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Based principally in San Francisco, U.S. and on the Web,, People for Legal and Non-Sectarian Schools (PLANS) campaigns against the public funding of Waldorf methods charter schools, and against Waldorf education generally.

The group was founded in 1995 by former Waldorf parents and became a California non-profit corporation in 1997. Its president is Debra Snell and vice president is Lisa Ercolano. Its secretary is sound engineer and skeptic activist Dan Dugan. Other board members as of 2006 include Judith Daar (public school teacher), John Morehead (Neighboring Faiths Project), Daniel Sabsay (President, East Bay Skeptics Society), and Kathleen Sutphen (public school teacher, former public Waldorf school teacher). In 2000, Dugan reported 44 members.

Mission statement

The groups describes its mission as to

1. "Provide parents, teachers, and school boards with views of Waldorf education from outside the cult of Rudolf Steiner."
2. "Expose the illegality of public funding for Waldorf school programs in the US."
3. "Litigate against schools violating the Establishment Clause of the First Amendment in the US."

Charter schools lawsuit

In February 1998, PLANS filed suit against two California public schools districts, Sacramento Unified School District and Twin Ridges Elementary School District operating Waldorf-methods schools; one a charter school and one a magnet school. PLANS argued that because the basis of Waldorf education comes from Anthroposophy, publicly-financed Waldorf methods charter schools are in violation of the "church and state" Establishment Clause of the First Amendment.

The organization asserted that the implementation of Waldorf teaching methods in public schools violates the Constitution because those methods are inseparable from its underpining religion, Anthroposophy, and that as a result, public schools that adopt Waldorf methods or practices are promoting religion in violation of the US Constitution. PLANS argued in this law suit that the primary purpose and effect of the operation of the two Waldorf-methods schools in those school districts was "to advance religion, including the religious doctrines of Anthroposophy".

In 1999, the Court ruled against the contention, finding that the two school districts targeted have a secular, non-religious purpose for implementing Waldorf teaching methods in their schools, but allowed the case to proceed to determine if those programs have the unintended consequence of directly and substantially advancing religion to such an extent that it violates the U.S. Constitution.

The trial was scheduled on September 12, 2005, and was expected to run for 16 days. The presiding judge determined two issues to be decided in the trial. The first issue was to determine if Anthroposophy is a religion for Establishment Clause purposes - the defendants contended it was not. The second issue, which required first an affirmative ruling that Anthroposophy is a religion for Establishment Clause purposes, would decide whether the public schools in those two districts were promoting Anthroposophy, now viewed as a religion, to such an extent that it violated the U.S. Constitution.

The trial convened as scheduled, but ended after 30 minutes after PLANS failed in their legal burden to present an offer of proof (proffer) of evidence sufficient to prove Anthroposophy was a religion. PLANS' attorney told the court PLANS could not meet its burden, and that it could furnish no witnesses. PLANS did attempt to introduce one piece of documentary evidence on the religion issue. Arguments were heard, but no evidence was presented during the trial. The court ruled that PLANS failed its evidentiary burden of proof, and ordered the case be dismissed on its merits.

Decision is appealed

PLANS filed an appeal of the decision in November, 2005. The appeal claims that the earlier rulings preventing PLANS from calling two defense expert witnesses for their own case-in-chief left them no witnesses able to give evidence that Anthroposophy was a religion, and that the two witnesses they were disallowed were irreplaceable. The earlier rulings resulted from pretrial motions submitted six months prior to trial. The appeal also argues the court ruled improperly when it refused to allow PLANS to enter its one piece of documentary evidence.

These two witnesses PLANS wished to call were first disclosed by the defendants who would testify against PLANS in the case. PLANS argues in the appeal that a timely disclosure rule cited in the judge's dismissal was not in effect in 1998 when the case was filed, and claims the witnesses were fully disclosed under the applicable rules.

The appeal also argues that the court erred in disallowing attempts to introduce as evidence a particular book which one school in the suit purchased for their educational reference library. PLANS had no witnesses prepared to offer foundational testimony at trial for the evidence, and as a result it too was disallowed, the judge describing it as "rank hearsay". In its appeal, PLANS argues that the school's earlier interrogatory admission to the purchase of this book served as an "adoptive admission", and as such no further foundation was necessary prior to introducing it as testimony in evidence at trial. The defendants dispute the validity of each of these claims in their Appellee Brief.

