Burning Bibles at Public Schools

Can a public school have Christian books in its library? Are religious books coming under fire? The latest story comes from Temecula, California. But religious activists have worried for generations that public schools have become aggressive book-burners.

In the current case, the Pacific Justice Institute has accused Temecula’s River Springs Charter School—apparently one of three schools in the Springs Charter School network—of anti-Christian bias. A parent complained to PJI that the school library had purged any book with a Christian bent. According to a report in Christian News, the parent told PJI that the librarian had been told to get rid of religious books. As conservative commentator Todd Starnes tells the story, the school librarian was instructed to remove “all books with a Christian message, authored by Christians, or published by a Christian publishing company.”

As Starnes concluded darkly,

The way I see it – book banning is just one step away from book burning. And I don’t mean to pour gasoline on the fire, but we all know what regime did that.

When the conservative activist group complained, the superintendent, Kathleen Hermsmeyer, responded that the school did not permit “sectarian materials on our state-authorized lending shelves.”

This episode reminds me of an extraordinary rumor I stumbled across in my research for my upcoming book on conservatism in twentieth-century American education. Investigating the 1974 school blow-up in Kanawha County, West Virginia, I found one conservative activist who insisted that the school district had recently removed all the Bibles from the schools. Even more shocking, this conservative reported that the secularizing zealots in charge of the public schools had dumped the Bibles unceremoniously in a dumpster. When pressed, this activist could not provide details or evidence for his story. He said he had heard it from another conservative leader.

But most important, the story seemed true and likely to him. As a religious conservative, he thought it was believable that a public school leader would purge the school of Bibles. And other conservatives at the time agreed.

We could take it even further back. In the 1925 Scopes Trial, anti-evolution celebrity William Jennings Bryan argued that public schools must ban evolution, since they already banned the Bible. That kind of argument has a good amount of gut political appeal. But it has one glaring problem: It just wasn’t true. In fact, as I noted in my 1920s book, Tennessee had actually passed a mandatory Bible-reading law in 1915. But as far as I could tell, no defender of evolution ever called Bryan on his mistake. On both sides, school activists in the past have believed that religious books had been kicked out of public schools.

Today’s story from California is more credible. In this case, the school leader admitted that the policy had been put into effect. Nevertheless, to this observer, it seems the case from Temecula will be another tempest in a teapot. The Pacific Justice Institute likely sniffed an easy win, since of course public schools are not under any legal compulsion to remove all Christian reading materials from their libraries. Indeed, the US Supreme Court has been very clear that public schools can and should teach about religions.

As Justice Tom Clark wrote in the landmark 1963 Abington v. Schempp decision, “Nothing we have said here indicates that such study of the Bible or of religion, when presented objectively as part of a secular program of education, may not be effected consistently with the First Amendment.” Indeed, Clark had just specified that public schools must not exclude religion from public schools, “in the sense of affirmatively opposing or showing hostility to religion.”

So it seems to me that Superintendent Hermsmeyer has indeed blundered. In a publicly funded school, there is absolutely no constitutional mandate to remove sectarian reading materials. The school itself must not preach any religion, but the library can and should be a place where students may encounter religious ideas.


Hobby Lobby-ing for Religion in Public Schools

Has God been kicked out of America’s public schools?  The most common answer among religious conservatives is yes.  But a better answer might be that God has been kicked out as a host, but earnestly welcomed in as a guest.

A new Bible curriculum for public schools hopes to reverse that trend.  As we’ve reported, Steve Green, conservative evangelical leader of the Hobby Lobby store chain, has funded a new Bible curriculum for public schools.  A recent study from the Texas Freedom Network insists that Green’s curriculum crosses the line.

Hobby Lobby's Promotional Image for Its New Bible Curriculum

Hobby Lobby’s Promotional Image for Its New Bible Curriculum

The study of the Hobby Lobby Bible curriculum was undertaken by Mark Chancey of Southern Methodist University.  Chancey is a religious-studies professor with considerable expertise in the question of religion in public schools.

As Chancey reviews, it is entirely permissible for public school students to read and study the Bible.  The US Supreme Court has encouraged such study.  The problem comes when public schools attempt to teach a certain interpretation of the Bible.  In short, public schools can and should teach students about religion.  But they err when they teach students religion.

