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Court Rejects Constitutional Challenge to Critical Teaching About Islamic Terrorism
The case was filed against the Maricopa County Community College District, over Prof. Nicholas Damask's World Politics class.
I think this is generally quite right, and indeed an important victory for academic freedom; professors, including those at public colleges, have to be able to speak freely about religious belief systems (whether Islam, Christianity, Judaism, Hinduism, Buddhism, or anything else), no less than other belief systems.
From Sabra v. Maricopa County Comm. College Dist., decided this morning by Judge Susan M. Brnovich (D. Ariz.):
Arising out of an Islamic Terrorism module in an online World Politics course taught by Dr. Nicholas Damask, this case tests the limits of the First Amendment's Religion Clauses. Mohamed Sabra enrolled in this spring semester course at Scottsdale Community College ("SCC") in 2020. Its syllabus describes it as one that will provide an "[i]ntroduction to the principles and issues relating to the study of international relations. Evaluation of the political, economic, national, and transnational rationale for international interactions."
The course is organized into six modules, each containing multiple components to explore various topics concerning world politics. The Islamic Terrorism module challenged by Mr. Sabra and the Council on American-Islamic Relations of Arizona … had three components: a PowerPoint presentation, excerpts from Future Jihad, and a quiz. The PowerPoint presentation explored world politics through three sub-topics: (1) "Defining Terrorism"; (2) "Islamic Terrorism: Definition"; and (3) "Islamic Terrorism: Analysis." The second component required students to read excerpts from Future Jihad, a book published by Walid Phares, and the quiz evaluated students on their comprehension of course material with twenty-five multiple choice questions.
Plaintiffs take issue with Dr. Damask's instruction throughout these various Islamic Terrorism module components, alleging that his teachings violate the Establishment Clause and Free Exercise Clause …. Plaintiffs allege his instruction unconstitutionally "conclude[es] that Islam 'mandates' terrorism and the killing of Non-Muslims, and that this is the only interpretation of religious texts, but without any disclaimer to inform students that this is one-perspective and that Islam itself does not condone terrorism." They further allege that Dr. Damask "is not teaching that only some extremists espouse these beliefs, but rather that literally, Islam itself teaches the mandates of terrorism."
And "[t]he only objectively reasonable construction of [Dr.] Damask's actions," Plaintiffs allege, "is that his primary message is the disapproval of Islam." As it specifically concerns the quiz, Plaintiffs allege "[it] forced [Mr.] Sabra to agree to [Dr. Damask's] radical interpretation of Islam." And when Mr. Sabra refused to answer questions in accordance with what he learned in the course, his answers were marked wrong, and his course grade was negatively impacted….
The court rejected Sabra's Establishment Clause challenge (applying the "endorsement" test set forth by Ninth Circuit precedent, though the Supreme Court seems to have retreated from that test in American Legion v. American Humanist Ass'n):
"The Religion Clauses of the First Amendment provide that 'Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.'" This includes not only government approval of religion, but its disapproval of or hostility toward religion [citing Ninth Circuit cases].
Courts are directed to apply the "Lemon test" in cases challenging government conduct under the Establishment Clause. Government action regarding religion only satisfies the Establishment Clause if it (1) has a secular purpose; (2) does not have the principle or primary effect of advancing or inhibiting religion; and (3) does not foster excessive entanglement with religion. Lemon v. Kurtzman (1971).
Plaintiffs argue that the challenged module fails under the second prong of the Lemon test. "Under the second prong of the Lemon test, [the Court] must consider whether the government action has the principal or primary effect of advancing or inhibiting religion." When making this determination, courts decide whether it would be "objectively reasonable for the government action to be construed as sending primarily a message of either endorsement or disapproval of religion." The analysis is whether the government action "'primarily' disapproves" of religious beliefs notwithstanding the fact that one may infer possible government disapproval of religious beliefs.
Under this objective standard, even where the government practice reflects "some disapproval" of religion, this alone is not enough to run afoul of the Establishment Clause. "Courts have long emphasized the importance of academic freedom in deciding the appropriate curriculum for the classroom."
