Case No. 20-cv-04540 Page 1 of 23

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

SEPARATION OF HINDUISM FROM 

OUR SCHOOLS, an unincorporated 

association; CIVIL LIBERTIES FOR 

URBAN BELIEVERS, an unincorporated 

association; AMONTAE WILLIAMS, 

individually and as a representative for all 

similarly situated persons; DASIA 

SKINNER, individually and as a 

representative for all similarly situated 

persons; and DARRYL WILLIAMS, 

individually and as a representative for all 

similarly situated persons,

)

)

)

)

)

)

)

)

)

)

)

)

)

Plaintiffs, )

) Case No. 20-cv-04540

v. )

) The Honorable Judge Matthew F. Kennelly

CHICAGO PUBLIC SCHOOLS, City of 

Chicago School District #299; THE 

DAVID LYNCH FOUNDATION; and 

THE UNIVERSITY OF CHICAGO,

)

)

)

)

)

Defendants. )

AMENDED CLASS ACTION COMPLAINT

NOW COME the Plaintiffs, SEPARATION OF HINDUISM FROM OUR SCHOOLS, 

an unincorporated association, CIVIL LIBERTIES FOR URBAN BELIEVERS, an 

unincorporated association, AMONTAE WILLIAMS, individually and as a representative for all 

similarly situated persons, DASIA SKINNER, individually and as a representative for all 

similarly situated persons, and DARRYL WILLIAMS, individually and as a representative for 

all similarly situated persons (collectively “Plaintiffs”), by and through their attorneys, MAUCK 

& BAKER, LLC, and hereby complain of Defendants CHICAGO PUBLIC SCHOOLS, THE 

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DAVID LYNCH FOUNDATION, and THE UNIVERSITY OF CHICAGO (collectively 

“Defendants”), as follows:

INTRODUCTION

1. Plaintiffs seek redress under 42 U.S.C. § 1983 for deprivations of their constitutional 

rights under the First and Fourteenth Amendments to the United States Constitution. Plaintiffs also 

seek redress for violations of the Illinois Religious Freedom Restoration Act, 775 ILCS 35/1, et seq.

2. Defendants violated the Establishment and Free Exercise Clauses of the First 

Amendment to the United States Constitution when they collaborated to implement and facilitate 

the “Quiet Time” program within eight known CPS schools.

3. Although all named Defendants have made statements to the contrary, the “Quiet Time” 

program is based in Hindu beliefs and the practice of “Transcendental Meditation” is fundamentally 

religious in nature.

4. Plaintiffs’ rights under the First Amendment were violated when Defendants created 

environments within public schools where Hindu beliefs and the practice of “Transcendental 

Meditation” were being endorsed and students were coerced to engage in religious practices against 

their wills, teachers were directed to participate in the coercion as part of their employment with 

CPS, and the coercion interfered with the rights of parents and legal guardians to direct the religious 

education of their CPS-student children.

5. Defendants, by collaborating to implement and facilitate the “Quiet Time” program 

within certain CPS schools, also violated the Illinois Religious Freedom Restoration Act by 

substantially burdening the religious free exercise rights of CPS students, CPS teachers, and the 

parents and legal guardians of CPS students.

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JURISDICTION AND VENUE

6. This Court has jurisdiction over this matter under 28 U.S.C. §§ 1331 and 1343.

7. This Court has supplemental jurisdiction over the substantially related state law matters 

under 28 U.S.C. § 1367(a).

8. The Court has the authority to grant declaratory relief under the Declaratory Judgment 

Act, 28 U.S.C. §§ 2201 and 2202 and injunctive relief under Federal Rules of Civil Procedure 7 and 

65.

9. Venue is proper under 28 U.S.C. § 1391(b), because a substantial part of the events or 

omissions giving rise to these claims occurred within the Northern District of Illinois.

PARTIES

10. Plaintiff Separation of Hinduism from our Schools is an unincorporated association of 

parents, students, and others who want to remove Hindu-based religious practices, concealed as 

“Transcendental Meditation,” from our public schools.

