Some religious groups, however, saw a silver lining in the Engel and Schempp decisions. In 1963 the Presbyterian Church (PCUSA) issued a statement that asserted that “Bible reading and prayers as devotional acts tend toward indoctrination or meaningless ritual and should be omitted for both reasons.” As part of the shift away from an ethical education linked directly with the (dominant Protestant) religious framework, the religious elements had become increasingly less meaningful to the many students whose religious commitments (or lack thereof) lay elsewhere. While the resulting “culture religion” remained attractive to many religious liberals, at least some conservative adherents felt that an empty, uninspiring ethical education was worse than none at all.38 While the majority opinion on Schempp was clear in its rejection of devotional Bible reading, it also added an important emphasis on public schools’ role in educating about religion: It might well be said that one’s education is not complete without a study of comparative religion or the history of religion and its relationship to the advancement of civilization. It certainly may be said that the Bible is worthy of study for its literary and historic qualities. Nothing we have said here indicates that such study of the Bible or of religion, when presented objectively as part of a secular program of education, may not be effected consistently with the First Amendment. While I will argue in later chapters that the idea of “objective study about religion” needs rethinking, this acknowledgment by the Court was one of the first judicial depictions of the government’s role as one of neutrality regarding religion, as opposed to the heretofore prevailing idea of separation between government and religion. If the state via public education is to be neutral regarding religion, it must not only avoid favoring one religion over another but also avoid favoring nonreligion over religion. Separationist policies that seek to prevent religion from being explored in the context of public education create a decidedly non-neutral environment. But the implications of this conceptual distinction were not recognized, as 27 Evading the Ethical ethical education continued to disengage from its singular religious source and transmuted into curricula that largely ignored or suppressed consideration of deep ethical sources almost entirely, religious and otherwise.39 ETHICAL EDUCATION ON THE SECULAR SIDE OF THE WALL While post-World War II America expressed strong support for ethical education, this commitment began to wane in the 1960s, as a concern for maintaining moral neutrality gained priority along with stronger distinctions between the public and private realms. Added to this was an increasing focus on technological and scientific advancement that emphasized “academic” skills. It was out of this decade, however, that two distinctive approaches to ethical education emerged. In 1966, the values clarification approach was introduced by Raths, Harmin, and Simon in their book Values and Teaching : Working with Values in the Classroom. While this approach has largely fallen out of favor, the sentiments behind it still operate as a subtext in many classrooms today. As its name suggests, the values clarification model aims for students to engage in discourse that allows them to clarify their own set of values through discussion of moral situations. In this approach, the teacher is encouraged to help students explore their own beliefs but not to provide direct instruction concerning their possible benefits and drawbacks.40 Although widely popular among teachers (one particular handbook sold an amazing 600,000 copies), values clarification came under harsh criticism beginning in the 1970s, both on empirical and conceptual grounds. From 1969 to 1985, a total of seventy-four research studies indicated that values clarification programs fostered very limited changes in a variety of moral categories: personal values, self-concept, attitudes toward school, dogmatism, and behavior. This preponderance of data did little to curtail the use of values clarification techniques in schools, however. It wasn’t until philosophical and political critiques raised the specter of unchecked relativism that values clarification was widely abandoned.41 From a conceptual standpoint, Thomas Lickona criticizes values...

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