Hostility Toward Religion Up 15 Percent Since 2015, Undeniable Survey Reveals

First Liberty Institute documents religious hostility in America every year.

First Liberty Institute client Alexia Palma of Houston, Texas. Palma was fired from her job as a health educator after she asked to be exempt from teaching a class on contraception and her request was denied.

By Liberty McArtor Published on September 14, 2017

Hostility toward religious freedom rose 15 percent in 2016, according to a new report. On Tuesday First Liberty Institute released Undeniable: The Survey of Hostility to Religion in America. The non-profit legal group has released Undeniable every year since 2012. Based in Texas, First Liberty focuses exclusively on religious freedom. The report documents all recorded instances of hostility to religion every year. 

First Liberty president Kelly Shackelford and deputy general counsel Jeremy Dys spoke with reporters via teleconference Tuesday. Justin Butterfield, senior counsel and Editor-in-Chief of Undeniable also joined.

Since 2012, there’s been a 133 percent increase in instances of hostility, they said. Undeniable now includes 1,400 recorded anecdotes of religious discrimination in the U.S. 

“We’re really in the middle of a battle,” Shackelford said. But despite the uptick in recorded discrimination, “things have been going in the right direction” for the past few decades. This year saw the Trinity Lutheran victory for religious freedom at the Supreme Court. The Hobby Lobby case of 2014 was another victory. In 2012 the SCOTUS sided with a veterans memorial with religious imagery. But the victories came by a slim margin. Many decisions, including victories at lower court levels, were split 5-4. 

It’s hard to tell which way it will go for religious freedom in the U.S., Shackelford said. For now, they’re focused on raising awareness and defending those who have faced discrimination for their faith.

Catholic Beliefs a Problem at Work

One client is Alexia Palma. The Houston, Texas resident joined the call Tuesday. 

Not long ago, Palma taught health classes at a Houston clinic. One of her classes was on contraception. A devout Catholic, Palma believes contraception is wrong. She asked her employers if she could show a video during that class instead of teach the information. For a year and a half, they were fine with her request. Then new management came along.

“They told me that I needed to put my religious beliefs aside if I wanted to continue being a health educator there.”

“They told me that I needed to put my religious beliefs aside if I wanted to continue being a health educator there,” she said Tuesday. 

Palma said she was shocked and devastated. “I really loved my job and my patients.” She claims that class constituted just two percent of her job duties. But when she refused to teach it, the clinic fired her. 

After litigation led by First Liberty, Palma said she reached a “friendly settlement” with the clinic. 

Synagogue Faces Zoning Discrimination

Butterfield spoke about another client of First Liberty’s, Congregation Toras Chaim.

The small Orthodox Jewish synagogue is located in Dallas, Texas. For the members, driving on the Sabbath is prohibited. So they have to meet within walking distance of their homes: the rabbi’s house. 

But one neighbor didn’t like the meetings. He sued the synagogue. As it turns out, the religious services violated the neighborhood’s HOA rules. But that’s a problem, Butterfield said. The congregation has no other option when it comes to nearby locations. 

First Liberty fought the neighbor’s lawsuit and won. But victory was short-lived; the city of Dallas soon sued the small congregation. That lawsuit is still ongoing. 

If Toras Chaim loses, its members will have to move to a different community, Butterfield said. 

Dys added that unfair zoning laws are “a big problem” for houses of worship. Undeniable contains several other zoning stories, he said. 

A “Pervasive” Issue

The idea for Undeniable came in the early 2000s, Shackelford said. At the time, Sens. Ted Kennedy (D-Mass.) and John Cornyn (R-Texas) were on a Constitution subcommittee. Around 2004, they listened to testimonies of religious hostility in the U.S. Testimonies included several of First Liberty’s clients. Afterward the senators asked if the testimonies represented more than a few isolated incidents. 

“Even we were shocked by how pervasive the issue was.”

To answer their question, the lawyers at First Liberty began serious research. What did they find? Evidence that hostility to religion in the U.S. was widespread. “It wasn’t one area of the country. It wasn’t one age group, one walk of life, one situation,” Shackelford said. “Even we were shocked by how pervasive the issue was.” A few years later, First Liberty decided to produce annual surveys to track the problem.