Ultimately, the only fully qualified expert witness to be heard on the question whether Anthroposophy is a religion would have been Douglas Sloan, a witness slated to testify for the defendants. Sloan is a Columbia University Professor Emeritus of Education, adjunct Professor of Religion and Education at the Union Theological Seminary and The Jewish Theological Seminary in New York City and former Director of the Masters Degree Program in Waldorf Education at Sunbridge College, New York.

Since PLANS presented no legally acceptable testimony or other evidence, the defense won the case without calling their own witnesses at trial. However, Sloan did submit his testimony rejecting the assertion that Anthroposophy was a religion in a declaration. The judge accepted this submission when PLANS filed a motion asking the court to decide the issue prior to trial and declare Anthroposophy to be a religion, a motion rejected by the Court.

Case history

After its first ruling in 1999, the U.S. District Court -- Eastern District of California has issued rulings on the case in 2001, 2004 and 2005: See Legal transcripts on Wikisource.

• 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 conclude that PLANS lacked a basis to claim taxpayer standing in the case. After an appeal by PLANS, the 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 101 of PLANS' exhibits, as a result of discovery sanctions.

History of the public activity of the group

One of the first steps taken in PLANS' campaign to expose Waldorf methods public schools was to seek the support of members and associates with the Skeptics Society, six of whom became members of the PLANS governing board and supporting advisors panel. PLANS secretary, Dan Dugan, delivered prepared presentations in Skeptics Society and Atheists and Other Freethinkers meetings, and PLANS distributed packets of prepared print materials to school boards which were at the time considering adopting Waldorf methods in their districts. Dugan also established the organization's internet webpage and moderated its public email discussion list, devoted to topics on the Waldorf curriculum, Anthroposophy, and to discussion related to the Waldorf schools.

In February 1996, Dugan delivered a slide presentation to the school board in Twin Ridges Elementary School District. The district had been operating a Waldorf methods charter school for two years. In response to Dugan's presentations, a local committee formed, headed by Baptist pastor, James Morton, and members of the committee argued both in public meetings and through the local media outlets that the school's teachings were in conflict with the US constitution's provision regarding the separation of church and state. Morton soon joined PLANS and took a place on its governing board. ,

PLANS contacted the California Attorney General in March of 1997, arguing for an investigation into Waldorf Methods public schools statewide, urging the officer to act immediately to end the funding of all such schools.

In April 1997, Dugan delivered arguments against the public funding of Waldorf methods education to a board meeting of the Yuba County Office of Educationin Marysville, California. The county operated two schools for juvenile offenders which were both engaged in an experimental project to develop a nationally-replicable Waldorf-based educational model. Shortly after this meeting, PLANS set up a picket line at one of the Yuba County Waldorf-based schools. One of the school's teachers, Kathleen Sutphen, joined the PLANS campaign and became Vice-President of their governing board.

In spring 1996, PLANS made its first contact with the Sacramento Unified School District to urge district officials there to discontinue their planned Waldorf methods magnet school program. Conversion to the new program was funded in its first year by a $238,000 federal grant, a portion of it used to begin training the school's faculty in the Waldorf approach. The magnet program proceeded as planned, and Waldorf methods were adopted at the beginning of the 1996/97 school year at Oak Ridge Elementary School. A parent survey conducted in the following spring indicated parents were mostly satisfied with this new teaching program. Attendance improved and none of the enrolled students applied for transfer during the district's "open enrollment" period. But 11 of the 26 teachers requested transfers from Oak Ridge School - half for personal reasons, and the rest objecting to the Waldorf teacher training or to its educational philosophy. ,

In response, PLANS redirected its efforts from school district officials toward the parents, teachers and students of the school itself, and began privately counseling some of the teachers. On April 30, 1997, PLANS officials distributed leaflets entitled, "Save Oak Ridge School From the Steiner Cult". Some parents reacted by forming a local committee called "Concerned Citizens for Oak Ridge School". In May, news media reported that controversial statements had been made during an Oak Ridge meeting, accusing the school of teaching the students about witchcraft, human sacrifices, and religious altars, and charging that the children were being initiated into a cult. Soon after, PLANS held protests in front of the school, and picketers waved flags and anti-Waldorf signs, some demanding the termination of two staff members in the school.