11. Plaintiff Civil Liberties for Urban Believers (“CLUB”) is an unincorporated association 

of churches and ministries located in Chicago, Illinois. CLUB seeks to protect religious civil 

liberties particularly relating to the First Amendment’s Free Exercise and Establishment Clauses. It 

is organized and directed by the Holy Spirit. Plaintiff CLUB has prepared a declaration that is 

attached and incorporated by reference as Exhibit A.

12. Plaintiff Amontae Williams is a former CPS student who graduated from a CPS school 

that hosted the “Quiet Time” program. Prior to his graduation, he participated in the “Quiet Time” 

program implemented at his CPS school.

13. Plaintiff Dasia Skinner is a substitute teacher who accepted assignments to teach 

students at two CPS schools that both hosted the “Quiet Time” program. On occasion, during class 

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time, students were escorted out of her classes by certified “Transcendental Meditation” instructors 

for the purpose of participating in extra CPS meditation sessions.

14. Plaintiff Darryl Williams is a parent of Plaintiff Amontae Williams, a former CPS 

student.

15. Defendant Chicago Public Schools (“CPS”), officially classified as City of Chicago 

School District #299, is the fourth largest school district in the United States. CPS recently reported 

overseeing 652 schools, including 477 elementary schools and 165 high schools. CPS claims an 

enrollment of over 355,000 students. CPS schools are funded in part through local property taxes.

16. Defendant David Lynch Foundation (“DLF”) is an Iowa not-for-profit corporation 

headquartered in New York City and registered to do business in Illinois and a 501(c)(3) 

organization with a stated mission of “promoting widespread implementation of the . . .

Transcendental Meditation (“TM”) program” with a specific focus on “inner-city students.” About 

DLF, https://www.davidlynchfoundation.org/about-us.html (last visited Jul. 20, 2020), Exhibit G. 

DLF’s program targeting implementation within urban schools is known as “Quiet Time” (“QT”). 

On its website, DLF states that it has successfully aided the implementation of the Quiet Time 

program in “hundreds of public, private and charter schools worldwide” and the organization 

solicits donations to pursue its intention to “expand the Quiet Time program in the U.S. and around 

the world.” Quiet Time with Transcendental Meditation in Schools, 

https://www.davidlynchfoundation.org/schools.html (last visited Jul. 20, 2020), Exhibit H. On its 

website, DLF also identifies Chicago as one of four locations where the organization is particularly 

interested “to expand the network of schools with Quiet Time programs.” Funding Guidelines 

Underserved Schools, https://www.davidlynchfoundation.org/funding-guidelines-underservedschools.html (last visited Jul. 20, 2020), Exhibit I.

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17. Defendant University of Chicago, an Illinois not-for-profit corporation, acting through 

the Crime and Education Labs of the University of Chicago Urban Labs, worked collaboratively 

with Defendants CPS and the David Lynch Foundation to plan and conduct a research project 

designed to implement the “Quiet Time” program within multiple CPS schools. The University of 

Chicago Urban Labs is a group of five research laboratories working “to address challenges across 

five key dimensions of urban life: crime, education, health, poverty, and energy & environment.” 

Defendant Urban Labs “partner[s] with civic and community leaders to identify, test, and help scale 

the programs and policies with the greatest potential to improve human lives.”

18. Although CPS is a governmental entity and, upon information and belief, the David 

Lynch Foundation and the University of Chicago are private entities, all defendants acting in 

concert were acting under color of law during the time periods relevant to this action. Dennis v. 

Sparks, 449 U.S. 24, 27–28 (1980)

COMMON ALLEGATIONS

19. “Transcendental Meditation” is a specific 

type of silent meditation, involving the use of mantras, 

that was developed by Maharishi Mahesh Yogi in India 

in the 1950s.

20. Proponents of “Transcendental Meditation” 

claim that the technique can help students to improve 

academic performance and reduce stress and violence.

21. Upon information and belief, the David 

Lynch Foundation approached the University of 

Chicago Urban Labs with a proposal to run a research TM Founder Maharishi Mahesh Yogi in 

Huntsville in January 1978 (Jdontfight / CC 

BY-SA (https://creativecommons.org/licens 

es/by-sa/3.0))

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project involving running the “Quiet Time” program within certain CPS schools.

