Front matter
ion of Church and State
STEPHEN M. FELDMAN
PLEASE DON'T WISH ME A MERRY CHRISTMAS
Contents
Preface t. INTRODUCTION: DIFFERENT STORIES
A Story about the Ways of Power A Dominant Story about the Separation of Church and State
2. ORIGINS OF POWER: THE EMERGENCE OF CHRISTIANITY AND ANTISEMITISM
Preface
Many people have helped me in different ways during the writing of this book. I thank the numerous individuals who commented on various parts of the manuscript: Richard Delgado, Daniel Farber, John Garvey, Gary Minda, Mark Tushnet, Tom Wartenberg, Larry Backer, Morris Bernstein, Bill Hollingsworth, Lundy Langston, Marla Mansfield, Nick Rostow, Mark Brauner, Laura Feldman, and Virginia Lockman. I appreciate also the comments received from the participants at the 1994 Mid-South Philosophy Conference, where I presented some of my ideas on the postmodern concept of power. I especially thank Richard Delgado, Jean Stefancic, and Niko Pfund for including this project in the Critical America series from New York University Press. The financial support of the Faculty Summer Research Grant Program of the University of Tulsa College of Law helped create the time needed to work on the book. The librarians at the University of Tulsa College of Law—particularly Nanette Hjelm, Carol Arnold, and Rich Ducey—helped me enormously in obtaining resources needed for research. Finally, I thank my family, Laura, Mollie, and Samuel, for always being so wonderful, loving, and supportive.
An earlier version of chapter 10 appeared in the Iowa Law Review.
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Introduction
Different Stories
A STORY ABOUT THE WAYS OF POWER
I am Jewish.
In the fall of 1993, my four-year-old daughter began a prekindergarten program in an experimental public school in Tulsa, Oklahoma. That October, when my wife and I learned that the school, called the Mayo Demonstration School, had displayed and decorated a Christmas tree during the previous year, we sent the following letter to the principal:
Dear Ms. Erling:
As parents of a Mayo student, we request that the Mayo School refrain from celebrating any religious holidays. We realize that many public schools routinely celebrate religious holidays, particularly the Christian holidays of Christmas and Easter. Nonetheless, we hope that Mayo, because of its commitment to diversity and its status as a flagship institution of the public school system, will assume a position of leadership in this regard. Public school celebrations of holidays inevitably place children who belong to minority (non-Christian) religions in a dilemma. The children must choose between, on the one hand, conforming to the celebratory practices of the majority religion or, on the other hand, refusing to participate in an activity that most if not all of the other children perform. An adult facing such a dilemma might feel uncomfortable; a young child will likely suffer more intense injury. Such a child will, at a minimum, feel a distance and exclusion from the Mayo community, or worse, the child might risk overt ostracism from peers and a loss of self-esteem.
We believe that this unfortunate situation can be avoided simply by not celebrating any religious holidays. We understand that many individuals believe that certain activities—such as singing Christmas songs, participating in a Christmas play, telling Christmas stories, hunting for Easter eggs, and constructing or displaying symbols or ornaments, including a Christmas tree, Christmas tree decorations, a Santa Claus, or Easter eggs—are secular and merely recognize our American traditions. But from the perspective of a religious minority, these activities and symbols clearly denote Christian holidays; Christmas and Easter are most assuredly not secular and are not holidays for Judaism, Islam, Buddhism, or any other non-Christian religion. To us, the American traditions that should be recognized in the public schools are diversity, respect for difference, and the separation of religion from governmental institutions (including the public schools).
Possibly, many who sympathize with our concerns might respond by proposing that Mayo recognize the activities and symbols of minority religions as well as those of Christianity. For example, in December, it might be suggested that a Chanukah Menorah (candle holder) and a Kwanzaa Kinara (candle holder) be placed alongside a Christmas tree. Unfortunately, such pluralistic displays—however well-intentioned—fail to alleviate the difficulties generated by any celebrations of religious holidays in the public schools. Pluralistic holiday displays are unlikely to protect children of minority religions from the psychological and educational injuries discussed above. Any religious activities or displays inevitably will strain the Mayo community by forcing children to choose between participating in religious activities or risking exclusion and self-doubt. Moreover, such pluralistic displays, often consisting of token symbols of many religious holidays, trivialize the significance of each child’s heritage. And most important, in an educational setting, these displays tend to confuse children by denigrating the important differences between religions. The celebrations of distinctive religions rarely can be equated: Chanukah is not the Jewish Christmas (Chanukah is a relatively minor Jewish holiday), just as Kwanzaa is not the African-American Christmas (Kwanzaa is not a religious holiday at all). In conclusion, a school policy sensitive simultaneously to both the importance of religion and the diversity of religious practices and beliefs should prohibit the celebration of all religious holidays.
