Electronic copy available at: http://ssrn.com/abstract=1851125

CUMBERLANDLAWREVIEW

RAY RUSHTON DISTINGUISHED LECTURERSERIES: EVANGELISM/PROSELYTISM ANDINTERNATIONAL RELIGIOUS LIBERTIES

PRIMER ON THE RIGHTS AND WRONGS OF PROSELYTISM

JOHN WITTE, JR.

Reprinted fromCUMBERLAND LAW REVIEW

Volume 31, Number 3Copyright © 2001, Cumberland Law Review

Cumberland School of Law Volume 31 No. 3Samford University 2000-2001

Electronic copy available at: http://ssrn.com/abstract=1851125

A PRIMER ON THE RIGHTS AND WRONGS OF PROSELYTISMJOHN WITTE, JR.*

INTRODUCTIONThe problem of proselytism is one of the great ironies of the

democratic revolution of the modern world. In the last third ofthe twentieth century, more than thirty new democracies wereborn around the world. More than 150 major new national, re-gional, and international instruments on religious liberty wereforged. Many of these instruments are replete with generousprotections of liberty of conscience and freedom of religiousexercise, guarantees of religious pluralism, equality, non-discrimination, and several other special protections and enti-tlements for religious individuals and religious groups.1

On the one hand, the modern human rights revolution hashelped to catalyze a great awakening of religion around theglobe. In regions newly committed to democracy and humanrights, ancient faiths once driven underground by autocraticoppressors have sprung forth with new vigor. In the formerSoviet bloc, for example, numerous Buddhist, Christian, Hindu,Jewish, Muslim, and other faiths have been awakened along-side a host of exotic goddess, naturalist, and personality cults.2

Jonas Robitscher Professor of Law and Ethics; Director of Law and ReligionProgram, Emory University. B.A. 1982, Calvin College; J.D. 1985, Harvard LawSchool. This essay is drawn largely from the preface to SHARING THE BOOK: RELIGIOUSPERSPECTIVES ON THE RIGHTS AND WRONGS OF PROSELYTISM xi-xviii (John Witte, Jr. &Richard C. Martin eds., 1999) [hereafter SHARING THE BOOK] and section IV of my ADickensian Era of Religious Rights: An Update on Religious Human Rights in Global Per-spective, 42 WM. & MARY L. REV. 707, 758-61 (2001).

1 See NATAN LERNER, RELIGION, BELIEF, AND INTERNATIONAL HUMAN RIGHTS129-147 (2000); RELIGION AND HUMAN RIGHTS: BASIC DOCUMENTS (Tad Stahnke & J.Paul Martin eds., 1998) [hereafter RELIGION AND HUMAN RIGHTS] (for a good samplingof international and local legal documents on religious liberty); see also FREEDOM OFRELIGION AND BELIEF: A WORLD REPORT (Kevin Boyle & Juliet Sheen eds., 1997);MALCOLM D. EVANS, RELIGIOUS LIBERTY AND INTERNATIONAL LAW IN EUROPE (1997)(for analysis).

2 See PROSELYTISM AND ORTHODOXY IN RUSSIA: THE NEW WAR FOR SOULS (JohnWitte, Jr. and Michael Bourdeaux eds., 1999) [hereafter PROSELYTISM AND

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In post-colonial and post-revolutionary Africa, these samemainline religious groups have come to flourish in numerousconventional and inculturated forms alongside a bewilderingarray of traditional groups.3 In Latin America, the humanrights revolution has not only transformed long-standingCatholic and mainline Protestant communities but also trig-gered the explosion of numerous new Evangelical, Pentecostal,and traditional movements.4 Many parts of the world haveseen the prodigious rise of a host of new or newly mintedfaiths — Adventists, Bahi'as, Hare Krishnas, Jehovah's Wit-nesses, Mormons, Scientologists, Unification Church members,among many others — some wielding ample material, political,and media power.5 Religion today has become the latest"transnational variable."6

On the other hand, in parts of Russia, Eastern Europe, Af-rica, and Latin America, the human rights revolution hasbrought on something of a new war for souls between indige-nous and foreign religious groups. With the recent politicaltransformations of these regions, foreign religious groups weregranted rights to enter these regions for the first time in dec-ades. In the 1980s and 1990s, they came in increasing numbersto preach their faiths, to offer their services, and to convert newsouls. Initially, local religious groups —Orthodox, Catholic,Protestant, Sunni, Shi'ite, and traditional — welcomed these for-eigners, particularly their foreign co-religionists with whomthey had lost contact for many decades. Today, local religiousgroups have come to resent these foreign religions, especiallythose from North America and Western Europe who assume ademocratic human rights ethic. Local religious groups resentthe participation in the marketplace of religious ideas that de-mocracy assumes. They resent the toxic waves of materialism

ORTHODOXY].3 See HUMAN RIGHTS IN AFRICA: CROSS-CULTURAL PERSPECTIVES (Abdullah!