Chancey asks if the Hobby-Lobby-funded curriculum, The Book: The Bible’s History, Narrative and Impact, keeps on the constitutional side of this divide.  For several reasons, Chancey concludes that it does not.

First, though Chancey notes this is not conclusive, Steve Green himself has publicly stated his intention to spread his religion.  As Chancey notes, Green makes no secret of his evangelical ambition.

Simply because Green wants to spread his faith, of course, does not mean that this Bible curriculum tries to do so.  But Chancey argues that the Bible curriculum repeatedly insists or implies that a certain evangelical-friendly interpretation of the Bible is correct.  For one thing, the Bible curriculum suggests that the Bible is historically accurate.  The authors tell readers

that the Bible, especially when viewed alongside other historical information, is a reliable historical source.

Also, Chancey argues that the curriculum privileges a Protestant vision of the Bible.  And the curriculum suggests that the real story of the Bible is salvation, a narrative that points unerringly toward the salvation offered by Jesus Christ in the Gospels.

As Chancey concludes,

The combination of a religious purpose, pervading sectarian bias, and frequent factual errors demonstrates that this curriculum has a long way to go before being appropriate for a public school classroom.

What’s next?  Since a public school district in Mustang, Oklahoma has already adopted this Bible curriculum, it appears we are headed for another lawsuit.  If Chancey’s review of this curriculum is accurate, my guess is that this material will be ruled unconstitutional for public schools.


The OTHER Hobby Lobby Case

You’ve been following Hobby Lobby’s case for religious freedom before the US Supreme Court.  But did you know Hobby Lobby’s Steve Green has also prepared an ambitious Bible curriculum for use in America’s public schools?

According to Religion News Service, the school board of Mustang, Oklahoma has voted to use the Bible curriculum in its public schools.  Of course, despite some rumblings to the contrary, there is nothing unconstitutional about teaching the Bible in public schools.  The US Supreme Court’s ruling in 1963’s Schempp decision specified that the Bible can and should be taught in public schools, as long as it is not taught devotionally.  That is, children can learn about the Bible, about religion, but not be drilled in any particular religious belief.

But it often seems as if the folks who want to see more Bible in public schools have a decidedly devotional bias to their activism.  As Mark Chancey of Southern Methodist University found in his study of Texas Bible classes, a significant proportion of them end up teaching religion, not just teaching about religion.

In this case, no one questions Steve Green’s ardent religiosity.  As the Religion News Service article points out, Green has admitted in public statements that he hopes the Bible curriculum will show that the Bible is “good,” that it’s “true,” and that the Bible’s impact,

whether (upon) our government, education, science, art, literature, family … when we apply it to our lives in all aspects of our life, that it has been good.

It seems evident that Green hopes this Bible curriculum will lead students toward faith, at least incidentally.  For that reason, the Freedom From Religion Foundation has promised to “scrutinize” the Bible curriculum.

More evidence, it seems, of the uselessness of talking about “America’s public schools” in general.  Schools in some communities, such as Mustang, Oklahoma, may welcome evangelical Protestant curricula into their class schedules.  In other places, Green’s Bible curriculum will not be an issue.  Local school boards make decisions that fit with the cultural politics of their local communities.


Do You Read the Bible? Why?

Do you read the Bible?  Regularly?  If you do, you’re in good company.  Or at least you have lots of company.  Results from a survey have been published by the Center for the Study of Religion in American Culture at Indiana University—Purdue University Indianapolis, fondly known as Ewee-poohee.

The survey-meisters attached Bible-related question to two large-group surveys, the General Social Survey and the National Congregations Study.  The authors suggested a few key findings:

*   There is a 50/50 split among Americans who read any form of
scripture in the past year and those who did not. Among those who did,
women outnumber men, older people outnumber younger people, and
Southerners exceed those from other regions of the country.

*   Among those who read any form of scripture in the past year, 95%
named the Bible as the scripture they read. All told, this means that 48%
of Americans read the Bible at some point in the past year. Most of those
people read at least monthly, and a substantial number-9% of all
Americans-read the Bible daily.

*   Despite the proliferation of Bible translations, the King James
Version is the top choice-and by a wide margin-of Bible readers.

*   The strongest correlation with Bible reading is race, with African
Americans reading the Bible at considerably higher rates than others.