Examining the course as a whole, a reasonable, objective observer would conclude that the teaching's primary purpose was not the inhibition of religion. The offending component was only a part of one-sixth of the course and taught in the context of explaining terrorism. One aspect of terrorism is Islamic terrorism. Only in picking select quotes from the course can one describe the module as anti-Islam. Dr. Damask also quotes Peter Bergen for the view that the terrorist threat comes from radical terror groups that represent a "twisted" variant of Islam as a whole.
{Further, as Plaintiff's counsel misstated in oral argument, Question 19 of Dr. Damask's quiz on terrorism states: "Walid Phares notes that although 'gullible' Westerners are taught that jihad can have two meanings, people in the Arabic world understand that its overwhelmingly obvious meaning is ___." This question merely asks students to identify the opinion of Walid Phares regarding Islam, not to adopt his position on Islam.} Thus, the Court finds that the primary effect of Dr. Damask's course is not the inhibition of the practice of Islam….
And the Court rejected Sabra's Free Exercise Clause challenge:
"The Free Exercise Clause, which applies to the States under the Fourteenth Amendment, 'protects religious observers against unequal treatment' and against 'laws that impose special disabilities on the basis of religious status.'" … Curriculum that merely conflicts with a student's religious beliefs does not violate the Free Exercise Clause. Parker v. Hurley (1st Cir. 2008) (requirement that public school students to read a book featuring gay couples did not violate constitutional rights of Christian parents or children); California Parents for Equalization of Educ. Materials v. Torlakson (N.D. Cal. 2017) (ruling that requiring students to learn class material that the plaintiffs viewed as "derogatory towards Hinduism" did not violate the Free Exercise Clause)….
Here, Mr. Sabra alleges that he was forced to choose between denouncing his religion by selecting the "correct" answer or receiving a lower grade. That is simply not correct. As Defendants point out, Mr. Sabra was not required to adopt the views expressed by Dr. Damask or the authors Dr. Damask cited to in his course, but only to demonstrate an understanding of the material taught. Dr. Damask's course did not inhibit Mr. Sabra's personal worship in any way. Instead, Mr. Sabra was simply exposed to "attitudes and outlooks at odds" with his own religious perspective. Therefore, as a matter of law, the Court finds that the Plaintiff's allegations do not amount to a violation of the Free Exercise Clause ….
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So teaching that all Muslims are terrorists or bad Muslims might be an issue.
But teaching a book that says all Muslims are terrorists is OK because you're not teaching it as fact?
I do like the return of Lemon. Reading it in high school is what got me interested in the law.
Sorry, I should have put 'exclusively' in that second sentence.
I concur that as a whole, this course looks fine. But want to see what the boundaries are.
I'm not sure why any of this should be an establishment clause issue in the first place. Teaching about religion is not the same thing as teaching religion, and at any event, even the "teaching religion" caselaw is really about grade and high schools, where you can argue there's significantly more of a coercive effect. This is an elective course at a college.
A college professor has the right to trash Islam. A college professor also has the right to teach that Islam is great. Either way, I don't see a constitutional problem.
I don’t think that a school comurriculum has any business demanding regurgitation on “Christianity says,” “Judaism says, “Islam says,” etc. They have accept “Professor x says in his book that Islam says” as a valid answer for full credit. They can’t demand that the student word the regurgitation to say that Professor X’s opinion is true.
The difference between demanding the student say “Islam says” and accepting “Professor X says Islam says” as a valid answer may seem subtle, but it’s important. Requiring the first and not accepting the second violates the First Amendment. Accepting the second permits a public educational institution to teach about religion consistent with the First Amendment. And it gives the educational needs of the institution everything they can legitimately ask for.
At least so far as this student’s complaint is concerned, at any rate.
Okay but an education that ends up teaching some say X and some say not-X, what good is that?
Yes, I agree that I would write “Professor X says Islam says” but education is so bad that most students can't distinguish the two.
Look at the 'adults' on here bitching about the 10 Commandments. IF someone takes them in a 'religious way' (whatever that means) they treat them as if they never existed even as a secular document.
i agree with you as a teacher. But our current educational system is so poor most students (even the smarter ones) would not even see that as an option. I teach Philosophy majors and on the most vexed questions they do the same thing.
I don't see why its a religion clause issue rather than a free speech issue, which would also be a loser, but would be a better losing theory.
Because you don't go to school to exercise your free speech rights but you do to learn about the pillars of civilization , the chief being religion. What I don't get is that for everything in the universe there is good and bad but talk of religion and for some it is all bad , itself a religious view !!!!