Ahmed An-Na'im & Frances Deng eds., 1990); PROSELYTIZATION AND COMMUNALSELF-DETERMINATION IN AFRICA (Abdullah! Ahmed An-Na'im ed., 1999); Symposium,The Problem of Proselytism in Southern Africa, 14 EMORY INT'L. L. REV. (2000).

4 See RELIGIOUS FREEDOM AND EVANGELIZATION IN LATIN AMERICA: THECHALLENGE OF PLURALISM (Paul E. Sigmund ed., 1999).

5 See NEW RELIGIOUS MOVEMENTS IN EUROPE (Helle Meldgaard & Johannes Aa-gaard eds., 1997); NEW RELIGIONS AND NEW RELIGIOSITY (Eileen Braker & Margit War-burg eds., 1998); Jonathan Luxmoore & Jolanta Babiuch-Luxmoore, New Myths for Old:Proselytism and Transition in Post-Communist Europe, 36 J. ECUMENICAL STUD. 43-64(1999).

6 Susanne Hoeber Rudolph, Introduction: Religion, States, and Transnational CivilSociety, in TRANSNATIONAL RELIGION AND FADING STATES 1-19 (Susanne Hoeber Ru-dolph & James Piscatori eds., 1997).

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and individualism that democracy inflicts. They resent themassive expansion of religious pluralism that democracy en-courages. They resent the extravagant forms of religiousspeech, press, and assembly that democracy protects.7

A new war for souls has thus broken out in these regions. Itis a war to reclaim the traditional cultural and moral souls ofthese new societies and a war to retain adherence and adher-ents to the indigenous faiths. In part, this is a theological war,as rival religious communities have begun actively to demonizeand defame each other and to gather themselves into ever moredogmatic and fundamentalist stands. The ecumenical spirit ofthe previous decades is giving way to sharp new forms of reli-gious balkanization. In part, this is a legal war, as local reli-gious groups have begun to conspire with their political lead-ers to adopt statutes and regulations restricting the constitu-tional rights of their foreign religious rivals. Beneath shiny con-stitutional veneers of religious freedom for all and unqualifiedratification of international human rights instruments, severalcountries of late have passed firm new anti-proselytism laws,cult registration requirements, tighter visa controls, and vari-ous discriminatory restrictions on new or newly arrived relig-ions.

Hence the modern problems of proselytism: How does thestate balance one's community right to exercise and expand itsfaith versus another person's or community's right to be leftalone to its own traditions? How does the state protect the jux-taposed rights claims of majority and minority religions or offoreign and indigenous religions? How does the state craft ageneral rule to govern multiple theological understandings ofconversion or change of religion? These are not new questions.They confronted the drafters of the international bill of rightsfrom the very beginning. Today some of the compromises of1948 and 1966 have begun to betray their limitations.

I. THE PROBLEM OF CONVERSION

One side of the modern problem of proselytism is the prob-lem of competing theological and legal understandings of con-version or change of religion.8 How does a state craft a legal

7 See supra notes 2-4; Symposium, Pluralism, Proselytism, and Nationalism in East-ern Europe, 36 J. ECUMENICAL STUD. 1 (1999).