22. Upon information and belief, the University of Chicago Urban Labs agreed to run the 

proposed research project and was involved in jointly approaching CPS with the project 

proposal.

23. Upon information and belief, CPS, the University of Chicago Urban Labs, and the 

David Lynch Foundation worked collaboratively to establish parameters for the “Quiet Time” 

program within CPS schools.

24. Upon information and belief, CPS, the University of Chicago Urban Labs, and the 

David Lynch Foundation worked collaboratively to implement the “Quiet Time” program within 

CPS schools.

25. The “Quiet Time” program took place during regular school hours and utilized space 

located on school property which was specifically designated for the use of the program.

26. The “Quiet Time” program was designed to provide instruction in—and to facilitate 

the practice of—“Transcendental Meditation” by CPS students.

“Puja” Initiation Ceremony

27. The practice of “Transcendental Meditation” requires participation in an initiation 

ceremony, also known as a “Puja.”

28. “Puja” initiation ceremonies must be led by “Transcendental Meditation” instructors, 

who are certified by the Maharishi Foundation USA, a 501(c)(3) founded by Maharishi Mahesh 

Yogi.

29. During a “Puja” initiation ceremony, various bowls, food items, and symbolic items 

are arranged around a picture of Guru Dev, a former teacher of Maharishi Mahesh Yogi, the 

founder of Transcendental Meditation.”

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30. During a “Puja” initiation ceremony, specific items are presented to the picture of 

Guru Dev while the “Transcendental Meditation” instructor performs a chant in Sanskrit, which 

is also accompanied by certain rehearsed movements.

31. At CPS schools, “Puja” initiation ceremonies involving either individual or small 

groups of students were performed in private by the certified “Transcendental Meditation” 

instructors.

32. CPS students were asked to actively participate in the “Puja” by bringing certain 

items to be presented to the image of Guru Dev.

33. The certified “Transcendental Meditation” instructors did not identify the person 

appearing in the photograph displayed on the table.

34. The certified “Transcendental Meditation” instructors did not explain the significance 

of presenting various items to the photograph displayed on the table.

35. CPS students were asked to remain present while the certified “Transcendental 

Meditation” instructor performed a ritual involving the chanting of Sanskrit words coordinated 

"Puja" shrine constructed around an image of Guru Dev

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with certain rehearsed movements.

36. The certified “Transcendental Meditation” instructors did not explain the meaning 

behind the Sanskrit words they were chanting during the “Puja” initiation ceremony.

37. When translated into English, the Sanskrit words chanted during the “Puja” initiation 

ceremony contain, among other things, statements recognizing the power possessed by various 

Hindu deities and invitations to those same Hindu deities to channel their powers through those 

in attendance at the “Puja” initiation ceremony.

38. Proponents of “Transcendental Meditation” consider the “Puja” initiation ceremony 

critical to the practice of “Transcendental Meditation,” because the “Puja” establishes the 

necessary connection between a practitioner and the entities that ultimately make the technique 

effective.

39. Every CPS student that participated in the “Quiet Time” program was asked to 

participate in a “Puja” initiation ceremony.

40. Each “Puja” initiation ceremony was led by a certified “Transcendental Meditation” 

instructor, during regular school hours, in a space located on school grounds but set aside for the 

exclusive use of the “Quiet Time” program.

41. The certified “Transcendental Meditation” instructors took steps to ensure that the 

spaces used for “Puja” initiation ceremonies remained private, by keeping doors closed, turning

off the lights during the “Puja,” and covering windows to block any outside view into the rooms.

Mantras

42. The practice of “Transcendental Meditation” involves silent meditation, with 

encouragement to utilize an assigned mantra to assist in the meditative process.

43. During meditation, “Transcendental Meditation” practitioners are taught to silently 

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repeat their mantras.

44. Certified “Transcendental Meditation” instructors told CPS students that mantras are 

“meaningless sounds.”

45. CPS students were also told that they 

should only utilize a mantra that has been uniquely 

assigned to them by a certified “Transcendental 

Meditation” instructor.

46. During their respective “Puja” initiation 

ceremony, the CPS students were taught how to 

pronounce their assigned mantra, but were not 

given the meaning or significance behind the 

Sanskrit words themselves.