In a newspaper interview in May, Dan Dugan commented on the independent Waldorf school in Davis: "They believe that there are spirits behind everything. I know there are people who would call that evil. (They) would consider anthroposophy a satanic religion.". When criticized by a supporter for the way PLANS was trying to get support from Christian fundamentalists by using an alleged connection between anthroposophy (the philosophical basis of Waldorf education) and satanism, he defended this on his mailing list: "What I say 'in defense of the Waldorfians' is that 'they don't eat babies.'", "Am I pandering to the prejudices of Christians? Personally, yes I am!".

In June 97, the school district superintendent mailed letters to parents of the school warning that threats of force had been reported, raising concerns about safety at the school. It also described reports of attempts made to intimidate and bribe students to discourage them from attending school. One school official quoted in a news report indicated that Waldorf teachers in the training college had received death threats, prompting PLANS spokesperson, Dan Dugan, to respond to a reporter that he wished no ill to come to anyone, and to describe the educators as "misguided", not "evil".

In the summer of 1997, district officials voted unanimously to continue the Waldorf methods magnet program, but to relocate it to another campus, John Morse Elementary. PLANS board member, Pastor Morton, sought legal assistance for PLANS, and found lawyer Scott Kendall, an attorney affiliated with the Christian evangelical legal organization, the Pacific Justice Institute (PJI). The PJI applied for a grant on behalf of PLANS, seeking to raise funds from the evangelical Alliance Defense Fund (ADF) to initiate PLANS' legal suit against public school districts operating Waldorf methods schools. The application alleged the Sacramento school engaged in "Wicca" based practices, religious proselytizing and coercion, and that a third of the parents had kept their children home from school in protest. A video copy of a local televised news report about the controversy accompanied the application. ADF awarded a $15,000 grant in February 1998, and immediately after, PLANS filed suit against Sacramento City Unified School District and Twin Ridges Elementary School District, demanding a permanent injunction against the implementation of the Waldorf methods curriculum in the schools, as well as full reimbursement for all legal costs. PLANS entered into a signed agreement with the Concerned Citizens for Oak Ridge School, promising the organization that in exchange for their efforts assisting PLANS in the lawsuit, PLANS would share one-fifth of any proceeds awarded in the event of a favorable judgement and "cost multiplier" fines imposed.

In July 2000, Snell and current Vice-President, Lisa Ercolano, began a confidential email support group reserved for those with negative experiences in Waldorf schools or other Anthroposophical activities. And in December 2000 Snell and Dugan hired a private detective to attend a voluntary Winter's Solstice celebration for K-3rd graders which took place in the evening in a privately rented meeting hall. A hidden camera was used to secretly videotape the children's celebration. PLANS publicly played the tape in a presentation to a school board in Chico, California, and argued that it was evidence that Waldorf teaching methods are religious.

In ongoing challenges against the Waldorf methods public schools in other districts, PLANS pointedly referenced their pending lawsuit, warning that other districts too would face expensive legal challenges if they allowed Waldorf based methods in any of their schools. PLANS' challenges against Waldorf methods charter schools in the Chico Unified and Ross Valley school districts resulted in the denial of pending charter school proposals there. However, the proponents of those charters soon reapplied in alternative districts nearby and both charters were accepted: the Blue Oaks Charter School, opened September 2001 under Chico's Butte County Office of Education, and the Waldorf-Inspired School of Lagunitas, opened September 2004 under Lagunitas School District. Sacramento Unified, Twin Ridges Elementary, and Yuba County districts also continue to operate their Waldorf methods programs. Today, there are 19 public schools in California that have adopted the Waldorf methods., ,

Criticism of PLANS

The Oak Ridge School in Sacramento became the target of threats and accusations that its teachers led children through witchcraft and sorcery practices in the classroom. School officials accused PLANS of playing to public prejudices and paranoia, and arousing anxieties in the community by presenting a distorted view of their teachings to the parents of the school, most of whom weren't English proficient. Sacramento newspapers characterized the controversy as an "hysteria" manipulated by disgruntled outsiders with an extreme ideological agenda. Local picketers who joined the PLANS organization to protest against Oak Ridge credited the PLANS leaflets as the initial source of their concerns, and the town's newspaper concurred, pointing to data from the school which indicated both positive impacts on absenteeism and voluntary re-enrollment, as well as overall parent satisfaction as measured just weeks prior to PLANS appearance at the school. The paper's editor accused PLANS of alarming parents with claims for which there was no evidence, including the suggestion that Waldorf methods were disguised witchcraft teachings.