8 See Natan Lerner, Proselytism, Change of Religion, and International HumanRights, 12 EMORY INT'L. L. REV. 477 (1998); LERNER, supra note 1, at 80-118; EVANS,

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rule that at once respects and protects the sharply competingunderstandings of conversion among the religions of the Book?Most Western Christians have easy conversion into and out ofthe faith.9 Most Jews have difficult conversion into and out ofthe faith.10 Most Muslims have easy conversion into the faith,but allow for no conversion out of it, at least for prominentmembers.11 Whose rites get rights? Moreover, how does onecraft a legal rule that respects Orthodox, Hindu, Jewish, or tra-ditional groups that tie religious identity not to voluntarychoice but to birth and caste, blood and soil, language and eth-nicity, sites and sights of divinity?12

On the issue of conversion or change of religion, the majorinternational human rights instruments largely accept the reli-gious voluntarism common among libertarian and WesternChristian groups. The 1948 Universal Declaration of HumanRights included an unequivocal guarantee: "Everyone has theright to freedom of thought, conscience, and religion: this rightincludes freedom to change his religion or belief . . . ,"13 The1966 International Covenant on Civil and Political Rights,whose preparation was more highly contested on this issue,became a bit more tentative: "This right shall include freedomto have or to adopt a religion or belief of his choice . . . ,"14 The1981 Declaration on the Elimination of All Forms of Intoleranceand of Discrimination Based on Religion or Belief repeated thissame tentative language.15 The dispute over the right to con-version contributed greatly to the long delay in the productionof this instrument and to the number of dissenters to it. The1989 Vienna Concluding Document did not touch the issue atall but simply confirmed "the freedom of the individual to pro-fess and practice religion or belief" before turning to a robust

supra note 1, at 201, 221; J.A. Walkate, The Right of Everyone to Change his Religion orBelief: Some Observations, 30 NETHERLANDS INT'L. L. REV. 146 (1983).

9 See Joel A. Nichols, Mission, Evangelism, and Proselytism in Christianity:Mainline Conceptions as Reflected in Church Documents, 12 EMORY INT'L. L. REV. 563-656(1998).

10 See David Novak, Proselytism and Conversion in Judaism, in SHARING THE BOOK,supra note *, at 17-44.

11 See Donna E. Arzt, The Treatment of Religious Dissidents under Classical and Con-temporary Islamic Law, in RELIGIOUS HUMAN RIGHTS IN GLOBAL PERSPECTIVE: RELIGIOUSPERSPECTIVES 387-453 (John Witte, Jr. & Johan D. Van Der Vyver eds., 1996).

12 See, e.g., Michael J. Sandel, Freedom of Conscience or Freedom of Choice, inARTICLES OF FAITH, ARTICLES OF PEACE 74 (James Davison Hunter & Os Guinness eds.,1990).

13 EVANS, supra note 1, at 183.14 Id. at 199-200.15 Id. at 227-28.

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rendition of religious group rights.16 Today, the issue has be-come more divisive than ever as various soul wars have brokenout, especially between and within Christian and Muslimcommunities around the globe.

"[A] page of history is worth a volume of logic," OliverWendell Holmes, Jr. once said.17 On an intractable legal issuesuch as this, recollection might be more illuminating than rati-ocination. It is discomfiting, but enlightening, for WesternChristians to remember that the right to enter and exit the re-ligion of one's choice was born in the West only after centuriesof cruel experience. To be sure, a number of the early churchfathers considered the right to change religion as essential tothe notion of liberty of conscience, and such sentiments havebeen repeated and glossed continuously over the centuries.However, in practice, the Christian Church largely ignoredthese sentiments for centuries. As the medieval CatholicChurch refined its rights structures in the twelfth and thir-teenth centuries, it also routinized its religious discrimination,reserving its harshest sanctions for heretics. The faithful com-municant enjoyed full rights. Jews and Muslims enjoyed fewerrights but full rights if they converted to Christianity. Here-tics—those who voluntarily chose to leave the faith —enjoyedstill fewer rights and had little opportunity to recover themeven after full confession. Indeed, at the height of the Inquisi-tion in the fifteenth century, heretics faced not only severe re-strictions on their persons, properties, and professions but alsounspeakably cruel forms of torture and punishment.18 Simi-larly, as the Lutheran, Calvinist, and Anglican churches born ofthe Protestant Reformation routinized their establishments inthe sixteenth and seventeenth centuries, they inflicted all man-ner of repressive civil and ecclesiastical censures —savage tor-ture and execution in a number of instances —on those whochose to deviate from established doctrine.19

The recovery and elaboration of earlier patristic concepts

16 Concluding Document of the Vienna Meeting of Representatives of the Par-ticipating States of the CSCE, Principle 16, reprinted in RELIGION AND HUMAN RIGHTS,supra note 1, at 155.