Am I interpreting your edit correctly to mean "But teaching exclusively from a single book that says..."?
While that would certainly be closer to the line, I don't think even that crosses it since this was an elective with a defined scope. Presumably, the school offers other electives with different scopes of study. You are not, for example, endorsing Marxism if you teach a semester long course solely about Marx while simultaneously offering a parallel course solely about Adam Smith. There is an academic obligation to balance but there is no obligation to require the balance within each day's lecture or even within each semester's course.
Indeed - that's the hypothetical.
I see what may be a bit of slight of hand between professor and institution, but I think I dig what you're laying down.
I took a semester long course on Marx. Marxism in practice is an evil thing. Looking at Marx as a economic theorist and philosopher was interesting and helped me understand why it was so.
Every ancient text my students read (they are Philosophy majors) has blatant errors but they do ask the right questions. If we knew ahead of time the truth by which we would measure everything in school why would we even go to school!!!!
You speak with no firsthand knowledge and no skin in the game. Many Muslims say your basis itself is false and demonatrably so
Take Aayan Hirsi Ali
“My observation is yes, Christianity is different from Islam…The worst thing that a Christian has ever said to me, the rudest thing that a Christian has ever said to me, the thing that made me most uncomfortable that a Christian said to me was ‘I’m going to pray for you. I hope you will be safe. I hope you will be redeemed.’ But within my own family and my own community, when I say I’m in doubt about the Koran and Muhammad and life after death and all that, it is ‘well, you are to die.’
=====Now you overlook the fatwa placed on Trump. Why is that?
Are you yourself Muslim? You will surely reply that that is not all Muslims but that point is logically against you. No, Islam does not have a Pope so even if X% of Muslims thing the Fatwa is anti-God, immoral, whatever it makes NO DIFFERENCE
The other aspect is student academic freedom -- exam questions in particular.
1915 AAUP statement
"...remember that his business is not to provide his students with ready-made conclusions, but to train them to think for themselves, and to provide them access to those materials which they need if they are to think intelligently."
I would start with Muslim rejection of almost every Human Rights document of the 20th Century.Complete rejection of Freedom of Religion, the core value of the American Founding.
Bigots have rights, too.
And AK has the right to be stupid. He practices that every time he posts here.
But not QUA bigot, so logic fail there.
As the Reynolds court case held :
This would be introducing a new element into criminal law. Laws are made for the government of actions, and while they cannot interfere with mere religious belief and opinions, they may with practices.
Suppose one believed that human sacrifices were a necessary part of religious worship, would it be seriously contended that the civil government under which he lived could not interfere to prevent a sacrifice? Or if a wife religiously believed it was her duty to burn herself upon the funeral pile of her dead husband, would it be beyond the power of the civil government to prevent her carrying her belief into practice?
SO YOU ARE as we say in class 'EXACTLY WRONG " 🙂
Judge Brnovich was appointed by President Trump.
Well done both.
I don’t see why the fact that the parts of concern were only a small part of the course has anything to do with it. According to the complaint, the course required him to make statements about his religion that contradicted his religious beliefs and graded him wrong if he didn’t.
What distinguishes this from the Pledge Case? There, the pledge was also only small part of the curriculum, the entire course taken as a whole dodn’t teach loyalty as such. What permitted the plaintiff in that case to take the pledge out of context and focus on it, but not this plaintiff?
To clarify, the issue is not at all what the professor said. It’s what the professor demanded that the STUDENT say. That’s what raises the constitutional problem and makes this case like the Pledge case.
If the professor had accepted “Professor X says that Islam says” as a valid answer rather than demanding the student say “Islam says,” there would have been no problem.
But, as I read the above, he DID accept that:
"Here, Mr. Sabra alleges that he was forced to choose between denouncing his religion by selecting the "correct" answer or receiving a lower grade. That is simply not correct. As Defendants point out, Mr. Sabra was not required to adopt the views expressed by Dr. Damask or the authors Dr. Damask cited to in his course, but only to demonstrate an understanding of the material taught. "
You seem to be taking the plaintif's complaint as true, but the court found it to be wrong.