47. Mantras are drawn from a select pool of Sanskrit words that honor or reference 

specific Hindu deities.

48. For example, the “Aim” mantra is associated with the deity Saraswati, who is the 

Hindu goddess of knowledge, music, art, wisdom, and learning.

49. Every CPS student that participated in the “Quiet Time” program was assigned a 

mantra and instructed to silently repeat it whenever engaged in CPS meditation sessions.

Secretive Nature

50. The practice of “Transcendental Meditation” involves an oath to secrecy.

51. “Transcendental Meditation” practitioners are warned to not discuss any details of 

what they heard, saw, or experienced during the “Puja” initiation ceremony.

52. “Transcendental Meditation” practitioners are warned to not reveal their mantras to 

Chart of Common TM Mantras

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others.

53. “Transcendental Meditation” practitioners are warned to not recount to others any of 

their private interactions with certified “Transcendental Meditation” instructors.

54. Every CPS student that participated in the “Quiet Time” program was instructed to 

keep their experiences with respect to the program secret from others, including their parents, 

legal guardians, other students, and their friends.

55. “Quiet Time” participants were further warned that failing to keep the oath to secrecy 

would render the practice of “Transcendental Meditation” wholly ineffective.

CPS Meditation Sessions

56. The “Quiet Time” program involved requiring CPS students to engage in two 15-

minute meditation sessions, one in the morning and one in the afternoon of every school day.

57. During each CPS meditation session, students were instructed to be silent.

58. Each CPS meditation session was preferentially led by a certified “Transcendental 

Meditation” instructor.

59. Whenever a certified “Transcendental Meditation” instructor was not available for a 

particular classroom during a scheduled meditation session, the CPS teacher assigned to that 

classroom was expected to lead the meditation session as part of their employment with CPS.

60. A small handheld bell, also known as a “Ghanta” or ritual bell commonly used in 

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Hinduistic religious practices, was rung by the certified “Transcendental Meditation” instructor 

or assigned CPS teacher to indicate the beginning of each CPS meditation session.

61. In the Hindu belief system, bells are often used to indicate a desire to interact with a 

deity and to prepare a listener’s mind for said interaction.

62. CPS, the University of Chicago Urban Labs, and the David Lynch Foundation all 

made representations, either directly or indirectly, to students, parents, legal guardians, and staff 

that the “Quiet Time” program and “Transcendental Meditation” are non-religious in nature.

63. By failing to disclose the religious nature of the “Quiet Time” program, students, 

parents, and legal guardians were not given a fair opportunity to decide whether to opt out of 

participation in the program. Declarations discussing the hidden religious nature of 

“Transcendental Meditation,” and the “Quiet Time” program by extension, are attached and 

incorporated by reference as Exhibits E & F.

64. The lack of transparency within the “Quiet Time” program created conditions under 

which interference with the rights of parents and legal guardians to direct the religious education 

of their CPS-student children could occur.

ALLEGATIONS AS TO AMONTAE WILLIAMS

65. Plaintiff Amontae Williams has prepared a declaration that is attached and incorporated 

by reference as Exhibit B.

66. Plaintiff was a former CPS student attending Bogan Computer Technical High School 

(“Bogan”) as a junior and a senior, until graduating in the spring of 2019.

67. Plaintiff regularly attended a Christian church with his family and was raised within the 

Christian faith.

68. While attending Bogan, Plaintiff first encountered the “Quiet Time” program, which 

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was being run at the school.

69. Plaintiff discussed with his classmates the collective pressure they felt from CPS 

administrators, CPS teachers, and the certified “Transcendental Meditation” instructors to 

participate in the “Quiet Time” program.

70. Plaintiff discussed with his classmates the collective discomfort they felt in participating 

in the “Quiet Time” program and their desire to discontinue their participation.

71. Plaintiff learned of the hidden religious nature of the “Quiet Time” program and shared 

that information with other CPS students, but he was reprimanded in the form of being sent to the 

principal’s office on two occasions.

72. During his first trip to the principal’s office, Plaintiff was warned by Sharon Dixon, 

Bogan’s Operations and Climate and Culture Manager, to stop sharing with other CPS students 

about how the “Quiet Time” program involves religious practices and rituals based in Hinduism.

