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>> 1 Introduction It should have been a mere formality. In 2006, Steve Elturk, president of the Islamic Organization of North America, planned to convert an existing office building in Warren, Michigan, into a mosque and education center, but he first had to obtain a variance from the city’s zoning board of appeals. What should have been a relatively straightforward process dragged on for months as city officials manufactured a multitude of reasons to deny Elturk’s request. At a series of planning commission public hearings in March and April, standing-room-only crowds gathered to voice their opposition to the proposed center. Their objections ranged from complaints about noise and traffic to more amorphous concerns about how the mosque would affect the character of the neighborhood. One irate resident even went so far as to issue a warning that worship at the mosque would include animal sacrifice. Sharing their constituents’ concerns, the planning commissioners delayed voting on Elturk’s application for as long as they could, until they were finally forced to relent under threat of litigation and a U.S. Justice Department investigation . Even then, they attached one final condition to their approval. Elturk would receive the requested variance only if he agreed never to install a loudspeaker or other amplificatory device to the building for the purpose of broadcasting the Islamic call to prayer. Elturk had never expressed any intention of doing so, but the city officials went out of their way to make clear that they would not put up with any noise.1 Three years later, Bishop Rick Painter, of Phoenix’s Christ the King Liturgical Charismatic Church (CKC), almost went to prison for ringing church bells. In June 2009, a Phoenix municipal court sentenced Painter to ten days in jail and three years’ probation for violating the city’s anti-noise ordinance (the sentence was suspended pending appeal). Neighbors had complained after Painter’s church installed an electronic carillon system that rang every half hour from 7:00 a.m. to 9:00 p.m., every day of the week. A belligerent Painter refused to back down, insisting that this amplificatory technology 2 > 3 ways. And through these differences, they have given voice to much broader debates about religion and its proper place in American society.3 Noise may seem like a relatively insignificant issue, at least as compared to the kinds of topics that often occupy scholarship on religion and American public life. Noise rarely appears in historical inquiries into how religious voices have shaped public policy or how religious actors have contributed to broader social movements, such as abolitionism or civil rights. It does not directly implicate fundamental questions about the origins and beginnings of human life, whom one has the right to marry, or how one ought to die. It is not obviously related to the practice of religion in America’s schools or prisons or about the extent to which limited public dollars should flow to religious institutions. Indeed, few social problems might seem as mundane or trivial as noise, so unexceptionally annoying and commonplace. Yet precisely for that reason, these relatively mundane disputes offer a surprisingly productive site for exploring competitions over public power, social order, and legitimacy in American society and for analyzing the concrete mechanisms through which Americans have managed their religious differences. They offer an important vehicle for investigating how religion’s boundaries have been carefully regulated throughout U.S. history, both overtly through punitive legal measures and more tacitly through widely shared social norms. Although seemingly unimportant, these cases raise much broader questions about American religious identity, the meaning and limits of religious freedom, and, indeed, the nature of religion itself. Through their varied responses to sounds deemed religious, the participants in these disputes have contested not just whether religion should make itself heard publicly in the United States, as if religion was a singular kind of “thing,” but how and in what manner it should do so. They have fought over what it means to be properly religious in America and, more broadly, what it means to be American, religiously speaking. Above all, they have debated who might enjoy a right to be heard in public and who should be expected to keep quiet.4 Noise has proven useful for this project of negotiating religion’s boundaries in the United States precisely because its meaning has seemed so indeterminate . On the one hand, complaints about noise have expressed genuine concerns about volume and decibel...

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