a question of first impression for the federal circuit courts, although several federal district courts have addressed the issue, uniformly concluding that ERISA does not pre- empt such claims
evidences student's decision making about ways to go about complex activities (e.g., notes and gathers needed articles for community-based instruction, collects information about specific community-based recreation activities in order to arrange transportation, surveys class members to determine refreshments for class party, or orders own work sequence in community or school job for the day)
People for Legal and Non-Sectarian Schools (PLANS), based principally in San Francisco, U.S. and on the Web http://www.waldorfcritics.org PLANS' home page, campaigns against the public funding of Waldorf methods charter schools based on separation of church and state. According to the group, both independent Waldorf schools and public Waldorf methods charter schools teach anthroposophical content, that this content is religious, and that they disguise this to the public. PLANS filed federal suit in 1998 against two California public school districts, Sacramento City Unified School District and Twin Ridges Elementary School District, to halt the Waldorf methods educational programs implemented in two of their schools.