Religion and the Law

Eugene Volokh | 5.9.2025 8:01 AM

The ABA Journal (Debra Cassens Weiss) reports on the settlement (in which "defendants did not admit liability"):

The lead plaintiff in the [class action] suit, Kaya Hudgins, was a practicing Muslim at the time of the "Quiet Time Program," according to prior coverage by Patch and Religion News Service and an April 2024 press release. Transcendental meditation was represented as nonreligious, but the mantras that students were taught to silently repeat were in fact words that honored or referenced specific Hindu deities, the suit had alleged.

The suit also alleged that students were required to complete a "Puja" initiation ceremony that included chants recognizing powers of Hindu deities.

Here's an excerpt from Judge Matthew Kennelly's decision in Williams v. Bd. of Ed. (N.D. Ill. 2021), which had allowed a related lawsuit to go forward:

Williams attended Bogan Computer Technical High School (Bogan) in Chicago from fall 2017 until he graduated on June 18, 2019. While Williams was a student, Bogan implemented the Quiet Time program during the 2017–18 and 2018–19 school years….

According to Williams, his first experience with Transcendental Meditation as a part of the Quiet Time program occurred during the 2018–19 school year, when he was eighteen years old. He stated that he did not receive any letters about the program to give to his parents, but in October 2018 he and other students were given a document titled "Quiet Time Program Student Application for Transcendental Meditation Instruction Bogan High School." He also stated that he had been informed that Transcendental Meditation was "a really effective way to meditate and find yourself" and that he signed the form when it was first presented to him because he "was interested learning [meditation] properly."

Although the document included language stating that "learning the TM technique is an optional activity," Williams maintained it was "not optional" and "mandated" for students to sign the document. He explained that this was because students who initially chose not to learn Transcendental Meditation "eventually had to sign up," though "off the top of [his] head at the [moment]" he was unable to name any student who did not sign the document at first and later "was forced to do [Transcendental Meditation]." As for meditating during the fifteen-minute Quiet Time periods, Williams did not dispute that "if [he] didn't want to do [Transcendental Meditation], [he] didn't have to."

In contrast, Principal Aziz-Sims testified during her deposition that students could choose not to learn Transcendental Meditation. She stated that although students who were disrupting others during Quiet Time may have been reprimanded by a teacher, an administrator, or the principal herself, she was not aware of any Bogan student being disciplined for choosing not to learn Transcendental Meditation. She also testified that she approved giving students at least two letters explaining Quiet Time to their parents and allowing their parents to opt out of the program, in accordance with the school's policy regarding student involvement in other school activities.

Sunita Martin, an independent contractor with DLF [David Lynch Foundation] who was involved in implementing Quiet Time, similarly stated that students were given an "opt-out packet" and instructed to "take it home and give to their parent or guardian so that they could look it over and if........

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