*   Half of those who read the Bible in the past year also committed
scripture to memory. About two-thirds of congregations in America hold
events for children to memorize verses from the Bible.

*   Among Bible readers, about half had a favorite book, verse, or
story. Psalm 23, which begins, “The Lord is my shepherd…” was cited most
often, followed by John 3:16.

*   Bible readers consult scripture for personal prayer and devotion
three times more than to learn about culture war issues such as abortion,
homosexuality, war, or poverty.

*   There are clear differences among Bible readers consulting scripture
for specific reasons. Age, income, and education are key factors.

*   Those reading the Bible frequently consult it on culture war issues
more than two times the rate as those who read it less frequently.

*   Less than half of those who read the Bible in the past year sought
help in understanding it. Among those who did, clergy were their top
source; the Internet was the least cited source.

*   Among Bible readers, 31% read it on the Internet and 22% use

*   Bible reading differences among religious traditions followed
predictably the historic divides between Protestants and Catholics, and
between white conservative and white moderate/liberal Protestants.
However, reading practices defy some stereotypes about certain groups.

What can we take away from these headlines?  First, for those of us who don’t read the Bible regularly and who don’t really care about what the Bible might say about any given social issue, this report serves as a reminder that many Americans see the Bible very differently.  For instance, if I read the above numbers correctly, about a quarter of respondents told interviewers that they thought it was important to memorize chunks of the Bible.  Also, those who do tend to read the Bible also tend to use the Bible to prove points on social issues.  For example, I do not find the Bible to be relevant to the issue of gay marriage, but many Americans do.  Finally, we see yet another reminder that religious divisions do not neatly match political ones.  African Americans, for example, tend to vote Democratic.  Yet they also tend to read the Bible more often than other groups.

Yet moving past the headlines, we also see some confirmation in this report of stereotypes about the Bible.  For instance, the authors found that Bible-reading was much more common among old people than among the young.  Of those over 75, 56% reported reading the Bible in the past year.  Of those between 18-29, only 44% did so.  Also, Bible-reading was most prevalent in the South (61%) and least prevalent in the Northeast (36%).

Yet even the body of the report contains intriguing surprises.  For example, of those who said they consider the Bible the “inerrant Word of God,” a significant percentage did not read the Bible at all in the past year.  If we add in respondents who said they believed the Bible was the “divinely inspired Word of God,” we get an astonishing result: Those Bible-lovers made up 65% of the people who said they had never read the Bible in the past year!  That’s right: of the people who said they had not read the Bible in the past year, 50% still thought the Bible was divinely inspired, and 15% thought that the Bible was inerrant.  Clearly, Bible-reading does not correlate with theological convictions about the importance or status of the Bible.

And, of course, people read the Bible for all sorts of reasons.  It was no surprise to find that the most common reason people give for reading the Bible is prayer and personal devotion.  But large numbers of respondents also claim to read the Bible to find out how to make more money, how to heal themselves, and how to predict the future.  As the study concludes, these uses of the Bible correlate strongly to levels of formal education.  People who have gone to college tend to use the Bible less for these sorts of purposes.  As the authors put it, “those with less education read the Bible at twice the rate of someone with a college degree for the purposes of learning about culture war issues, health and wealth, and what the future holds” (24-25).

So what can this survey tell us?  The IUPUI researchers asked prominent scholars for their opinions.

As prominent historian of religion Mark Noll commented, one hoped-for result of this survey was to add needed complexity to public discussions about the Bible.  “These IUPUI surveys,” Noll suggested, “should bring sanity back into journalists’ reporting on religion, at least to the extent that they show how important non-political use of scripture continues to be in modern American life.”

Professor of African American Studies Sylvester Johnson added a different take-away message.  This survey, Johnson noted, demonstrates the persistence of “the dominant reality of biblical fundamentalism in Black churches.”  Many observers, Johnson said, have long attributed a social progressivism to African American churches that simply doesn’t match the cultural reality.

In any case, whether it is used as a symbol of cultural identity, a source of clues to the future, or a dusty tome on a shelf that is left alone to molder, Americans still care about the Bible.


Are You a Camel Denier?

The authenticity of the Bible has received a new challenge, a new camel’s nose under the tent.  You’ve probably seen the headline: Two archaeologists have published their findings that camels did not likely live in Biblical lands at the time of Abraham, yet the Bible says they did.