We must emphasize that we do not wish to deny any children the joy of celebrating their religious holidays. We respect the desires of many within the Mayo community to honor their religious traditions by celebrating with family and friends in their homes and at their churches (or synagogues, mosques, or other places of religious worship). We ask only that these traditions not be observed at Mayo itself.
We thank you for your consideration of this matter.
At first, unknown to my wife and me, our letter prompted the principal to ask a Site Advisory Committee, consisting of three school personnel and five parents of Mayo students, to consider the issue of “holiday” parties. When my wife eventually (though inadvertently) discovered that the Committee had placed this issue on the agenda for its next meeting, she
INTRODUCTION 3 managed to secure an invitation so that we could present our views (the principal had not given copies of our letter to the members of the committee, supposedly in an effort to protect our privacy). At the meeting, we distributed our letter to the Committee members and summarized our position orally.
In response, the Committee members informed us that this matter had been fully considered the previous year. From their perspective, the Committee and the parent-teacher association (PTA) had thoughtfully deliberated, with appropriate concern for all positions, and had decided not to display a Christmas tree, but to display instead a “holiday” tree during December. Moreover, the children had merely created (secular) art decorations that were then placed on the holiday tree; those decorations, we were told, were not Christmas ornaments. The committee members insisted that they had handled the issue with tremendous “sensitivity”; after all, they noted, unlike some other schools, Mayo had not displayed a créche. (As Dave Barry might say: I am not making this up.) Unconvinced by the Committee’s professed sensitivity, my wife emphasized that since the tree was erected only in December, its display would strongly suggest to the children that it was, in fact, a Christmas tree. In response, the one Committee member who appeared somewhat sympathetic to our position asked if the religious symbolism would be neutralized if the tree were displayed throughout the year. Hopeful for compromise, my wife agreed that she would be satisfied with this modification of the school policy (though I found it unsatisfactory). The committee then voted to present to the PTA a proposal to have the tree displayed all year long. Before the meeting ended, though, another committee member flatly declared that my wife and I were being “ridiculous.”
At the next PTA meeting, the proposal was unanimously defeated.
A DOMINANT STORY ABOUT THE SEPARATION OF CHURCH AND STATE
The establishment and free exercise clauses of the first amendment to the Constitution state: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.” In recent years, commentators have discussed exhaustively and have disputed vehemently the meanings of these religion clauses. Do the clauses prohibit the injection of religious values into the so-called public square of political debate? Does the establishment clause prohibit praying, moments of silence, and other religious or quasi-religious activities in public schools?
Does the free exercise clause require the government to grant religious exemptions from laws of general applicability? What doctrinal tests should courts use to determine the scope of the two clauses?
Regardless of the particular topical issue, though, nearly all discussions of the religion clauses build upon one dominant or standard story of the separation of church and state. This oft-repeated and almost universally accepted story focuses on two themes. First, the separation of church and state stands as a constitutional principle that promotes democracy and equally protects the religious freedom of all Americans, especially religious outgroups, including Jews. Second, this principle emerges as a unique American contribution to political theory. Sometimes this latter theme is modified to acknowledge that the framers of the first amendment drew upon Enlightenment political thought; the principle of separation of church and state is then understood as a political idea spawned during the Enlightenment that culminated in American constitutionalism.* Either way, commentators assume that at some point in the history of the United States, religious freedom and equality triumphed over persecution, oppression, and injustice. Indeed, the dominant story appears in different guises only because writers disagree about when (and not whether) religious liberty ascended to victory: either during the late eighteenth century, after the constitutional framing and the adoption of the first amendment; during the nineteenth century, after the last official state establishments withered away; or during the twentieth century, after the Supreme Court began seriously enforcing the religion clauses against the state and federal governments.
