Debra Snell, President
12562 Rough and Ready Highway
Grass Valley, CA 95945
(530) 273-1005 snell gv.net
Lisa Ercolano, Vice President
220 Gaywood Road
Baltimore, MD 21212-1709
(410) 377-4204 momof2gals mindspring.com
Dan Dugan, Secretary
290 Napoleon St. Studio E
San Francisco, CA 94124
(415) 821-9776 dan dandugan.com



On February 10, 2003, the Ninth Circuit Court of Appeals published its decision on PLANS v. Sacramento City Unified School District and Twin Ridges Elementary School District. The document can be found at:


The court reversed the district court’s dismissal, and remanded the case back to the district court.


PLANS contends that public Waldorf schools are intrinsically and inseparably based upon Anthroposophy, a New Age occultic religion. Curriculum decisions and teacher training in public Waldorf schools are based on Anthroposophy’s spiritually-based child development model. Publicly-funded use and reliance upon the doctrines of Anthroposophy impermissibly endorses that religion in violation of the United States and California constitutions.

PLANS filed its federal lawsuit in Sacramento on February 11, 1998, naming as defendants the Sacramento Unified School District, which operates a “Waldorf Method” magnet school, and the Twin Ridges Elementary School District, which has established seven “Waldorf-inspired” charter schools.

During the discovery phase of the litigation, PLANS discovered internal documents that described, in the words of the Anthroposophists themselves, the true nature and purpose of Waldorf education. The Sacramento City Unified School District identified “The Waldorf Teacher’s Survival Guide” as one of its resource materials for “training or instruction in Waldorf teaching methods or Waldorf curriculum.” This book, which is published by Rudolf Steiner College Press–the same Anthroposophical institution that trained Sacramento’s public Waldorf teachers–describes the agenda and methods of Waldorf education. The Anthroposophical author, in a candid moment, describes the relationship between Waldorf education and Lucifer:

“Most of that which contributes to our work as teachers, preparation work, artistic work, even meditative work, is under the guardianship of Lucifer. We can become great teachers under his supervision, for he is responsible for much that has blossomed in the unfolding of civilization and culture in the past.”

In May, 2001, The Honorable Frank C. Damrell (U.S. District Court, Eastern District of California) dismissed PLANS’ Establishment Clause lawsuit against two school districts based on lack of standing. Judge Damrell reversed his earlier ruling in favor of PLANS’ standing in the light of the 2nd Circuit Court’s decision in the Altman case.

In the Altman case, Roman Catholic parents sued a public school district because they objected to a number of practices that they saw as New Age religion in a public school. The court upheld some claims and dismissed others. The judge found that the making of an image of the Hindu god Ganesha, the use of “worry dolls” to “chase away bad dreams,” the liturgy of an Earth Day celebration, and the playing of a Native American prayer on a meditation tape violated the Establishment Clause. Other practices that were ruled to be harmless included the game “Magic, the Gathering,” a Yoga class taught by a Sikh priest, and meditation exercises.

In its decision on an appeal, the 2nd Circuit Court threw out all of the allowed claims on a technicality without considering the merits of the case. The circuit court ruled that most issues were moot because the children were no longer at the schools. Taxpayer standing was also denied because the plaintiffs did not show that the alleged religious activities involved any specific expenditure of public funds.

A major difference between the Altman case and PLANS’ case is that while in Altman the practices complained about were not coordinated, PLANS alleges that Waldorf schools, both private and public, are pervaded with Anthroposophy, the religious philosophy of Rudolf Steiner (1861-1925). The issue with public Waldorf schools, therefore, goes beyond specific practices to the allegation that a religious philosophy is the foundation of both educational theory and day-to-day activities.

With regard to taxpayer standing, the situation is also different in PLANS’ case. The schools involved made large expenditures for teacher training by Anthroposophical mentors and teacher training at Rudolf Steiner College, self-described as “a center for Anthroposophical endeavors.” The Sacramento public Waldorf program occupies a separate campus established for that purpose, and the Yuba River Charter School that PLANS is suing was formed for that purpose, so in both situations taxpayer funds have been specifically paid for the alleged religious activities.


“A good-faith pocketbook challenge identifies a measurable sum of public funds being used to further a challenged activity. Here, where PLANS objected to the entire Waldorf curriculum of the two schools in question and identified public funds used for those schools, we conclude that it raises a good-faith pocketbook challenge.” [p. 1760]

“PLANS does not limit its objection to specific programs or activities within the Waldorf educational day. Rather, it alleges that the entire Waldorf approach is inherently religious, and that in using public funds to support it, the school districts are impermissibly establishing religious schools. These allegations, along with PLANS’s identification of public funds used for the operation of the Waldorf schools, are sufficient to support taxpayer standing. This case is no different from a situation in which a school district uses public monies to fund the operation of a parochial school, e.g., setting up a magnet or charter Catholic school, where there would be no question as to taxpayer standing to challenge such funding.” [pp. 1762-1763]


Debra Snell, president of PLANS, said: “Our intention is to put Waldorf schools back in the private sector where they belong, and seal the crack in the wall of separation between church and state. I’m fully confident that we will win.”

Scott Kendall, attorney for PLANS, said: “This precedent-setting decision affirms that public funds can’t be used to establish emerging New Age religious schools without challenge.”

Dan Dugan, Secretary of PLANS, said: “Our federal court case is five years old today. What a nice anniversary present!”


PLANS was organized in late 1995 by former Waldorf parents and teachers concerned about both private and public Waldorf schools. It became a California non-profit corporation in 1997. PLANS’ volunteer board includes two public school teachers, one of whom has received Waldorf teacher training; the president of a skeptical society; the associate director of a Christian anti-cult ministry, and two former Waldorf parents. PLANS’ President, Debra Snell, was a director of a private Waldorf school and helped found a Waldorf charter school. For more information, please see the PLANS web site, https://waldorfcritics.org.