One obvious conclusion is that the early books of the Bible were written long after the events they describe.  Conservative Protestants quickly disputed this implication.  Dr. Andrew Steinmann, a professor of Hebrew and theology at Concordia University-Chicago, insisted that this evidence merely proved the accuracy of the Old Testament.  Camels, Steinmann argued (according to an article in the Christian Post), were not described in the OT as widespread, but rather only owned by recent emigres from other areas.

As Gordon Govier aptly put it in the pages of Christianity Today, this archaeological dispute is only the “latest challenge to the Bible’s accuracy.”

Indeed, as historians of evangelicalism will tell you, the roots of what we think of as fundamentalism and its neo-evangelical offshoots came directly from an earlier generation of scholarly criticisms of the Bible’s accuracy.

In all the ruckus, nothing I’ve seen has been more poignant than the recent accusation by Julie Borg in World Magazine that the archaeologists amount to nothing more than cynical “Camel Deniers.”  She argues that plenty of secular research disproves their bitter and ill-conceived anti-Biblical argument.

So how about it?  Is this a new “denier” category to add to our culture-war lists?


Charter Schools SHOULD Be Religious


Thanks to alert colleagues, I’ve been following the great series of articles in Slate about creationism and charter schools.  Most recently, we find a map of charter schools that seem to be teaching creationism.  According to this survey by Chris Kirk, plenty of tax-funded charter schools across the nation are teaching creationism.

But is there anything wrong with charter schools teaching creationism?

Don’t get me wrong: I think all students should learn the best science, even if they go to non-tax-funded schools or homeschools.  That should not be a legal requirement, but rather simply a goal for common education and citizenship.  In traditional public schools, we should demand a rigorously pluralist ethos.  No student from any religion or non-religion (or race, or gender identity, or etc.) should ever feel squeezed out due to his or her background.  And I don’t dispute Kirk’s accusation in this Slate piece that lots of charter schools are likely teaching creationism.  As Kirk puts it,

If you live in any of these states, there’s a good chance your tax money is helping to convince some hapless students that evolution (the basis of all modern biological science, supported by everything we know about geology, genetics, paleontology, and other fields) is some sort of highly contested scientific hypothesis as credible as “God did it.”

But let’s step back a moment and examine the real legal, educational, and constitutional issues here.  Let’s not forget that charter schools were created in order to offer more authentic diversity of educational models.  Should that diversity not include religious diversity?

According to a note in the Yale Law Journal a few years back, the proper line between religion and publicly funded charter schools is not as clear cut as journalists and policy-makers often assume.  In that 2008 piece, Benjamin Siracusa Hillman argues that charter schools ought to be allowed or even encouraged to include religious practices and beliefs.

Recent US Supreme Court decisions, Hillman argues (see esp. page 576), support a notion that school districts may legitimately include religious schools without violating the famous 1970 “Lemon Test.”  If a state or school district has a secular purpose in setting up schools—including even religious schools—those schools are more likely to pass constitutional muster.  The goal must not be to serve only one sort of religion.  Nor must school districts hope to exclude non-religious students, or students from other religious backgrounds.  Religious schools may fit into a broad charter school/voucher school network, the Court has suggested, as long as the first purpose is to improve education for all.

Hillman also analyzes the decision of a Michigan court in which parents sued a charter school for cramming religion into their publicly funded school.  The school, according to this federal court ruling, did no wrong in including religion, since it did not force students to engage in religious practice or adopt religious beliefs.

So can publicly funded charter schools teach creationism?  Or, even more provocatively, SHOULD charter school networks work to include schools that teach creationism?

The recent string of Slate articles implies that such practice ought to raise alarm bells.  But if we view creationism as an expression of a religious belief, it seems the rule is not quite so cut-and-dried.  Public school districts have much more leeway to include religious schools than many people seem to think.  Such ignorance can be politically useful.  For example, no one will mobilize to fight against teaching that might be perfectly legal and even desirable.  But some sections of our chattering classes might have better luck with breathless exposes of religion in publicly funded schools.




Should Liberals Teach the Bible in Public Schools?

Usually, when we hear pleas for the teaching of the Bible in America’s public schools, they come from conservative evangelical Protestant activists.  Today, though, liberal scholar and friend of ILYBYGTH Mark Chancey makes the liberal case for teaching the Bible in public schools.  Do you buy it?

