"This is not a church. It's a school and it's a public school. I have to do things that include every child. So what we do is celebrate winter," said Brown. The school did give presents to its students and allowed Christmas carols, along with Hanukkah songs and Kwanzaa songs. (Waterbury Republican-American, 12-3-09)

Lantern Road Elementary in Fishers, Indiana had a holiday show that aimed to teach inclusiveness through its second-grade program, according to principal Danielle Thompson. The show included segments about Christmas, Hanukkah, Ramadan, Las Posadas and Kwanzaa. School officials did take out a line that included "Allah is God" after American Family Association publicized the matter, prompting about 30 people to call the school with concerns. Thompson said that the change was made because no other deities were specifically named in the program. (IndyStar.com, 12-12-09)

A recent federal appeals court decision upholding a New Jersey school district's restrictions on the performance of holiday religious music also cited inclusiveness as a factor. Parent Michael Stratechuk argued that the South Orange-Maplewood district policy is hostile to religion and infringes upon his children's right to learn about religious music. The district encourages secular holiday songs such as "Rudolph the Red-nosed Reindeer" and "Winter Wonderland," while precluding songs like "Joy to the World" and "Silent Night." Stratechuk believes that because the school's song exclusion policy is based only on religion, it violates the First Amendment requirement that the government be neutral towards religion. The 3rd Circuit Court of Appeals in Philadelphia disagreed, and ruled that allowing only secular carols did not demonstrate hostility towards religion. "Certainly, those of us who were educated in the public schools remember holiday celebrations replete with Christmas carols, and possibly even Chanukah songs, to which no objection had been raised," states the opinion by U.S. Circuit Judge Dolores K. Sloviter. "Since then, the governing principles have been examined and defined with more particularity. Many decisions about how to best create an inclusive environment in public schools, such as those at issue here, are left to the sound discretion of the school authorities." (blogs.edweek.org, 11-24-09)