In December of last year, officials in the New Britain, Connecticut, school district suspended teacher Marisol Arroyo-Castro for insubordination after she ignored their orders to remove a small crucifix from near her desk. This essay will examine the underlying facts before reflecting on what this controversy portends for the future of religious freedom in education.
The controversy
Ms. Arroyo-Castro, who “regularly received ‘proficient’ or ‘exemplary’ evaluations” since 2004, has almost 33 years of teaching experience, having taught both fourth and seventh-grade classes in New Britain. Ms. Arroyo-Castro refused to obey officials in early December 2024 after being asked to remove the small crucifix from her classroom workplace. The crucifix had been given to her by a now deceased friend and had been displayed in her classroom workspace for about ten years. Ms. Arroyo-Castro, who is Catholic, often looked at the crucifix for “peace and strength, especially when the (already stressful) task of teaching young students proved particularly challenging.” Further, at lunchtime, she typically stayed at her desk to look at the crucifix and pray.
Officials removed Ms. Arroyo-Castro’s crucifix, claiming that its presence “posed the risk of appearing to observers that she favored Christian over non-Christian students or that the school endorsed Christian beliefs, in violation of the Establishment Clause.” However, these officials did not object to displays that other teachers had near their desks of “photos of family and friends , images of Wonder Woman and Baby Yoda, a miniature of the Mona Lisa, New England Patriots football team pennant, inspirational quotes, a photograph of a statue of the Virgin Mary, and a mug referencing a Bible verse.”
When officials ordered Ms. Arroyo-Castro to place the crucifix under her desk to avoid having students see it, she responded that she could not return to work under such a condition.
Ms. Arroyo-Castro is represented by WilmerHale, a successful high profile national law firm, through its Boston office, and the First Liberty Institute of Plano, Texas, “the largest legal organization in the nation dedicated exclusively to defending religious liberty for all Americans.”
Ms. Arroyo-Castro seeks to get her job back after being placed on paid administrative leave and being threatened with dismissal, as officials pressured her to resign or retire early and to not file a suit.
Ms. Arroyo-Castro’s suit charges that officials violated her First Amendment to the free exercise of her religion and free speech. In her defense, her attorneys cite the Supreme Court’s 2022 ruling in Kennedy v. Bremerton School District that educational officials could not prevent a football coach from praying silently on the field after games.
The demand letter on her behalf referred to the Court’s having “dispelled the ‘false choice’ between the Establishment Clause and the Free Exercise Clause.” The letter reminds officials that the Kennedy Court reasoned that “the demand to completely suppress from view religious expression proved an unreasonable burden on deeply held convictions” was unconstitutional.
The suit also alleges that officials violated her rights under Connecticut law by burdening her religious freedom.
At the same time, the formal judicial complaint filed on her behalf cites the letter Ms. Arroyo-Castro wrote to the board noting that “[g]uidance from President Biden’s U.S. Department of Education [in 2023] explains:
In contexts where a school permits teachers, coaches, and other employees to engage in personal speech…it may not prohibit those employees from engaging in prayer [or other personal expression] merely because it is religious or because some observers, including students, might misperceive the school as endorsing that expression.
Ms. Arroyo-Castro seeks to enjoin officials from suspending, dismissing, or otherwise disciplining her for displaying the crucifix; returning her to her job without conditions over the crucifix’s placement; and expunging her record of the disciplinary sanctions she faced.
Additionally, she seeks a declaratory judgment that officials violated her federal and state law rights along with costs, attorney fees, and other relief the court deems appropriate.
Selective animosity despite the First Amendment
Consistent with the Supreme Court’s judgment in Kennedy, educational officials cannot infringe on the religious expression rights of teachers solely because they acted in public schools. It is unfortunate that in a nation founded in part on the belief in religious freedom as reflected in the First Amendment, namely that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof,” that public school officials adopted an short-cited view of Ms. Arroyo-Castro’s right to display her crucifix.
And yet Dario Soto, the principal at Ms. Castro-Arroyo’s school, insultingly told her “that her prayers with her crucifix were a form of ‘idol’-worship” while allowing others to post secular items in their work areas.
School officials seeking to limit Ms. Castro-Arroyo’s fundamental right to the free exercise of religion would have to demonstrate that their actions were justified by a compelling governmental interest using the least restrictive means, standards they failed to reach. Further, officials violated her right to free speech by limiting how she could express her beliefs. In lights of the board’s espoused policy of “ valu[ing] diversity of backgrounds, beliefs, and perspectives and…promoting an equitable and inclusive educational environment,” officials’ behavior demonstrated blatant hypocrisy.
It is unclear why officials believed the posting of the crucifix “posed the risk of appearing to observers that she favored Christian over non-Christian students or that the school endorsed Christian beliefs….” If being educated involves “valu[ing] diversity of backgrounds, beliefs, and perspectives,” what risk or harm would children have experienced by seeing a crucifix, or some other religious symbol, in a public school? It is not clear how posting the crucifix violated the Establishment Clause.
The response of New Britain officials calls to mind Justice Scalia’s dissent in 1992’s Lee v. Weisman, wherein the Supreme Court invalidated school-sponsored prayer at a middle school graduation ceremony. Scalia wondered whether the Nation has reached “the point that anyone who does not stand on his chair and shout obscenities can reasonably be deemed to have assented to everything said [or seen] in his presence.”
Why are different points of view not be allowed to exist as part of diversity of perspective, especially in schools?
Ultimately, such situations come down to a question of objective values: will only secular views be allowed in schools as people of faith are relegated to the second class status Justice Alito’s dissent feared in 2015’s Obergefell v. Hodges’ wherein the Supreme Court discovered the heretofore unknown right to same sex-unions? Alito worried that if people of faith expressed their views in public, like Ms. Castro-Arroyo, “they will risk being labeled as bigots and treated as such by governments, employers, and schools,” hounded as she was to resign for expressing her Catholic beliefs in a public school. It remains to be seen whether the board will amend its approach or the matter proceeds to trial.