Did you read the article? The complaint did allege that the plaintiff was required to make a personal statement of belief. The court determined that allegation to be untrue. The quiz question did not require the student to say anything about his religion or even to say what the professor said. The question required the student to correctly say what a named author in the course's required reading said. By your own logic, there was no problem.
Either a sane educated person would admit that Islam kills people in the name of God or it does not. This (your opinion) reminds me of the Burqa ruling in France, that something involves Religion does not ipso facto make it a Freedom of Religion case
I think a class would have to go pretty far in order for it to violate the establishment clause especially at a university.
What would be more of an interesting question though is what if one of these classes, which might cast a religion in a hostile light, violates non-discrimination obligations? That would make an interesting intersection between the bounds of non-discrimination law, academic freedom, and free speech. I think it would take a lot of get there but would be interested in hearing someone speculate on a set of facts where a court might conclude such a course violates non-discrimination laws and is not protected by academic freedom or free speech.
I'm surprised the course was permitted to be taught.
Religion is ANY statement about ultimates so to cast all religion in a negative light is to have a religious opinion. A little logic would cure such a stupid teacher.
IF you say "reason shows that religious statement to be wrong" and you don't produce the reason then you arguing from Faith against Faith.
This is the most honest statement I've found from a major atheist on this point
"“In speaking of the fear of religion, I don’t mean to refer to the entirely reasonable hostility toward certain established religions and religious institutions, in virtue of their objectionable moral doctrines, social policies, and political influence. Nor am I referring to the association of many religious beliefs with superstition and the acceptance of evident empirical falsehoods. I am talking about something much deeper–namely, the fear of religion itself. I speak from experience, being strongly subject to this fear myself: I want atheism to be true and am made uneasy by the fact that some of the most intelligent and well-informed people I know are religious believers.
I want atheism to be true and am made uneasy by the fact that some of the most intelligent and well-informed people I know are religious believers. It isn’t just that I don’t believe in God and, naturally, hope that I’m right in my belief. It’s that I hope there is no God! I don’t want there to be a God; I don’t want the universe to be like that.”(”The Last Word” by Thomas Nagel, Oxford University Press: 1997)”
― Thomas Nagel"
In America adults are free to choose whichever religion they want to...the fact so few progressives choose to convert to Islam tells you it is an inferior religion.
Which flavor of adult-onset superstition is superior, in your judgment?
Do you always have to be a jerk?
Dude he's replying to is going on about Islam being an inferior religion.
Bigotry like that deserves RAK.
All religions are stupid...Islam is extremely stupid. So Obama had the choice to convert to Islam but he chose Christianity...because Islam is so dumb.
So it is OK to be a jerk if you are being a jerk for the right reasons? Got it.
Is that the way it works when it is OK to call Trump fat and stupid, but if you say anything about Harris you get cancelled?
Jimmy, somehow I don't believe you think infinite patience and civility is always the rout that'll get things done.
Have you converted to Islam yet?? If you are still an infidel then you are making a very clear statement—Islam is a stupid religion.
I believe reasonable people can differ in their faith without passing judgement on one another.
Nope, by not converting to Islam you are clearly stating that Islam is a phony religion. In America adults are free to belong to any religion or no religion...I choose no religion because I think they are all phony. So convert to Islam or the message is clear—Islam is a phony religion just like Scientology or Hinduism.
Forgive me if I don't take your understanding of the tenets of Islam as gospel.
It has nothing to do with Islam—as an American adult you are free to choose your religion. So you could tell your mother you are a Christian but secretly practice Islam if you thought Islam was the way to get to paradise.
Which superstition-laced fairy tales are not phony, Sebastian? Christian? Catholic? Jewish? Baptist? Calvinist? Mormon?
Is there more than one?
Here's a head start on your research, Sebastian.
Progressives were the ones that celebrated Tlaib and Omar being elected to the House...literally the only two Muslims in the world that support gay marriage, support abortion, watch RuPaul, and believe Allah is a woman. Oh, and they support Palestine over Israel even though Palestinians oppose gay marriage and force women to have rape babies.
Could be wrong, but I believe in the eyes of Muslims, one does not "convert" to Islam, they "revert" to Islam.
Because it is the one true religion. Celebrating diversity of religion is probably the dumbest thing ever. Tolerance is great...celebration is dumb.
Well, to be fair most religions teach that adherents of the others will spend eternity in hell. That kinda sorta sounds worse than saying their version is "inferior."
