December dilemmas: the celebration of Christmas in American Public Schools
As contentious as Americans are about prayer1 and other forms of religious expression in public education,2 it is amazing to consider the dearth of litigation over a related, complex issue, the celebration of religious holidays, most notably Christmas, in public schools. In fact, while the Supreme Court has addressed Christmas holiday displays on two occasions, and lower courts have examined the appropriateness of Easter as a school or public holiday, there has been no direct litigation on the place, if any, of Christmas in public schools. The question is all the more complex due to the important place that religion has played, and continues to occupy, in American life as educators seek ways to teach students to appreciate diversity in all of its manifestations, including religion. This article briefly reviews the litigation in this area, little of which admittedly involves education, and reflects on the 'December Dilemma' that confronts educators in American public schools.