Public school officials in California's Marysville, Twin Ridges, Novato and Butte schools criticized PLANS as well; one principal quoted in a newspaper expressing outrage over "the lies, the distortion of facts." The accuracy and expertise of PLANS officials also came under attack during lawsuit witness hearings. Six of the PLANS board directors and advisors (Dugan, Snell, Sutphen, Morton, Morehead, and Eugenie Scott) sought to testify as expert witnesses in the case, but each was eliminated due to their lack of expertise on the subjects of Anthroposophy and Waldorf education: three were eliminated by the court judge, and the other three subsequently withdrawn voluntarily by PLANS' attorney, Kendall. After reviewing key sections of the deposition testimony taken of PLANS' most vocal spokesperson, Dan Dugan, the judge expressed "grave doubts about any reliance upon his opinions about anything that has to do with any intellectual endeavor, including Anthroposophy" before ruling that Dugan would not be allowed to give testimony in the trial.

PLANS has also been accused of using rumors and threats of lawsuits to intimidate school boards to reject proposals for new Waldorf-based charters. When PLANS succeeded in convincing board members in Ross Valley and Chico school districts to vote against proposed Waldorf methods charters there, both proposals were welcomed by other school districts nearby, allowing the new schools to go forward. Local news commentators in one of the targeted communities castigated their local school district for caving to PLANS' threat of a lawsuit, and showcased the episode as one of the most notably "boneheaded or downright wrong things" of the past year.

The Anthroposophical Society in America (ASA), which is the legal representative of Anthroposophy in the United States, has challenged PLANS over PLANS' characterizations of Anthroposophy, as well as PLANS' suggestion that the Anthroposophical movement has a direct interest or involvement in the growth of Waldorf teaching methods in the public schools. It has come forth denying PLANS' claim that Anthroposophy is a religion, and PLANS' allegation that Waldorf methods public schools serve to promote Anthroposophy. These were two claims PLANS made in its May 28, 2004, "Motion for Summary Judgement". Though not a direct party to the case, the ASA petitioned the court's permission to respond to this trial motion as a "friend of the court". The court granted ASA's petition, and in July 2004, the organization submitted an 18 page legal brief to the court challenging PLANS' assertions. In his subsequent ruling, the judge acknowledged arguments put forth in the ASA's brief, stating, " have set forth considerable evidence that Anthroposophy is a 'philosophy', not a 'religion'", and PLANS' motion was denied.

Argumentation by Waldorf methods charter schools and PLANS

Advocates of public Waldorf education claim that Waldorf methods (charter) schools should be able to enjoy public funding. PLANS claims that although officials often state that a public "Waldorf methods" program has been structured so as not to violate the U.S. Constitution, these schools nevertheless have religious underpinnings. Private Waldorf schools have religious festivals and observe religious holidays, for instance. In public Waldorf methods schools, these activities, which potentially violate church/state separation, are not always avoided and are sometimes simply renamed ("Michaelmas," a key anthroposophic festival, becomes a "Dragon Festival" , for instance). PLANS claims that morning verses recited in the public school in which children thank the sun for its warmth are actually prayers, claiming that the sun is a metaphor Steiner used to refer to Christ. . In public Waldorf methods schools in the U.S., "God" has been removed from the verse and replaced with "the Sun" to avoid violation of the U.S. Constitution. Critics claim this is a cosmetic and not a substantive change.

PLANS also claims that not only private, but also public, Waldorf methods schools are anthroposophical institutions. According to PLANS, public Waldorf teachers are required in most cases to take Waldorf teacher training and to read works almost exclusively by Rudolf Steiner, the founder of both Waldorf education and Anthroposophy, in which tenets of Anthroposophy are discussed in detail and are the focus of the Waldorf teacher training.