73. During his second trip to the principal’s office, Sharon Dixon threatened Plaintiff with 

suspension for continuing to tell other CPS students about the concealed connections between 

“Quiet Time” and Hinduism.

74. While participating in a CPS meditation session, Plaintiff had a traumatic experience 

that felt to him like exposure to negative spiritual influences, contrary to his religious upbringing.

75. Plaintiff was repeatedly rebuffed when he asked certified “Transcendental Meditation” 

instructors to explain what was happening during the “Puja” initiation ceremony, the meaning 

behind his assigned mantra, and the religious and/or spiritual significance of the scheduled CPS 

meditation sessions.

76. The above described conduct demonstrates how Plaintiff was coerced, as a CPS student, 

to engage in religious practices and rituals that are based in Hinduism, in violation of his rights 

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under both the Establishment and Free Exercise Clauses.

ALLEGATIONS AS TO DASIA SKINNER

77. Plaintiff Dasia Skinner has prepared a declaration that is attached and incorporated by 

reference as Exhibit C.

78. Plaintiff was a CPS substitute teacher who accepted assignments to work at Bogan 

Computer Technical High School and Gage Park High School in 2018 and 2019, during periods 

while the two schools were actively facilitating the “Quiet Time” program.

79. Plaintiff is an active participant within a Christian church and strongly identifies with the 

Christian faith.

80. By virtue of her position as a CPS employee and authority figure to CPS students 

entrusted to her care and instruction, Plaintiff felt pressured by CPS administrators to support the 

“Quiet Time” program and to encourage CPS students to participate.

81. Plaintiff was also pressured to evaluate students based upon their participation in the 

“Quiet Time” program.

82. After speaking with a number of students, multiple certified “Transcendental 

Meditation” instructors, and conducting her own investigation into the foundations of 

“Transcendental Meditation,” Plaintiff confirmed that “Transcendental Meditation” is built upon 

religious practices and rituals that are based in Hinduism.

83. Plaintiff’s personal faith and religious practices are inconsistent with the practices and 

beliefs associated with Hinduism.

84. The above described conduct demonstrates how Plaintiff was coerced, as a CPS teacher, 

to facilitate religious practices and rituals that are based in Hinduism, in violation of her rights under 

both the Establishment and Free Exercise Clauses.

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ALLEGATIONS AS TO DARRYL WILLIAMS

85. Plaintiff Darryl Williams has prepared a declaration that is attached and incorporated by 

reference as Exhibit D.

86. Plaintiff is a parent of a former CPS student who felt pressured to participate in the 

“Quiet Time” program at a CPS school.

87. Plaintiff is an active participant within a Christian church and strongly identifies with the 

Christian faith.

88. As a parent, Plaintiff has gone to great lengths to direct the religious education of his 

children.

89. When Plaintiff enrolled his children into CPS schools, Plaintiff did not anticipate that 

CPS, as a secular and governmental entity, would interfere in the religious education of his children.

90. When Plaintiff first learned of the existence of the “Quiet Time” program and its 

connection to practices and beliefs based in Hinduism, long after the program was first instituted 

within CPS schools, Plaintiff was angered by the intrusion into his child’s religious education and 

coercion toward a belief system that is inconsistent with his personal faith and the religious practices 

of his family.

91. As a taxpayer, Plaintiff was also angered by the use of public funds and resources to 

create environments within public schools where Hindu beliefs and the practice of “Transcendental 

Meditation” were being endorsed by Defendant CPS.

92. The above described conduct demonstrates how Defendants, by facilitating religious 

practices and rituals that are based in Hinduism, interfered with Plaintiff’s parental right to direct the 

religious education of his CPS-student child, in violation of Plaintiff’s rights under both the 

Establishment and Free Exercise Clauses.

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CLASS ACTION ALLEGATIONS

93. Plaintiffs bring all claims herein as class claims pursuant to Federal Rule of Civil 

Procedure 23. The requirements of Federal Rules of Civil Procedure 23(a), (b)(2), and (b)(3) are 

met with respect to the class defined below.