And I'd say anyone coming in here and saying I'm going to Hell for not being his flavor of Baptist or whatever was being a bigot as well.
That may be fine in church, but taking that talk to the streets has never been a great thing in our pluralistic country.
Or that progressivism is a religion 🙂
Sounds like that case a while back where some overly-concerned dad was outraged his daughter was learning about Islam in school and tried to sue.
To about the same success, if I recall.
It seems that the distinction between religious instruction and instruction about religion is one that people of all religions struggle with.
NO, it's an educational-cum-religous argument and very valid. You must in certain subjects have a firm coherent answer before you examine other answers OR you end up denigrating the very quesiton itself.
Tell a 6-year old to 'pick a religion" and he hears it as 'religion is totally unimportant like whether I want chocolate or strawberry ice cream for dessert OR NEITHER"
I am a teacher, your view destroys the idea of truth and morality at its root
Is the Lemon test really what we want to use? The third point, does not promote 'excessive entanglement' with religion is terribly subjective. How does that work in practice? Where is the line for 'a lot of entanglement' versus 'excessive entanglement'?
The only moral judge is the parent QED
I'm not sure I agree with footnote 4 in the opinion, where the court states that "Question 19 of Dr. Damask's quiz ... merely asks students to identify the opinion of" author Walid Phares. First of all, the verb used, "to note" ("Walid Phares notes ...") is an unusual way of introducing a statement of opinion. One does not ordinarily "note" one's own opinions; one might "say" or "express" or "assert" an opinion, but one "notes" the facts that support the opinion. The only word in Dr. Damask's question which is unambiguously the opinion of Walid Phares is the word "gullible"; the remainder of the sentence appears to be a recitation of the assertions of fact that Phares cites in support of his opinion, and that's the part that students are expected to fill in. Of course it doesn't help if the plaintiff's counsel misstated the phrasing of the question, as the court says. But it would also be more helpful if the court had taken just a moment longer to explain how counsel misstated it. Sure, they may not have helped their client's cause by racing past the part that sounds like opinion to get to the part they saw as objectionable; but if the problematic portion, the blank students are asked to fill in, is truly problematic (and I think reasonable people could go either way), it's problematic regardless of the fact that it's framed as merely reciting an author's opinion rather than reciting matters the author claims to be facts. How counsel read the question at oral argument would only make a difference if it looked like they were trying to mislead the court or conceal the evidence. And the court doesn't say that.
Seems similar to most organized superstition -- helps some people, hurts others, promotes some good, causes some harm . . . roughly a wash, in general, from a charitable perspective.
The "wash" I described involved the entirety of religion, not any particular flavor of religion or any comparison among religions.
With respect to your assertion concerning the historical magnitude of Islam-relating killing, I would wish to see reliable assessments of the casualties of other superstition-based atrocities (the Crusades, for example) before acknowledging that Islam should wear that particular crown.
Assuming that Islam has killed more people than any other religion, that's probably a function of which religion came along at which time and place. I don't think there's any doubt that if the Medici popes had had the technological ability to hijack airliners and fly them into skyscrapers, they'd have had no hesitation in doing so. Don't forget that many thousands of people lost their lives to settle the question that the Holy Spirit proceeds from both the Father and the Son.
I would agree that at this particular time and place in history, Islam is more dangerous than any other religion, but that's at this time and place. The Aztecs, the Incas, and the pagans of Northern Europe would all, I'm sure, have a different perspective. And if it ever has a Renaissance, it may actually become a religion of peace.
"Islamic jihad has killed more people than any other religion" -- more than the Crusades?
"Mike Konrad" and the American Thinker?
Your 'American thinking' is the reason conservatives are casualties of the culture war, vanquished by better Americans.
I read enough to see the second reference to Daniel Pipes, which was plenty to rebut your "properly sourced" description.
American society rejects your bigotry, mad_kalak. I'm with American society.
I didn’t say the Aztecs were nice people, but then a lot of the people Islam has killed over the years were bad people too. I wasn’t aware that genocide was excusable if the people you’re killing are bad people.
The point is, though, that as Islam and Christianity claimed land by conquest, they both offered the same choices: convert, be killed, or leave. There isn’t a dimes worth of difference between what the Muslims did in Arabia and what the Christians did in South America. And even if you’re right that Islam has a higher body count, by that standard Charles Manson is a better person than Ted Bundy.