The two Waldorf methods public schools PLANS brought to court presented numerous witnesses and introduced documents which contradicted this claim. The judge ruled that PLANS could not introduce evidence taken in the context of the private and independent Waldorf schools to argue their case against the public Waldorf-methods schools. The court agreed with the defendants that private schools are separate entities, and insisted evidence be limited to policies and practices in effect within the litigated public school districts. The two schools furnished statements and documents in this case showing that the teachers in their Waldorf methods schools were held to the same state mandated training and credential requirements as the teachers in other public schools in those districts. In response to a demand to prepare a complete list of all Waldorf-related documents and reading materials related to training or instruction in Waldorf teaching methods, neither school district identified a single text written by Rudolf Steiner. Betty Staley, the Rudolf Steiner College staff member who developed the public teacher training program, testified the college's 1993-1994 Teacher Training Booklists did not apply to the public teacher training program, and that only one of the texts, Steiner's Philosophy of Freedom, was used by the program.

In their trial case, PLANS did not repeat their claim that these or other texts works by Steiner were required in the public Waldorf-methods teacher training. However, they did claim that the schools "provide books for its teachers that are filled with Anthroposophical doctrine", and that teachers were "hire because of their Anthroposophical training." According to Staley's testimony, references to spirituality were eliminated from the public Waldorf teachers’ training materials to meet state standards. One teacher who had participated in this program before adopting Waldorf methods in her teaching in the Oak Ridge, and later John Morse schools, reported that Steiner’s philosophy was alluded to in her training and that teachers who wanted to learn more could pay for their own classes. But she went on to say most of her colleagues from Morse did not pursue any anthroposophical training to become public Waldorf methods teachers.

PLANS claims Anthroposophy has at its basis esoteric Christianity. In court documents, PLANS argued that Rudolf Steiner considered himself a Christian and that he considered Anthroposophy to be a Christian form of theosophy and Rosicrucianism. PLANS argued that Steiner himself described Anthroposophy as a training to access skills of psychic awareness latent in each human being, and argued that the discipline 'spiritual science' is not a true science nor philosophy, but a theology. PLANS acknowledged that Steiner's supporters frequently concede the spiritual foundations of Anthroposophy and Waldorf education, but claimed they make a false distinction between spiritual and religious. It considered Anthroposophy as part of a New Age religious movement, characterized by its seekers' rejection of orthodoxy and creedal forms of religious expression in favor of a more eclectic and individualized path of spiritual-psychological transformation, a process which PLANS claimed to be generally acknowledged as "religious experience".

PLANS wanted the court to agree that Waldorf methods schools lead students through New Age rituals and interpret them as religious practices. It also wanted the court to agree that in the schools, Anthroposophy permeates every subject, and that the underlying theory of the education is based on theology, not philosophy. In order to do this, PLANS first needed to convince the court that Anthroposophy was a religion. This attempt was unsuccessful, and PLANS seeks to reverse the decision in appeals court.

Waldorf educators who also opposed public Waldorf methods education

There are Waldorf education supporters who agree with PLANS' insistence that Waldorf education does not belong in government schools. Waldorf educator Gary Lamb argued in a 1994 article that independence from state control was one of the key tenets in Steiner's original vision for the Waldorf schools. Lamb also argued that if Waldorf methods were applied in the public school system, Anthroposophy and Rudolf Steiner would be attacked in the courts and in the media by fundamentalists and secular humanists applying their own interpretations of Anthroposophy in order to challenge the constitutionality of public Waldorf methods education.

Eugene Schwartz is a prominent teacher and author who started a controversy with a speech he gave in 1999 at Sunbridge College in Spring Valley, New York, where he served as director of Waldorf teacher training. Schwartz stated that he agreed with PLANS founder Dan Dugan, who was also in attendance, that Waldorf education could not properly be separated from Anthroposophy. In Schwartz's view, although Waldorf education is not sectarian, the children are intended to have religious experiences. In his speech he exemplified this with the way the origin and dramatic history of the Jews is taught in grade three in independent Waldorf schools.

Schwartz was fired from the position shortly after the speech, and in a later interview, claimed there were many other Waldorf teachers who agreed with him but were afraid to speak out. He described the importance in Waldorf education to "make everything sacramental", and explained how the Waldorf essentials of "willing, feeling, and thinking" are "soul forces" which are intentionally brought to every aspect of the education. Schwartz objected to those educators who would reject the movement's religious aspect to suit the requirements of public education. In the interview, Schwartz lamented the fact that, in his view, public Waldorf methods schools are watered-down imitations of authentic Waldorf. .

