graphic image depicting green amicus briefs for Atlantic Legal Foundation Amicus Brief Summary

Yoga For Exercise Is Not Religious

This case concerns a challenge by parents of students in the Encinitas Union School District (EUSD) to a yoga-based health and wellness program which was initiated with funding provided by a private philanthropic foundation the Jois Foundation which has a mission to establish and teach “Ashtanga yoga” and an interest in encouraging the use of yoga. The objective of the school district’s yoga-based physical education program was to improve focus, discipline, and behavior, as well as physical fitness, of students.

Stephen and Jennifer Sedlock, Christian parents of two children who attended El Camino Creek Elementary School, initiated this action against the EUSD Superintendent, Timothy Baird, and Board of Trustees of the District, seeking a writ of mandate prohibiting the continuation of the yoga. Petitioners alleged that the teaching of yoga in the District schools violated various provisions of the California Constitution concerning religion (article I, §4; article IX, §8; and article XVI, §5), and that the District was not providing 200 minutes of physical education as required by Education Code section 51210, subdivision (g). Petitioners also brought an action for injunctive and declaratory relief under sections 525-26, and 1060 of the Code of Civil Procedure to stop the District from using state resources to endorse Ashtanga yoga, alleging that the practice unlawfully promotes religious belief while discriminating against other religions.

The trial court determined that “yoga and Ashtanga yoga have religious roots” and that “yoga is religious,” but also concluded that “‘EUSD yoga’ [is] completely devoid of any religious, mystical, or spiritual trappings.”


Issue Areas:

Effective Education, Individual Liberty

Read the Amicus Brief:
Question(s) Presented:

Whether yoga, as taught as part of a wider physical education curriculum in the Encinitas Union School District (EUSD) schools, can be considered “religious.”

ALF’s Amicus Brief:

In an amicus brief ALF argues that the yoga included in the EUSD physical education program cannot be reasonably seen as religious and therefore there was no need for the Superior Court to engage in a discussion of the Establishment Clause or First Amendment. The Petitioner’s whole case was built around an expert whose testimony asserted that yoga was part of a “sinister mind-control conspiracy,” to convert young children to Hinduism. This bizarre argument completely ignores the secular exercise purposes for which non-hindus practice yoga while being completely unaware of it being originally tied to a religion. Further this expert ignores that a form of yoga has developed in the United States that is completely focused on exercise. Because of this critical context, the ALF asks this Court to affirm the judgement below on the basis of a threshold finding that yoga as taught in EUSD schools is “completely devoid of any religious or spiritual trappings.”


On April 3, 2015 the California Court of Appeal Fourth Appellate District issued a favorable opinion and affirmed the Superior Court’s decision.

Date Originally Posted: October 16, 2014

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