Malnak v. Yogi, 592 F.2d 197 (3d Cir. 1979)

Malnak v. Yogi, 592 F.2d 197, decided by the United States Court of Appeals for the Third Circuit in 1979, is the primary legal text itself, the appellate ruling that Transcendental Meditation's Science of Creative Intelligence course, as taught in New Jersey public schools, constituted religious instruction under the First Amendment despite the organization's own claims that the practice was secular science. Its strength is that it is the actual controlling appellate opinion, including Judge Adams's influential concurrence proposing functional criteria for what counts as a religion under the Constitution, so a claim about TM's legal classification or about how American courts have defined religion functionally can be checked against the Court's own reasoning. Its limit is that a legal ruling on First Amendment classification settles a constitutional question rather than describing Transcendental Meditation's own practice or teaching in any depth, so a claim about what TM practitioners actually do or believe needs a source on the practice itself.