References

1. PLANS' home page
2. Public schools teaching occult religion? Worldnet Daily News October 1999
3. Susan Lauer, "Parents challenge NC charter school", The Union, Feb 27 1996
4. Deposition of James Morton, PLANS, Inc vs Sacramento City Unified School District, Twin Ridges Elementary School District
5. Jeff Forward, "Group says teaching methods are religious", Appeal-Democrat, Marysville, CA, May 15, 1997
6. Defendant's response to Interrogatories, PLANS, Inc vs Sacramento City Unified School District, Twin Ridges Elementary School District
7. "Will Summer Chill Waldorf Protests?", Sacramento Bee, June 11 1997
8. School is teaching witchcraft, critics say Sacramento Bee, May 16, 1997
9. California Aggie (Davis), 22 May 1997
10. Posting June 9, 1997 by Dan Dugan on his antiwaldorf mailing list.
11. "Waldorf Hysteria", Sacramento News and Review, June 12, 1997
12. "Davis Primary School Answers Charges of Racism". Robert Shiu, The California Aggie, May 22, 1997.
13. Debra Snell, "Dr. Morton's death a tragic loss", The Nevada City Union Aug 23, 2003
14. ALLIANCE DEFENSE FUND GRANT REQUEST APPLICATION, dated 18 July 1997, made on behalf of PLANS by Pacific Justice Institute and sent to ADF.
15. Letter dated Aug 4, 1998, addressed to Tina Means, Concerned Parents of Oak Ridge School, signed by PLANS directors D Snell, D Dugan, J Daar, J Morton, D Sabsay.
16. David Ruenzel, "The Spirit of Waldorf Education", Education Week Vol. 20, Iss. 41 (2001)
17. Debra Moon, "From Acorn to Seedling", Chico News and Review, May 30, 2002
18. "Waldorf style school stirs controversy", Marin Independent Journal, Aug 2003
19. Ivan Gale, "Lagunitas approves Waldorf school", Point Reyes Light, Mar 25 2004
20. "Educators Spurn Witchcraft, Cult Allegations by Critics", Sacramento Bee, May 11, 1997
21. Editorial: The attack on Oak Ridge Sacramento Bee, June 10, 1997
22. "Will Summer Chill Waldorf Protests?", Sacramento Bee, June 11, 1997
23. Reporter's Transcript, PLANS, Inc. vs Sacramento City Unified School District, Twin Ridges Elementary School District, Apr 11, 2001 Document #95
24. "From acorn to seedling", CN&R, May 30, 2002
25. "What were they thinking?", Chico News & Review, Dec 27, 2001
26. "Amicus Curiae Brief of the Anthroposophical Society in America for the Defendants", PLANS, Inc., v Sacramento City Unified School District, Twin Ridges Elementary School District, July 13, 2004 Document #187
27. Memorandum and Order, PLANS, Inc. v. Sacramento City Unified School District, Twin Ridges Elementary School District, Nov 30, 2004, Document #195
28. Note the "Dragon Festival" on September 29th (Michaelmas)
29. Schooling the Imagination Sacramento News and Review, February 03, 2005
30. Teacher Training Reading List
31. "Deposition of Betty Staley", PLANS, Inc v Sacramento City Unified School District, Twin Ridges Elementary School District, d Apr 23 1999
32. "Second Supplemental Answer to Special Interrogatories", PLANS, Inc v Sacramento City Unified School District, Twin Ridges Elementary School District, Apr 2004.
33. Schooled in spirituality Article in Sacramento News and Reviews by Chrisanne Beckner, February 03, 2005
34. Plaintiff's "Answer to Special Interrogatories", pages 3 and 4, (Jan 15, 2004)
35. Gary Lamb, "Public Waldorf Schools: Cultural Advance or Cultural Suicide?", Renewal Magazine, Vol. 3, No. 2 (1994).
36. David Ruenzel, "The Spirit of Waldorf Education", Education Week Vol. 20, Iss. 41 (2001)

External links

• PLANS web site
• Schooled in spirituality Article about Waldorf methods schools and PLANS litigation, Sacramento News and Review, February 03, 2005.

• Alternative education
• United States district court cases
• United States education case law
• United States First Amendment case law
• United States church-state separation case law