To compile the survey, the First Liberty team scours news articles, legal filings and other records. They summarize each incident in a few sentences. Each summary includes links or case references so people can find more information, Butterfield said. 

Undeniable is a free resource that the non-profit disseminates as widely as possible. On Tuesday the president, vice president and every member of Congress received copies, Dys said. Stream readers can request free digital and hard copies of Undeniable here.


Disclaimer: Liberty McArtor is a former employee of First Liberty Institute. Today, she occasionally writes for the organization.

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  • Religious faith a personal, subjective matter. Hostility arises when people of one particular faith insist that their religious doctrines should be a part of public policy.

    • Shaquille Harvey

      The same could be said of those of non religious strand and those who wish to push thier sexuality constantly.

    • Charles Burge

      Nope. That’s just flat-out wrong. All of our nation’s founders understood that religious ideas have a place in the public square, and they crafted our constitution and other laws with that in mind. Religious people get to participate in society, and reasonable accommodations need to made for them. The Supreme Court has consistently upheld this idea, such as in the recent 7-2 decision in favor of Trinity Lutheran Church in Missouri.

    • cestusdei

      Yes, just like your personal subjective beliefs should not be imposed on the rest of us. But Leftists insist on forcing others to agree, or else.

    • GPS Daddy

      Oh, my, isn’t this the pot calling the kettle back…

  • tether

    This nation’s founding was the result of such persecutions and more in other countries. This nation was established with the intent that we are all free to worship God as we choose.
    If a town, city, county, state etc. is going to ban people from gathering in someone’s home to spend time with or learn about God then they better make sure these laws are consistent. If group a can not gather to enjoy their religious activities then group b can not be allowed to have a Halloween gathering in their home, as Halloween is a pagan activity. I am sure if one gives some thought to it we could make arguments for many home gatherings that would be subject to the same scrutiny.

  • Bob Adome

    If the world hates you, understand that it hated Me before it hated you. The harder they press, the more it is proved out.

  • Jones Howell

    One survey said that a third of millennials have quit the church because they church won’t sanction “LGBTQ.”

    • James

      That 80% of Evangelicals and 60% of white Catholics voted for Trump will probably cause these numbers to accelerate.

      Church is one of the few places where you still can find open racism, sexism, and anti-gay attitudes. Not that Churches necessarily preach these things, but they are common in the pews and socially acceptable. Many millennials see church as something that makes you more narrow minded and judgemental, not something that helps you be a better person.

      • cestusdei

        Did you get enough of the talking points in there James? Leave out any of the usual insults? You seem pretty narrow-minded and judgmental. You are not a better person, in fact your hate, bigotry, and intolerance are very evident. Your ignorance about what we believe and why is stunning. There, did that convince you?

        • James

          Keep whistling past the graveyard.

          This is why so many millennials don’t go to church. Either these are real problems in the church or the church has a serious image problem.

          • cestusdei

            So why don’t they go to the Episcopal church which loves sodomy? Why are they in terminal decline? They do everything you say they should and they are dying. You create graveyards.

          • James

            Clearly, you don’t know many Episcopalians.

            The public face of liberal churches is not necessarily reflective of what happens in the congregation. Also, the Christian left can be quite narrow minded, judgmental, and superstitious themselves. Left-wing politics do not immunize one from bad behavior.

            The big reason, however, that liberal churches are in decline is not because people are leaving them (in Protestantism, about as many people convert from liberal->conservative as conservative->liberal) but because members of liberal churches aren’t having as many children.

            In the United States, liberal Protestant churches are declining rapidly, conservative Protestant churches are declining more slowly. The Catholic Church is collapsing in the Northeast and Midwest, although growth from immigration is hiding the decline. Nobody is growing.

          • cestusdei

            Correct, there are so few left out there. Which proves my point. All mainline churches have followed your blueprint, all are in terminal decline. Even if your assumptions are correct they decline much faster then conservative churches. So why should they opt for suicide by doing what you suggest?