A. Class Definition(s)

94. The (b)(2) Injunctive and Declaratory Relief Class consists of:

All persons who are CPS students, CPS teachers, parents or legal 

guardians of CPS students directly associated with any CPS school 

facilitating the “Quiet Time” program, or any other program involving the 

practice of “Transcendental Meditation.”

95. The Three (b)(3) Sub-Classes consist of:

All students who attended a CPS school during a period when the school 

facilitated the “Quiet Time” program.

All teachers at CPS schools who were required to accommodate, endorse, 

facilitate, or enable the “Quiet Time” program at a CPS school where they 

were employed at the time.

All parents and legal guardians of students who attended a CPS school 

during a period when the school facilitated the “Quiet Time” program.

96. Plaintiffs reserve the right to amend the above Class and Sub-Class definitions if further 

investigation and discovery indicates that the Class and Sub-Class definitions should be narrowed, 

expanded, or otherwise modified. Excluded from the Class and Sub-Classes are Defendants, any of 

their subsidiaries, affiliates, officers, directors, and members of such persons immediate families; 

also excluded are the presiding judge in this action and the judges’ immediate family.

97. Defendants’ collaboration in implementing and facilitating the “Quiet Time” program 

within certain CPS schools uniformly applied to all Class and Sub-Class members, so that common 

questions of law and fact predominate as to all members of the Class and Sub-Classes.

98. Plaintiffs believe that the potential number of Class and Sub-Class members exceeds 

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1,000 per year across the eight known CPS schools that hosted the “Quiet Time” program for one or 

more school years.

99. Questions of law and fact common to the Class and Sub-Classes include, among others, 

the following:

a. Whether the practice of “Transcendental Meditation,” and the “Quiet Time” program by 

extension, is fundamentally religious in nature;

b. Whether Defendants concealed from students, teachers, parents, and legal guardians, the 

“Quiet Time” program’s connection to practices and beliefs that are based in Hinduism;

c. Whether all Defendants were acting under color of law based upon their respective roles 

in implementing and facilitating the “Quiet Time” program within CPS schools;

d. Whether Defendants have acted or refused to act on grounds generally applicable to the 

Class and Sub-Classes; and

e. Whether Plaintiffs and other members of the Sub-Classes have been damaged, and if so, 

what is the proper measure of such damages?

100. The claims asserted by Plaintiffs are typical of the claims of the members of the 

Class and Sub-Classes, as the claims arise from the same course of conduct by Defendants, and the 

relief sought within the Class and Sub-Classes is common to the members of each.

101. The Class and Sub-Classes are manageable because Defendant CPS keeps records 

on each student, teacher, parent, and legal guardian. Identifying Class and Sub-Class members will 

therefore be manageable.

102. The Plaintiffs will fairly and adequately represent and protect the interests of the 

Class and each Sub-Class, and do not have interests adverse to the Class and Sub-Classes.

103. Plaintiffs and their counsel can fairly and adequately represent the Class and SubCase: 1:20-cv-04540 Document #: 35 Filed: 09/25/20 Page 16 of 23 PageID #:322
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Classes.

104. Allowing the prosecution of these claims as separate actions would create the risk of 

establishment of incompatible standards of conduct being imposed on Defendants; would risk 

needlessly duplicative results and protracted proceedings; is inconsistent with the portion of the 

Class claim that seeks injunctive or declaratory relief; and is inappropriate because common 

questions of law or fact predominate over questions affecting only individual members of the 

Class and Sub-Classes.

COUNT I

VIOLATION OF THE ESTABLISHMENT AND FREE EXERCISE CLAUSES

(First Amendment)

(All Defendants)

105. Plaintiffs incorporate Paragraphs 1–104 as if fully restated here.

106. The Establishment and Free Exercise Clauses of the First Amendment to the United 

States Constitution provide that “Congress shall make no law respecting an establishment of 

religion, or prohibiting the free exercise thereof.” These prohibitions apply equally to the official 

acts of local governmental entities, including the Chicago Public Schools and its officers and 

employees, through the Due Process Clause of the Fourteenth Amendment to the United States 

Constitution.

107. The Chicago Public Schools’ practice of facilitating the “Quiet Time” program 

within certain CPS schools violates the Establishment and Free Exercise Clauses for all the reasons 

that follow.

