The United States Court of Appeals for the Eleventh Circuit addressed whether a public university could restrict a professor’s religious expressions during instructional time without infringing upon First Amendment rights.

[2][3] Phillip A. Bishop, an assistant professor of exercise physiology at the University of Alabama, occasionally shared his Christian beliefs during class sessions, framing them as his personal “bias.” In April 1987, he organized an optional after-class lecture titled “Evidences of God in Human Physiology,” which discussed the complexity of the human body and suggested divine creation over evolutionary processes.

[4] In response to these concerns, Carl Westerfield, Head of the Health, Physical Education, and Recreation Department, issued a memorandum instructing Bishop to cease interjecting religious beliefs during instructional periods and to stop holding optional classes presenting a “Christian perspective” on academic topics.

The university’s administration upheld these directives, emphasizing the need to prevent any appearance of endorsing religion, in line with the Establishment Clause.

The court emphasized that the university’s directives aimed to avoid the appearance of endorsing religion, thereby adhering to Establishment Clause requirements.