17 N.Y. Trust Co. v. Eisner, 256 U.S. 345, 349 (1921).18 See generally PERSECUTION AND TOLERATION (W.J. Sheils ed., 1984); JAMES

PARKES, THE JEW IN THE MEDIEVAL COMMUNITY: A STUDY OF HIS POLITICAL ANDECONOMIC SITUATION (2d ed., 1976); SOLOMON GRAYZEL, THE CHURCH AND THE JEWSIN THE XIIITH CENTURY (1933).

19 See RELIGIOUS LIBERTY IN WESTERN THOUGHT (Noel B. Reynolds & W. ColeDurham, Jr. eds., 1996).

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of liberty of conscience as well as the slow expansion of newProtestant and Catholic theologies of religious voluntarismhelped to end this practice. However, it was also the new pos-sibilities created by the frontier and by the colony that helpedto forge the Western understanding of the right to change relig-ion. Rather than stay at home and fight for one's faith, the dis-senter found it became easier to move away quietly to the fron-tier, or later to the colony, to be alone with his conscience andhis co-religionists. Instead of tying the heretic to the rack or thestake, the establishment found it easier to banish him quicklyfrom the community with a strict order not to return. Suchpragmatic tempering of the treatment of heretics and dissenterseventually found theological justification. By the later sixteenthcentury, it became common in the West to read of the right andthe duty of the religious dissenter to emigrate physically fromthe community whose faith he no longer shared.20 In the courseof the next century, this right of physical emigration from areligious community was slowly transformed into a generalright of voluntary exit from a religious faith and community.American writers, many of whom had voluntarily left theirEuropean faiths and territories to gain their freedom, particu-larly embraced the right to leave —to change their faith, toabandon their blood, soil and confession, to reestablish theirlives, beliefs, and identities afresh —as a veritable sine qua nonof religious freedom.21 This understanding of the right tochoose and change religion —patristic, pragmatic, and Protes-tant in initial inspiration — has now become an almost universalfeature of Western understandings of religious rights.

To tell this peculiar Western tale is not to resolve current le-gal conflicts over conversion but is to suggest that even hardand hardened religious traditions can and do change over time,in part out of pragmatism, in part out of fresh appeals to an-cient principles long forgotten. Even those schools of jurispru-dence within Shi'ite and Sunni communities that have been the

20 The most famous formulation of the right and duty of the dissenter to emi-grate peaceably from the territory whose religious establishment he cannot abide,comes in the Peace of Augsburg (1555), and its provisions are repeated in the Edict ofNantes (1598) and the Religious Peace of Westphalia (1648). CHURCH AND STATETHROUGH THE CENTURIES: A COLLECTION OF HISTORICAL DOCUMENTS WITHCOMMENTARIES 164-198 (Sidney Z. Ehler & John B. Morrall eds., 1954).

21 See generally Max L. Stackhouse & Deirdre King Hainsworth, Deciding for God:The Right to Convert in Protestant Perspectives, in SHARING THE BOOK, supra note *, at201-230; JOHN WITTE, JR., RELIGION AND THE AMERICAN CONSTITUTIONAL EXPERIMENT:ESSENTIAL RIGHTS AND LIBERTIES 96-100 (2000) (on the nineteenth century Americanexperience).

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sternest in their opposition to a right to conversion from thefaith, do have resources in the Qur'an, in the early develop-ment of Shari'a, and in the more benign policies of other con-temporary Muslim communities, to rethink their theologicalpositions.22

Moreover, the Western story suggests that there are half-way measures, at least in banishment and emigration, that helpto blunt the worst tensions between a religious group's right tomaintain its standards of entrance and exit and an individual'sliberty of conscience to come and go. Not every heretic needs tobe executed. Not every heretic needs to be indulged. It is onething for a religious tradition to insist on executing its chargesof heresy when a mature adult, fully aware of the consequencesof his choice, voluntarily enters a faith, and then later seeks toleave. In that case, group religious rights must trump individ-ual religious rights —with the proviso that the religious grouphas no right to violate or to solicit violation of the life and limbof the wayward member. It is quite another thing for a reli-gious tradition to press the same charges of heresy againstsomeone who was born into, married into, or coerced into thefaith, and now, upon opportunity for mature reflection, volun-tarily chooses to leave. In that case, individual religious rightstrump group religious rights.