108. CPS’ practice coerces students and others to engage in religious practices and rituals 

that are based in Hinduism, and thus violates both the Establishment Clause and the Free Exercise 

rights of the students and teachers.

109. CPS’ practice communicates a message that the District endorses and favors the 

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Hindu belief system and the practice of “Transcendental Meditation.”

110. CPS’ practice excessively entangles the government with religion, and leads to 

religious divisiveness in CPS schools and within the community.

111. CPS’ practice causes taxpayer funds to support the practice of “Transcendental 

Meditation” and the propagation of the religious views specific to “Transcendental Meditation.”

112. CPS also violated the Establishment and Free Exercise Clauses by making 

participation in the “Quiet Time” program effectively mandatory for all students and teachers at 

certain CPS schools.

113. CPS students and teachers were told by school officials that all students must 

participate in the “Quiet Time” program.

114. Students who did not want to participate in the “Quiet Time” program were warned 

that their failure to participate could impact their grades and disqualify them from participating in 

their respective graduation ceremonies.

115. Certified “Transcendental Meditation” instructors were presented to students as 

authority figures, and permitted to interact with students in private, without adequate oversight from 

CPS employees.

116. Certified “Transcendental Meditation” instructors repeatedly pressured students to 

participate in the “Quiet Time” program.

117. Certified “Transcendental Meditation” instructors targeted certain students, due to 

their popularity with peers, for the purpose of trying to influence other students to participate in the 

“Quiet Time” program.

118. Certified “Transcendental Meditation” instructors offered incentives to students in 

exchange for participation in the “Quiet Time” program, in the form of food, money, and other 

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special privileges.

119. These actions undertaken by the certified “Transcendental Meditation” instructors 

had the cumulative effect of creating an environment that pressured students to engage in religious 

practices against their wills.

120. By violating the Establishment and Free Exercise Clauses as set forth above, CPS 

has injured Plaintiffs, the Class, and the respective Sub-Classes, and threatens continued or future 

injury to Plaintiffs, the Class, and the respective Sub-Classes.

121. By violating the Establishment and Free Exercise Clauses as set forth above, CPS 

has, under color of statutes, ordinances, regulations, policies, custom, or usage, deprived or 

threatened to deprive Plaintiffs of rights secured by the First and Fourteenth Amendments to the 

United States Constitution, entitling them to a remedy under 42 U.S.C. § 1983.

122. By collaborating with CPS to implement the “Quiet Time” program within CPS 

schools, the David Lynch Foundation and the University of Chicago jointly participated in the 

constitutional deprivation against Plaintiffs.

123. Implementation of the “Quiet Time” program within CPS schools has caused 

Plaintiffs, members of the Class, and members of the respective Sub-Classes to experience anger 

and anxiety over personal salvation. The program has pressured and coerced students and teachers 

to engage in religious practices that are contrary to their personal beliefs and the religious 

instruction provided by parents, legal guardians, and their respective faith communities.

COUNT II

VIOLATION OF ILLINOIS RELIGIOUS FREEDOM RESTORATION ACT

(775 ILCS 35/1, et seq.)

(All Defendants)

124. Plaintiffs incorporate Paragraphs 1–123 as if fully restated here.

125. Under the Illinois Religious Freedom Restoration Act, the “[g]overnment should not 

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substantially burden the exercise of religion without compelling justification.” 775 ILCS 

35/10(a)(3).

126. The joint actions of Defendants have substantially burdened the religious exercise 

rights of CPS students, CPS teachers, and the parents and legal guardians of CPS students.

127. The implementation and facilitation of the “Quiet Time” program within CPS 

schools was neither in furtherance of a compelling governmental interest nor the least restrictive 

means of furthering a compelling governmental interest.

JURY DEMAND

128. Plaintiffs demand a trial by jury on all the issues so triable.

RELIEF REQUESTED

129. Plaintiffs incorporate Paragraphs 1–128 as if fully restated here.

130. Plaintiffs and the members of the Class and Sub-Classes respectfully request that 

the Court certify this action as a Class action under Federal Rules of Civil Procedure 23(b)(2) 

and (b)(3).

131. Plaintiffs and the Class respectfully request a declaratory judgment that the practice 

of “Transcendental Meditation,” and the “Quiet Time” program by extension, is fundamentally 

religious in nature.

