Minarcini v. Strongsville

Kurt Vonnegut’s apocalyptic novel Cat’s Cradle is not one of the most frequently challenged of challenged books, but it is an interesting example, both because of the motivations behind the attempted censorship of it, and because of the court decision that censorship led to.

First published in 1963, Cat’s Cradle is one of Vonnegut’s many satirical observations of the human condition. Using fiction as a metaphor for current events, it deals with the relationship between technology and society, religion and society, economic development, and the arms race. Ice-nine, a mysterious substance invented by scientists without thought to its consequences, is a transparent metaphor for nuclear weaponry.

The usual objections are unsupportable in this case. Some strong language appears, but is quite limited. The gerundive of the “F” word is rendered as “fugging,” which isn't much of a disguise, but must have made some censors happy. There are a few minor and very indirect references to sexual activity, but nothing approaching a description of any such act. Even though, operatically, everybody winds up dead in the end, there is no violence at all.

Objections to the book have more to do with its political and religious perspective. Its primary political stance is one against war, with some focus on the darker side of capitalism, although it is far from anti-American.  Oddly, Cat’s cradle is listed in N. J. Karolides’ volume Literature Suppressed on Political Grounds, rather than the companion volume, Literature Suppressed on Religious Grounds, by M. Bald. Vonnegut's well-known secularism is readily apparent in the text. Although carefully crafted as cynicism about the invented and fictional religion of Bokononism, it is clear that all religions are being portrayed as so much hokum.

In 1972, the School District of the City of Strongsville, Ohio, decided to remove Cat’s Cradle from classroom curricula and the school library, also taking action against Joseph Heller’s Catch-22. Unsurprisingly, some students and their parents, with the assistance of the ACLU, sued the district in a case known as Minarcini v. Strongsville City School District (541 F.2d 577, U.S. Court of Appeals, Sixth Circuit, 1976).  The school district won a first round, but lost on appeal.

Minarcini v. Strongsville anticipates later decisions such as Right to Read Defense Committee v. School Committee of the City of Chelsea (1978, 454 F. Supp. 703), Board of Education v. Pico (1982, 457 U.S. 853), Case v. Unified School District (1995, 908 F.Supp. 864), and Counts v. Cedarville School District (2003, 295 F.Supp.2d 996). In Minarcini the court acknowledged the broad power of school boards to regulate the informational content of schools, and cautioned that courts should not interfere with that power unless a board’s actions “directly and sharply implicate basic constitutional values.” Such a direct and sharp implication is exactly what the court found the board had committed, given the uncontested literary value of the challenged book, and the absence of any claim of obscenity (one of the few legitimate grounds for removing a book from a school library).

Even today, censorship proponents like to claim that removing a book from a library or classroom isn’t really censorship, since the removed book will remain available elsewhere. This ridiculous and self-serving redefinition of the term censorship has been done away with in a number of court cases, including this one. In Minarcini, the court accused the school board of attempting “to censor the school library," and wrote:

“Further, we do not think this burden is minimized by the availability of the disputed book in sources outside the school. Restraint on expression may not generally be justified by the fact that there may be other times, places, or circumstances available for such expression.”

The court’s final decision was:

“. . . to declare the School Board resolutions of August 19, 1972 and August 31, 1972, null and void as violative of the First Amendment to the United States Constitution and to direct the members of the Strongsville School Board to replace in the library the books with which these resolutions dealt . . .”