Where a religious group exercises its trump by banishmentor shunning, and the apostate voluntarily chooses to return, hedoes so at his peril. He should find little protection in state lawwhen subject to harsh religious sanctions unless the religiousgroup threatens or violates his or his family's life or limb.Where a religious individual exercises his trump by emigra-tion, and the group chooses to pursue him, it does so at itsperil. It should find little protection from state law whencharged with tortuous or criminal violations of the individual.

II. THE PROBLEM OF PROSELYTISM

The corollary to the problem of conversion is the problem ofproselytism —the efforts taken by individuals or groups to seek

22 See Farid Esack, Muslims Engaging the Other and the Humanum, in SHARING THEBOOK, supra note *, at 118 passim; Richard C. Martin, Conversion to Islam by Invitation:Proselytism and the Negotiation of Identity in Islam, in SHARING THE BOOK, supra note *, at95 passim; Arzt, supra note 11; Donna E. Arzt, Jihad for Hearts and Minds: Proselytizingin the Qur'an and First Three Centuries of Islam, in SHARING THE BOOK, supra note *, at 79passim.

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the conversion of another. On this issue the international hu-man rights instruments provide somewhat more nuanced di-rection.23 Article 18 of the 1966 International Covenant on Civiland Political Rights protects a person's "freedom, either indi-vidually or in community with others and in public or private,to manifest his religion or belief in worship, observance, practiceand teaching."2* However, the same article allows such manifes-tation of religion to be subject to limitations that "are pre-scribed by law and are necessary to protect public safety, order,health, or morals or the fundamental rights and freedoms ofothers."25 It prohibits outright any "coercion which would im-pair [another's right] to have or to adopt a religion or belief ofhis choice."26 It also requires the State Parties "to have respectfor the liberty of parents . . . to ensure the religious and moraleducation of their children in conformity with [the parents']own convictions" — a provision underscored and amplified inmore recent instruments and cases on the rights of parents andchildren.27

Similarly, Article 19 of the same 1966 Covenant protects the"freedom to seek, receive and impart information and ideas of allkinds, regardless of frontiers, either orally, in writing, or inprint, in the form of art, or through any other media of hischoice."28 In addition, Article 19 allows legal restrictions thatare necessary for "respect of the rights or reputations of others"or for "the protection of national security or of public order(ordre public), or of public health or morals."29 As a further limi-tation on the rights of religion and religious expression guaran-teed in Articles 18 and 19, Article 26 of the 1966 Covenant pro-hibits any discrimination on grounds of religion. Additionally,Article 27 guarantees to religious minorities "the right . . . toenjoy their own culture [and] to profess and practice their ownreligion "30

23 LERNER, supra note 1, at 80-118; Tad Stahnke, Proselytism and the Freedom toChange Religion in International Human Rights Law, 1999 BYU L. REV. 251, 269-74 (1999).

24 International Covenant on Civil and Political Rights (hereinafter "ICCPR"), re-printed in RELIGION AND HUMAN RIGHTS, supra note 1, at 74 (emphasis added).

25 Id.

26 Id.27 Id.; see also UNITED NATIONS: CONVENTION ON THE RIGHTS OF THE CHILD 28

I.L.M. 1448 (1989).28 ICCPR, reprinted in RELIGION AND HUMAN RIGHTS, supra note 1, at 74 (empha-

sis added).29 Id.30 Id.; see also Declaration on The Rights of Persons Belonging to National or Eth-

nic, Religious, and Linguistic Minorities, reprinted in LERNER, supra note 1, at 140 and

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The literal language of the mandatory 1966 Covenant and itsamplification in more recent instruments and cases certainlyprotects the general right to proselytize —understood as theright to "manifest," "teach," "express," and "impart" religiousideas for the sake, among other things, of seeking the conver-sion of another. The Covenant provides no protection for coer-cive proselytism. At minimum, the Covenant bars physical ormaterial manipulation of the would-be convert and in somecontexts even more subtle forms of deception, enticement, andinducement to convert. The Covenant also casts serious suspi-cion on any proselytism among children or among adherents tominority religions. However, outside of these contexts, theCovenant regards the religious expression inherent in prosely-tism as no more suspect than political, economic, artistic, orother forms of expression and entitled to the same protection.