Chancey attracted attention a while back for his study of the ways public schools in Texas teach the Bible.  Too many of them, he concluded, teach a sectarian theology.  Too many public school programs, he found, don’t teach students about the Bible, but rather try to tell students what to believe about the Bible.

Recently in the pages of Religion & Politics Chancey outlined the ways the Bible should be taught.  He offered an eight-point outline of the ways good public-school Bible programs work.  Everyone interested in religion, he argues, should staunchly support the teaching of the Bible in America’s public schools.  To do it right, though, schools need to learn from the successful Texas programs he saw in his review.

What do good public-school Bible programs do?  Here are Chancey’s pointers:

  • They relied on resources informed by a broad range of biblical scholarship, not just the scholars of one particular religious community.

  • They informed students about the unique features of the Bibles of different traditions (Jewish, Roman Catholic, Protestant, and Eastern Orthodox).

  • They were intentional in exposing students to biblical translations associated with different religious traditions.

  • They were sensitive to the different ways various religious communities have interpreted particular passages and did not present one tradition’s interpretation as normative.

  • They recognized the importance of biblical texts as ancient historical sources without lapsing into a tone of assumed historicity.

  • They discussed the Bible’s moral and theological claims without presenting them as authoritative for the students.

  • They recognized that the Bible is not a science textbook.

  • They treated Judaism as a religion in its own right and not merely as the foil or background for Christianity.

I never learned squat about the Bible in all my public-school experience.  Part of that might be geography.  I grew up in the liberal heartlands of suburban Boston.  Chancey’s study focuses on the Bible teaching in Texas.  I know there are plenty of conservative religious folks in Boston, but the history and culture of Boston’s public schools differs in enormous ways from that of other regions.

I agree wholeheartedly that educated people should know about the Bible.  But here is a question for ILYBYGTH readers: should liberals push for more Chancey-style Bible education?  That is, should liberals encourage their local public schools to teach about the Bible, even as they don’t try to cram Biblical Christianity down students’ throats?  Or is that too eerily similar to mainstream scientists who might agree to teach “problems with evolution” in public-school science classes?

In other words, we might all agree that students should learn the real scientific debates about evolution, just as we might agree that students should learn about the Bible.  But the history of controversy over the teaching of evolution—just as with the history of controversy over the teaching of the Bible—has made it difficult if not impossible for liberals to support the teaching of scientific debates over evolution.  Too often, because of political meanings, teaching the “debate” over evolution has been code for teaching religious ideas in science classes.  Is the same true here?  If public schools attempt to teach about the Bible, would it tend to devolve into cramming religion down students’ throats?

Professor Chancey says no.


Guns and Bibles

School needs more of both.  At least according to Texas Attorney General Greg Abbott.

In their continuing series of year-end quotations from conservatives, the Texas Freedom Network Insider publicized this gem from Abbott’s Facebook page:

Source: Greg Abbott

Source: Greg Abbott

For those of us who are trying to understand the intellectual world of educational conservatism, Abbott’s plea is a good place to start.  The give-and-take of comments that accompanied this eye-catching poster sums up lots of the perennial debate in school culture wars.

As one back-and-forth had it,

Person 1: Satan is having a POW-WOW in our country right now….the Anti-Christ is alive and well! WAKE UP AMERICA!!!

Person 2: Good they should not be taught in school. Bible is mythology and learn to shoot at a gun range.

Abbott’s call for more Bibles and more guns in schools may seem shocking to progressives like me, but it seems many conservatives want both.  Especially after each school shooting, we hear calls for more armed guards to protect the innocent.  And of course there is never any lack of tumult for increasing the use of Bibles with America’s public school students.

Here’s a question for all you readers out there: For those agree with Abbott’s call for more Bibles and guns in schools, which should come first?  That is, if you had to pick, which would improve schools more, guns or Bibles?

And for those who are shocked with Abbott’s post, here’s a very different question: what are you more scared of, more Bibles or more guns in public schools?


God, Darwin, Creationism, and UFOs

What do Americans believe?

A new Harris poll suggests that Americans believe all sorts of things.  Folks who think religion is a bad thing might be heartened by recent increases in the numbers of people who claim not to believe in God.  But the same anti-religion types might be depressed by the high numbers of believers and by their descriptions of their belief.

