California Parents for the Equalization of Educational Materials v. Torlakson, 267 F. Supp. 3d 1218

CAPEEM (an organization) and Hindu parents sued California State Board of Education officials and four school districts, alleging the K–12 History-Social Science Standards and the 2016 Framework discriminate against and denigrate Hinduism and endorse Abrahamic faiths.
Plaintiffs challenged both (a) the content of the Standards/Framework (e.g., emphasis on caste, alleged privileging of biblical content) and (b) aspects of the Framework adoption process (e.g., reliance on a South Asia Faculty Group report, disparate treatment of edit requests).
Relief sought: declaratory and injunctive relief under 42 U.S.C. § 1983 for violations of substantive due process, Establishment Clause, Free Exercise Clause, and Equal Protection.
Defendants moved to dismiss under Rule 12(b)(6); court took judicial notice of the Standards and Framework.
Court dismissed with prejudice: substantive due process, Free Exercise, and Equal Protection claims. Court denied dismissal of the Establishment Clause claim, allowing that claim to proceed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substantive due process — parental right to direct education	Parents claim curricula interfere with their liberty to direct children’s education.	Ninth Circuit precedent forecloses a substantive-due-process right to dictate public-school curriculum.	Dismissed with prejudice (Fields controls).
Free Exercise — curricular burden on religion	Curriculum compels students to learn derogatory material conflicting with Hindu beliefs, burdening exercise.	No allegation of an actual burden on religious practice; mere exposure or offense is insufficient.	Dismissed with prejudice (no substantial burden pleaded).
Establishment Clause — endorsement/disapproval of religion	Framework denigrates Hinduism (emphasizing caste) and treats Abrahamic faiths more favorably, conveying disapproval.	Curriculum has a secular purpose (teaching history); does not teach scripture as fact; no excessive entanglement.	Dismissal denied as to primary-effect prong — plausible that a reasonable sixth grader could perceive disapproval of Hinduism; claim proceeds.
Equal Protection — discrimination in content/process	State treated Hinduism worse in content and gave Hindu groups worse process treatment during adoption.	Equal Protection cannot be used to challenge curriculum content; adoption-process allegations are implausible or actually content challenges.	Dismissed with prejudice: content-based claim foreclosed by Monteiro; process allegations insufficiently pleaded.

Fields v. Palmdale School Dist., 427 F.3d 1197 (9th Cir.) (parents cannot dictate public-school curriculum)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient)
Lemon v. Kurtzman, 403 U.S. 602 (1971) (Establishment Clause Lemon test)
Brown v. Woodland Joint Unified Sch. Dist., 27 F.3d 1373 (9th Cir.) (curriculum adoption not excessive entanglement; evaluate primary effect in context)
Monteiro v. Tempe Union High Sch. Dist., 158 F.3d 1022 (9th Cir.) (Equal Protection not a vehicle to challenge curriculum content)
Larson v. Valente, 456 U.S. 228 (1982) (government shall not prefer one religious denomination over another)
Sch. Dist. of Abington Twp. v. Schempp, 374 U.S. 203 (1963) (teaching about religion objectively as part of secular program is permitted)
Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993) (neutrality and general applicability in Free Exercise analysis)
Employment Div., Dept. of Human Resources v. Smith, 494 U.S. 872 (1990) (neutral, generally applicable laws get rational-basis review)
Am. Family Ass’n v. City & Cty. of S.F., 277 F.3d 1114 (9th Cir.) (subjective chilling or offense is not a substantial Free Exercise burden)