132. Plaintiffs and the Class respectfully request a preliminary injunction barring CPS 

from continuing to facilitate the “Quiet Time” program or any other program involving the practice 

of “Transcendental Meditation,” within or through any CPS school, either in-person or virtually. 

Plaintiffs further request a permanent injunction barring CPS from facilitating the “Quiet Time” 

program, or any other program involving the practice of “Transcendental Meditation,” within or 

through any CPS school at any point in the future, either in-person or virtually.

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133. Plaintiffs and the Class respectfully request a preliminary injunction barring the 

David Lynch Foundation from engaging in any further attempts to establish the “Quiet Time” 

program or any other program involving the practice of “Transcendental Meditation,” within or 

through any CPS school, either in-person or virtually. Plaintiffs further request a permanent 

injunction barring the David Lynch Foundation from engaging in any attempts to establish the 

“Quiet Time” program, or any other program involving the practice of “Transcendental 

Meditation,” within or through any CPS school at any point in the future, either in-person or 

virtually.

134. Plaintiffs and the Class respectfully request a preliminary injunction barring the 

University of Chicago from conducting any research projects involving implementing the “Quiet 

Time” program or any other program involving the practice of “Transcendental Meditation,” within 

or through any CPS school, either in-person or virtually. Plaintiffs further request a permanent 

injunction barring the University of Chicago from conducting any research projects involving 

implementing the “Quiet Time” program, or any other program involving the practice of 

“Transcendental Meditation,” within or through any CPS school at any point in the future, either inperson or virtually.

135. Plaintiffs and the Class respectfully request a declaratory judgment that facilitating, 

establishing, implementing, or reimplementing the “Quiet Time” program, or any other program 

involving the practice of “Transcendental Meditation,” within or through any CPS school, either inperson or virtually, violates the United States Constitution. Plaintiffs further request a declaratory 

judgment that each named Defendant violated the constitutional rights of Plaintiffs through their 

collaborative efforts to facilitate the “Quiet Time” program within or through CPS schools, by 

pressuring students and teachers to participate in the “Quiet Time” program against their wills, and 

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by failing to adequately monitor and supervise the non-CPS certified “Transcendental Meditation” 

instructors running the “Quiet Time” program. Plaintiffs further request a declaratory judgment that 

each named Defendants’ respective involvement in facilitating and implementing the “Quiet Time” 

program within or through CPS schools constituted a violation of the Illinois Religious Freedom 

Restoration Act.

136. Plaintiffs and their respective Sub-Classes seek an order awarding them 

compensatory damages for the mental anguish and emotional distress suffered in connection with 

the constitutional deprivations suffered at the hands of the named Defendants. Alternatively, 

Plaintiffs and their respective Sub-Classes seek an order awarding them nominal damages for 

violations of their constitutional rights.

137. Plaintiffs and their respective Sub-Classes seek an order awarding them damages for 

violations of the Illinois Religious Freedom Restoration Act.

138. Plaintiffs and their respective Sub-Classes also seek an order awarding them 

punitive damages against Defendants The David Lynch Foundation and The University of Chicago.

139. Plaintiffs also request an order awarding them the costs of this action, including 

attorneys’ fees and expenses, under 42 U.S.C. § 1988 and 775 ILCS 35/20.

140. Plaintiffs, the Class, and the Sub-Classes also request any other relief as the Court 

deems appropriate and just.

Dated: September 14, 2020 Respectfully submitted,

SEPARATION OF HINDUISM FROM 

OUR SCHOOLS, CIVIL LIBERTIES 

FOR URBAN BELIEVERS, AMONTAE 

WILLIAMS, DASIA SKINNER, and 

DARRYL WILLIAMS

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John W. Mauck (#1797328) By: s/ John W. Mauck

Terry S. Lu (#6313383) One of their attorneys

MAUCK & BAKER, LLC

One North LaSalle Street, Suite 600

Chicago, Illinois 60602

Telephone: (312) 726-1243

Facsimile: (866) 619-8661

D:\M&B\3845 Transcendental Meditation\Pleadings\20200911_Class Action Complaint_final.docx

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