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When freemasonic instigated post-conciliarism requested that Christian nations end the reign of Christ the King and embrace multiculturality they paved the way for this situation. The application of Vatican II by Rome is to blame, not the local school authorities.
DT signs Executive Order to eradicate anti-Christian bias:
https://www.whitehouse.gov/presidential-actions/2025/02/eradicating-anti-christian-bias/
I don’t agree, Mr Cracked Nut. The blame rests solely on the school district authorities, because it was their pathetic choice to hassle Ms Castro over her crucifix. Your blaming of the Vatican II council for this situation over a crucifix is almost as ridiculous.
The New Britain school district would’ve done the same thing to this person, regardless of whether Vatican II occurred or not, as the world has become increasingly Godless, but that’s not the fault of Vatican II. That’s the fault of anyone who has deliberately chosen to reject Christ and embrace the materialistic world.
You can’t blame something you don’t like over someone else’s actions.
Many thanks for your comments, all.
Stay tuned, let’s see if the board blinks, so to speak.
Charlie
Meanwhile, the Bishops wish to intervene in immigration policy and temporal matters, using duplicitous terms like “undocumented immigrant” and “immigration status”, where are they as forces of this world white martyr this woman?
She is being supported by First Liberty Institute.
She should just afix it to her nose and she would be in vogue and compliance, like the rest of us have to endure when encountering the “ringed” in public.
Whatever we do, we don’t want people with any character, silent or otherwise, in charge of teaching our youth!
Granted the inconsistency of the school officials (if an image of Our Lady was permitted, why not a crucifix?). However, if the teacher wants to have religion on display, she should not be hiring herself out to a godless institution, to begin with. Go teach in a Catholic school!
Fr. Stravinskas, I can’t think of any of your writings that I’ve read that I haven’t supported. Until now!!! Following your “logic” here, St. Isaac Joques (and all other martyred missionaries around the world throughout time) should never have been martyred – they should have scurried back “where they belong” when confronted by secular powers. This woman is a hero and should be supported 100% by us Catholics!
“And yet Dario Soto, the principal at Ms. Castro-Arroyo’s school, insultingly told her “that her prayers with her crucifix were a form of ‘idol’-worship” ”
This is a very interesting comment and indicates that the underlying personal dynamics here may not be only the secular hostility to Christianity, though that is certainly present and is at the center of the lawsuit. The comment sounds like the sort of thing a protestant of a certain sort would throw at a Catholic and makes me wonder about Mr. Soto’s religious background. Given his surname, if Mr. Soto were of a Catholic background I don’t think he would have made that particular accusation.
I know nothing about this situation beyond the article but in my own experience the people who often are the most anti Catholic are fallen away Catholics.
I’ve experienced that same phenomenon. Interestingly enough, the anti-Catholicism of a lapsed Catholic often reflects the maturity level of the person when he or she abandoned the Faith. For example, one could be talking to a well-educated, well-read 40-year-old, but if that person left the Church, slamming the door behind her when she was 16, when the subject turns to Catholicism, that well-educated, well-read 40-year-old often suddenly reverts to the angry 16-year-old who just slammed the door behind her.
Thank you for sharing that. I hadn’t thought about it that way before.
“Brava!” to Ms. Arroyo-Castro for exercising her Constitutionally guaranteed right to freedom of religion. Do school officials fear that the students will actually learn something beneficial?
Reece Newman
Bravo, Marisol Arroyo-Castro! Jesus said, “So everyone who acknowledges me before men, I also will acknowledge before my Father who is in heaven…” (Mt 10:32)
The crucifix:“Posed the risk of appearing to observers…”
The word:”appear” , the antonym for it- disappear.
Is this what people want-be careful what you wish for-
I am sure glad she is a teacher in a public school. It’s just a recess now for her, much support and encouragement for Ms.C.-A.
I pray more people read the Bible and learn to love their neighbors.
Selective animosity & rank hypocrisy, indeed! The author does a great job of highlighting these and it will be fascinating to observe how the Kennedy decision may play a part in the outcome of Ms. Arroyo-Castro’s suit. I was especially stunned by the Principal’s comments to her about the crucifix!!
Ah, but salaries are RC schools are much lower.
Plus, with schools closing as in NYC, where can one go?
I would suggest pulling the kids from the Godless public schools that are operated by the uber-leftist Dept of “Education” and either homeschool your own kids in the Faith, or find a private school if you have the money.
Not sure that the teacher in question is a victim here. Ideally, a public school classroom should be neutral. There is no reason for individuals to overtly bring their religious beliefs & practices or their politics into the classroom. Would we feel the same way if a practicing witch wanted to hang Wiccan symbols up in the classroom? What about someone who practices New Age spirituality and who hangs crystals up in the windows? What about a statue of Ganesh on the desk for Hindus? If you make exceptions for one faith, you have to allow all of them if you are going to be consistent.
It’s a public school. Would the above commentators be ok with a Buddha statue or a picture of Krishna in the classroom?
That sort of stuff is very common in public schools here in Oregon. Along with plenty of other “stuff”. So…
That’s interesting. The school system is not monolithic. I guess there is a lot of variation in terms of what is and is not allowed or supported in a particular district.
Oregon’s school system is bottom of the barrel. In nearly every possible way. The amount of blatant woke, radical left-wing, pro-LGBTXYZ stuff is off the charts.
Indeed Mr Olson. Not to mention Portland’s crime and homeless rates, in addition to Governor Brown’s retarded environmental policies that have crippled Oregon’s economy.