One last thing: as to communistic atheism, you do realize that a Russia run by libertarian atheists would have looked a whole lot different, right? So atheism has nothing to do with it. The relevant factor is that Stalin was a communist, not that he was an atheist.
The stupid rev in many many posts makes the lazy assertion 'seems' Too stupid and lazy to have a settled opinion at his age.
"The darkest places in hell are reserved for those who maintain their neutrality in times of moral crisis"
Watch , he'll say "but I don't believe in Hell because it seems...."
Again, only people kill and to take a killer who professes a religion and say he is an honest non-lying killer makes no sense. Many take religion as the cover
"there is only one thing that bears a heavier responsibility than religion as a principal cause of war. And that is, of course, irreligion."
"Since culture and greed often clothe themselves in religion, wars fought for culture often appear to be fought for religion. With keen analysis of global history and current events, Pearse shows how irreligion has produced far bloodier wars than religion, and how global secularism itself does violence to religion and traditional cultures. Ultimately, throughout history warfare has been waged over the shape of society itself. "
Your stellar ignorance of history provokes astonishment.
Even Voltaire , as anti-Church as the Devil, said of the Church in South America
He praised the Jesuit Reductions as a "triumph of humanity" later out of hatred for the Jesuits he had them suppressed
But what really makes you look the bigoted fool is Aayan Hirsi Ali's famous quote about fools who argue moral equivalence as you always do
'“My observation is yes, Christianity is different from Islam…The worst thing that a Christian has ever said to me, the rudest thing that a Christian has ever said to me, the thing that made me most uncomfortable that a Christian said to me was ‘I’m going to pray for you. I hope you will be safe. I hope you will be redeemed.’ But within my own family and my own community, when I say I’m in doubt about the Koran and Muhammad and life after death and all that, it is ‘well, you are to die.’"
let's put that stupid comment to the test
Here is a 4 -minute clip from 14 years ago where former Muslim and current Atheist Aayan Hirsi Ali was asked a question exactly like yours and she eviscerated the fool
https://www.youtube.com/watch?v=Z3QaLugRjMg
THIS MADE A HUGE EFFECT ON ME obviously but after 14 years she has been proved absolutely right and you , proved absolutely wrong. I treasure the wisdom of the reply
One last reply to this Guinness Book illiterate.
Stalin's own daughter rebuts everything you said. She became a Christian , had to do so secretly for fear her father would kill her for it, and she says he was a an anti-God beast LOOK IT UP
Ilya , do you realize you are saying that evil should not be resisted !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
This is from a non-catholic historian, okay
as British historian Derek Lomax (1933-1992) explained, 'The popes, like most Christians, believed war against the Muslims to be justified partly because the latter had usurped by force lands which once belonged to Christians and partly because they abused the Christians over whom they ruled and such Christian lands as they could raid for slaves, plunder and the joys of destruction.' It was time to strike back.”
― Rodney Stark, God's Battalions: The Case for the Crusades
IN WHAT CAME TO BE KNOWN as his farewell address, Muhammad is said to have told his followers: “I was ordered to fight all men until they say ‘There is no god but Allah.’”1 This is entirely consistent with the Qur’an (9:5) : “[S]lay the idolaters wherever ye find them, and take them [captive], and besiege them, and prepare for them each ambush.” In this spirit, Muhammad’s heirs set out to conquer the world.”
― Rodney Stark, God's Battalions: The Case for the Crusades
“Stark reviews the history of the seven major Crusades from 1095 to 1291, demonstrating that the Crusades were precipitated by Islamic provocations, centuries of bloody attempts to colonize the West, and sudden attacks on Christian pilgrims and holy places.
' I have written at length several times about the many centuries (beginning in about 500 CE) of peaceful relations between Christians and Jews in Europe and the Church’s lack of concern about heresy during this same era. Both ended at the start of the Crusades, and I argue that the outbreak of anti-Semitism and heresy-hunting were a fallout of the conflict with Islam which magnified concerns about religious nonconformity on both sides! There were similar outbursts of attacks on Jews within Muslim societies. See my: One True God (2001)."
This will be the first time in my memory that you were with 'American society"