Consider some highlights: the number of respondents (out of 2,250 overall) who claimed not be “not at all religious” was 23%, up from 12% in 2007.  And the numbers of respondents who said they thought the Bible was the “word of God” was down 6% since 2008.

But before the American Humanist Association breaks out the bubbly, consider some countervailing numbers: even though the number of Bible-believers may have declined slightly, it still represents just under half of respondents. That is, almost half of Americans—if we can extrapolate from these responses—will tell you that the Bible is the Word of God.

And though the number of respondents who said they “believe in Darwin’s theory of evolution” is up five percent, the new total is still under half, far fewer than the number (58%) who say they believe in the Devil.

How about creationism?  Here are a few numbers to chew on: 29% of respondents say they don’t believe in “Darwin’s theory of evolution,” but 36% of them claim to believe in creationism.

Here’s my hunch: science pundits might fixate on the lead sentence that “36% each believe in creationism and UFOs.”  Some folks who don’t like creationism but don’t know much about it might conclude that belief in these things is somehow similar.  Those who don’t know enough real science, these pundits might assume, are prone to believe in all sorts of kooky non-science.

Such mistaken assumptions misunderstand the nature of creationism.  Belief in UFOs might come from all sorts of backgrounds, from eccentric FBI agents to rural isolation.

But in the USA, creationism represents something more than the lack of knowledge about evolution.  Instead, creationism comes from its own intellectual tradition, one that does more than simply ignore evolution.  You would be hard pressed, for example, to find a network of colleges and universities dedicated to teaching a worldview centered on the existence of UFOs.  But there is indeed a strong network of religious schools that teach creationism.

Certainly, belief that humanity resulted from God’s special creation can have lots of intellectual sources.  But it is a fundamental mistake of outsiders like me to assume that such creationist belief is a lack of something, a deficit of knowledge about evolution.

There are pundits out there who assume that these poll numbers represent a victory for anti-religious activism.  I’m not so sure.  Americans seem to believe all kinds of things.  The wobble in numbers represented by these results may point toward an anti-religious trend.  That is, if the number of respondents who said they did not believe in God increased ten percent in the last ten years, we might conclude that pretty soon large majorities of Americans will join them.

I doubt it.  My hunch is that these increases in atheism and skepticism will not represent a continuing trend.  Large numbers of people believe that the Bible is the Word of God.  Large numbers of people believe in things that mainstream science would pooh-pooh.  And they will continue to do so for a long time to come.


Bible Bullying and the Borders of Fiction

Is the Bible nonfiction?  Can public-school teachers call it fiction?  More important, can a teacher poke fun at a student who considers the Bible nonfiction?

Those questions are at the heart of a new lawsuit from Temecula, California.

According to The Christian Post, a middle-school teacher asked students to bring in a nonfiction book to read.  When one student pulled out a Bible, the teacher objected.  Worst of all, according to The Post, the teacher ridiculed the student for considering the book nonfiction.

An activist legal group, Advocates for Faith and Freedom, has sued the school district.  The Christian legal group wants the school district to add teachers to its bullying policy.

According to AFF President Robert Tyler, the teacher’s actions in this case represent just the tip of the anti-Christian iceberg.

In an interview with the Christian News Network, Tyler denounced public-school teachers’ tendency to bully Christian students.  “These days,” Tyler said,

there is no shortage of bullying against Christian students by teachers.  If a teacher were to take the same tone and tactic against a homosexual student based on the student’s sexual orientation, the teacher would be subjected to serious and significant discipline. But for some reason, these teachers feel that they have the ability to engage in this type of hostility and attempt to humiliate Christian students.

The exact boundaries of religious expression for public-school students have long been tricky to figure out.  Can self-funded cheerleaders display Bible messages at public-school football games?  Can students wear religious t-shirts?

But this case raises different questions, too.  Can teachers be bullies?  Can school districts use their existing anti-bullying policies to discipline teachers?

It seems like a difficult proposition.  After all, teachers in most schools have an explicit duty to manage the behavior of their students.  It would be bullying, in many cases, for one student to make another student quiet down.  But if a teacher makes a student quiet down, isn’t that just classroom management?

Couldn’t the Advocates for Faith and Freedom make a simpler argument?  Teachers certainly should not belittle students for their religious beliefs.  Why should the school district have to call it “bullying?”