            However, if you look globally you will find that conservative Christianity is growing. Your ethnocentric view prohibits looking at Asia and Africa as part of the mix. There is more to the world then the Leftwing American bubble. The Anglicans in Africa are growing and are conservative. Same with the Catholics. Sodomy is sterile in everything that it touches.

            We started with 11 apostles. Many past dictators have written our obituary. We are still here. You can’t kill us all.

          • James

            American “conservative” and “liberal” dichotomies don’t really apply to Africa and Asia.

            In the West, conservative churches are also sinking. Sinking more slowly is not the same as swimming.

            The reason why they are sinking more slowly than liberal churches is not because people are flocking to it or people are running away from liberal Christianity, but because conservative Christians have more children than liberal Christians.

            Outbreeding the opposition is not a sign that what you are doing is right and good. It it were, we should all convert to Islam.

          • cestusdei

            Okay, use the term orthodox. Either way my point stands.

            Just because a movement grows does not mean that it is right. I remember a movement in German back in the 30’s that grew quickly. Or the one that grew starting in 1917 in Russia and doesn’t exist anymore. Christianity has declined before and then risen again. It is rising in other parts of the world. Your side loves to pretend that you are the future, while we’ve been thru this many times over the last 2000 years. We were born when Tiberius was Emperor, so who is the Emperor today? Oh you mean the Roman empire is gone?

            “There is not, and there never was on this earth, a work of human
            policy so well deserving of examination as the Roman Catholic
            Church. The history of that Church joins together the two great
            ages of human civilisation. No other institution is left standing
            which carries the mind back to the times when the smoke of
            sacrifice rose from the Pantheon, and when camelopards and tigers
            bounded in the Flavian amphitheatre. The proudest royal houses
            are but of yesterday, when compared with the line of the Supreme
            Pontiffs. That line we trace back in an unbroken series, from the
            Pope who crowned Napoleon in the nineteenth century to the Pope
            who crowned Pepin in the eighth; and far beyond the time of Pepin
            the august dynasty extends, till it is lost in the twilight of
            fable. The republic of Venice came next in antiquity. But the
            republic of Venice was modern when compared with the Papacy; and
            the republic of Venice is gone, and the Papacy remains. The
            Papacy remains, not in decay, not a mere antique, but full of
            life and youthful vigour. The Catholic Church is still sending
            forth to the farthest ends of the world missionaries as zealous
            as those who landed in Kent with Augustin, and still confronting
            hostile kings with the same spirit with which she confronted
            Attila. The number of her children is greater than in any former
            age. Her acquisitions in the New World have more than compensated
            for what she has lost in the Old. Her spiritual ascendency
            extends over the vast countries which lie between the plains of
            the Missouri and Cape Horn, countries which a century hence, may
            not improbably contain a population as large as that which now
            inhabits Europe. The members of her communion are certainly not
            fewer than a hundred and fifty millions; and it will be difficult
            to show that all other Christian sects united amount to a hundred
            and twenty millions. Nor do we see any sign which indicates that
            the term of her long dominion is approaching. She saw the
            commencement of all the governments and of all the ecclesiastical
            establishments that now exist in the world; and we feel no
            assurance that she is not destined to see the end of them all.
            She was great and respected before the Saxon had set foot on
            Britain, before the Frank had passed the Rhine, when Grecian
            eloquence still flourished at Antioch, when idols were still
            worshipped in the temple of Mecca. And she may still exist in
            undiminished vigour when some traveller from New Zealand shall,
            in the midst of a vast solitude, take his stand on a broken arch
            of London Bridge to sketch the ruins of St. Paul’s.”

      • Shaquille Harvey

        What racism ?

        • James

          There is nothing in Christianity that supports racism—quite the opposite. Yet Sunday morning remains “the most segregated hour in America”.

          Why are churches so far behind on issues of race?

          • Shaquille Harvey

            How do Churches remain segregated?
            Behind on what racial issues?

    • cestusdei

      Most of Jesus’ disciples left after he taught them about the Eucharist. He didn’t change what he said.

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