Such rights to religion and religious expression are not ab-solute. The 1966 Covenant and its progeny allow for legal pro-tections of "public safety, order, health, or morals," "nationalsecurity" and "the rights or reputations of others," particularlyminors and minorities.31 All such legal restrictions on religiousexpression must always be imposed without discriminationagainst any religion and with due regard for the general man-dates of necessity and proportionality— the rough internationalanalogues to the compelling state interest and least restrictivealternative prongs of the strict scrutiny test of American consti-tutional law. General time, place, and manner restrictions thatare necessary, proportionate, and applied without discrimina-tion against any religion might be apt. However, categoricalcriminal bans on proselytism or patently discriminatory licens-ing or registration provisions on proselytizing faiths are aprima facie violation of the religious rights of the prosely-tizer —as has been clear in the United States since Cantivell v.Connecticut^2 and in the European community since Kokkinakisv. Greece?3

To my mind, the preferred solution to the modern problemof proselytism is not so much further state restriction but fur-ther self-restraint on the part of both local and foreign religiousgroups. Again, the 1966 International Covenant on Civil andPolitical Rights provides some useful cues. Article 27 of the

analyzed in id. at 33-35.31 ICCPR, reprinted in RELIGION AND HUMAN RIGHTS, supra note 1, at 74.32 310 U.S. 296 (1940).33 260-A Eur. Ct. H. R. (ser. A) 18 (1993).

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Covenant reminds us of the special right of local religiousgroups, particularly minorities, "to enjoy their own culture,and to profess and practice their own religion." Such languagemight well empower and encourage vulnerable minority tradi-tions to seek protection from aggressive and insensitive prose-lytism by missionary mavericks and drive-by crusaders whohave emerged with alacrity in the past two decades. Article 27might even have supported a moratorium on proselytism for afew years in places like Russia so that local religions, even themajority Russian Orthodox Church, would have had some timeto recover from nearly a century of harsh oppression that de-stroyed most of its clergy, seminaries, monasteries, literature,and icons. However, Article 27 cannot permanently insulatelocal religious groups from interaction with other religions. Noreligious and cultural tradition can remain frozen. For localtraditions to seek blanket protections against foreign prosely-tism, even while inevitably interacting with other dimensionsof foreign cultures, is ultimately a self-defeating policy. Such apolicy would stand in sharp contrast to cardinal human rightsprinciples of openness, development, and choice. Even more,the demand for blanket protections belies the very meaning ofbeing a religious tradition. As Jaroslav Pelikan reminds us:"Tradition is the living faith of the dead, traditionalism is thedead faith of the living."34

Article 19 of the Covenant reminds us further that the rightto expression, including religious expression, "carries with itspecial duties and responsibilities."35 One such duty, it wouldseem, is to respect the religious dignity and autonomy of theother and to expect the same respect for one's own dignity andautonomy. This is the heart of the Golden Rule. It encouragesall parties, especially foreign proselytizing groups, to negotiateand adopt voluntary codes of conduct that espouse restraintand respect of others. This requires continued cultivation ofinterreligious dialogue and cooperation —the happy hallmarksof the modern ecumenical movement and of the growing em-phasis on comparative religion and globalization in our semi-naries. It also requires guidelines of prudence and restraint thatevery foreign mission board would do well to adopt and en-force. These guidelines would include: knowing and appreciat-ing the history, culture, and language of the proselytizee,

34 JAROSLAV PELIKAN, THE VINDICATION OF TRADITION 65 (1984).35 ICCPR, reprinted in RELIGION AND HUMAN RIGHTS, supra note 1, at 74.

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avoiding Westernization of the Gospel and First Amendmenti-zation of politics, dealing honestly and respectfully with theo-logical and liturgical differences, respecting and advocating thereligious rights of all peoples, being Good Samaritans as muchas good preachers, proclaiming their Gospel both in word andin deed.36 Moratoria on proselytism might provide temporaryrelief, but moderation by proselytizers and proselytizees is themore enduring course.

56 See Anita Deyneka, Guidelines for Foreign Missionaries in the former Soviet Un-ion, in PROSELYTISM AND ORTHODOXY, supra note 2, at 331-340; Lawrence A. Uzzell,Guidelines for American Missionaries in Russia, in PROSELYTISM AND ORTHODOXY, supranote 2, at 323-330.