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PLANS


People for Legal and Non-Sectarian Schools (PLANS) is an organization based in California in the United States which campaigns against the public funding of Waldorf methods charter schools alleging they violate the United States Constitution's separation of church and state. The group claims independent Waldorf schools and public Waldorf methods charter schools teach anthroposophical content, that this content is religious in nature, and that the schools disguise the anthroposophical content from the public. PLANS filed federal suit in 1998 against two California public school districts, Sacramento City Unified School District and Twin Ridges Elementary School District, to halt the Waldorf methods educational programs implemented in two of their schools. The case was ultimately dismissed on its merits in 2012.

The group was founded in 1995 and became a California non-profit corporation in 1997. Its founding officers, president Debra Snell and secretary Dan Dugan are former Waldorf school parents. The organization numbered less than 50 members when the lawsuit was brought.

The group describes its mission as to

In February 1998, PLANS filed suit against two California public school districts, Sacramento City Unified School District and Twin Ridges Elementary School District, operating Waldorf-methods schools; one operating a Waldorf-based charter school and the other operating a Waldorf-based magnet school. In the complaint, PLANS argued that it was "informed and believes that a primary purpose and primary effect of said operation of Waldorf schools is to advance religion, including the religious doctrines of Anthroposophy", and as such were acting in violation of the First and Fourteenth Amendments of the United States Constitution and Article IX of the California Constitution.



  • In 2001, the Court dismissed the case. A legal precedent set earlier in a similar case in New York, though not related to Waldorf education, led the Court to find that PLANS lacked grounds to claim taxpayer standing in the case. After an appeal by PLANS, the US 9th Circuit Appellate Court in February 2003 reversed the decision on taxpayer standing by the lower court, allowing the case to proceed towards trial.
  • In May 2004, PLANS filed a motion for summary judgment, or, in the alternative, summary adjudication, requesting that the Court rule that anthroposophy is a religion, based on material presented by PLANS. But the Court did not accept these arguments, and on 15 November 2004 denied the motion, stating that "triable issues of material fact exist as to whether Anthroposophy is a religion". The Court also provided a new opportunity for both sides to declare witnesses and evidence, with a deadline of January 2005 for disclosure of these.
  • In April 2005, the Court issued an order outlining the trial issues and the evidentiary and procedural guidelines for the trial, scheduled for September 12, 2005. The court separated the issues, stating that it would be first necessary to try the question of whether anthroposophy was a religion, and secondly, whether anthroposophy was present in the schools. The order denied PLANS eleven witnesses, for failure by its attorney to make timely disclosure to Defendants, and 105 of PLANS' exhibits, as a result of discovery sanctions.
  • In June, 2009, PLANS' lawyer for the case tendered his "resignation with disciplinary charges pending" from the California Bar; previous disciplinary charges in 2007 and 2008 had cited willful violations of the professional code.
  • In August, 2010 the second trial is set to begin in federal court in Sacramento.
  • In November, 2010 the ruling on the second trial was published, with a finding against the plaintiff (PLANS) and for the defendants. An appeal was planned with the support of the Pacific Justice Institute.
  • In 2012, PLANS' appeal was heard by the U.S. Court of Appeals for the 9th Circuit. The Court affirmed the 2010 ruling and the case was dismissed on its merits.
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