Anti-Semitism is a deadly hatred. Defendants either disagree with this statement or share in this hatred because, for years, they have stubbornly refused to remove anti-Semitic and anti-Israel materials from the history lessons that they teach in the high schools of the City of Newton. Despite significant community concerns, scholarly findings of anti-Jewish bias, and formal citizen requests for remedial action, Defendants have categorically and repeatedly refused to remedy the teaching of false and hateful stereotypes about Israel, Israelis, and the Jewish people. These refusals are not simply indecent and vile: they are also illegal under Massachusetts education and civil rights laws. Plaintiffs therefore bring this complaint for a writ of mandamus pursuant to G.L. c. 249, § 5, to compel Defendants to perform their mandatory, mandatory, non-discretionary duties under G.L. c. 71, §§ 37, 59 & 59B; G.L. c. 76, § 5; and 603 Mass. Code Regs. 26.05(1) & (2).
After seven Sisyphean years spent petitioning, begging, and pleading with Defendants to review their curricula for simplistic and demeaning generalizations of the Jewish religion and Israeli national origin, Plaintiffs have exhausted all avenues and are now at a complete loss for any alternative remedy. We ask the Court to end this continuing public injustice with an order 1) directing Defendants to perform their mandatory, non-discretionary duties under G.L. c. 71, §§ 37, 59 & 59B; G.L. c. 76, § 5 and 603 Mass. Code Regs. 26.05 (1 & 2); and 2) granting such other legal and equitable actions as the Court deems proper to ensure that the civil rights of Jewish and Israeli students in the City of Newton are protected under the civil rights laws of the Commonwealth.