American legal scholars and Supreme Court justices have long celebrated this dominant story of the separation of church and state. In the nineteenth century, David Dudley Field wrote: “It is the reasonable and lofty boast of this, our country, that it has made religious freedom a reality at last.”° In the mid-twentieth century, Leo Pfeffer, the renowned church-state advocate and scholar, passionately declared:
Before the launching of the American experiment, the concept of religious liberty and the separation of church and state was—for all practical purposes—unknown. The experiment embodied in the majestic words [of the religion clauses] was a uniquely American contribution to civilization.... The principle of separation and freedom was conceived as a unitary principle. Notwithstanding occasional instances of apparent conflict, separation guarantees freedom, and freedom requires separation.... When the constitutional fathers and the generation that adopted the Constitution formalized the concept [of separation of church and state] in the First Amendment, they thereby imposed—and intended to impose—on future generations of Americans in church and state a great moral obligation to preserve their experiment and
INTRODUCTION 5 adhere strictly to the principle they expressed. [And] the American people have by and large been faithful to the obligation placed on them by the framers of the First Amendment; church and state have been kept separate, and religious freedom has been preserved.®
And again, in 1993, Stephen L. Carter wrote similarly: “The separation of church and state is one of the great gifts that American political philosophy has presented to the world.”’
The Supreme Court too has subscribed to the dominant story. Shortly after World War II, the Court wrote: “These words [in the religion clauses] of the First Amendment reflected in the minds of early Americans a vivid mental picture of conditions and practices which they fervently wished to stamp out in order to preserve liberty for themselves and for their posterity.... The First Amendment has erected a wall between church and state. That wall must be kept high and impregnable.”® More recently, the Court reiterated: “[The religion clauses] are recognized as guaranteeing religious liberty and equality to ‘the infidel, the atheist, or the adherent of a non- Christian faith such as Islam or Judaism.””?
My purpose in this book is to challenge the two themes of this dominant story of church and state. In contesting the first theme, I argue that the separation of church and state is far more (or far less) than a principle protecting democracy and religious liberty. Contrary to the dominant story, the separation of church and state stands, to a great extent, as a political and religious development that manifests and reinforces Christian domination in American society. In disputing the second theme of the dominant story, I argue that the separation of church and state, whether a principle or not, did not arise first in America, either at the time of the constitutional framing or later. Rather, as a political and religious development, the separation of church and state has slowly evolved throughout western history, beginning with the initial emergence of Christianity as it contentiously separated from Judaism. Thus, to understand the growth and transformation of the concept of separation of church and state, I follow the historical path of two institutions—the Christian church and the state— from the origins of Christianity to the present day.
In challenging the dominant story of the separation of church and state, this book offers an extended study of power in a specific context: I explain or interpret the development of Christian social power vis-a-vis the state and religious outgroups. Significantly, with regard to method, I approach the question of power in society from a postmodern perspective. Unlike a modernist approach to power, which typically locates power in some conscious or intentional center, such as an individual, a group of individuals, or a sovereign, a postmodern approach underscores that “power is everywhere and in everyone.”! Hence, although I explore the evolution of church and state from premodernism to modernism to the current time (postmodernism or modernism/postmodernism?), I use a postmodern conception of power to understand developments throughout all of these eras. Such a postmodern approach is justified because I do not seek, particularly, to describe how individuals during the various eras subjectively understood power in a broad sense. Rather, I seek to describe (or interpret) how power operated through Christianity during the different epochs.
With this goal in mind, my precise method is to present what I call a critical social narrative of the separation of church and state. In general, a critical social narrative is a narrative re-interpretation of a series of social events and developments that is oriented toward uncovering how power operates. Roughly, in my narrative, I approach the problem of power from three perspectives: the symbolic, the structural, and the interaction of the symbolic and structural. With regard to symbolic power, I typically explore how language or discourse contributes to the orientation of power within society. With regard to structural power, I explore how power is oriented through the contingent relations of different social roles or positions in the organization of society. With regard to the interaction of symbolic and structural power, I explore how they can combine to reinforce certain societal effects such as domination. For example, a specific type of discourse might operate as an ideology that hides or legitimates particular social structures of subjugation.
I do not mean to suggest that I will describe power only in terms of symbols, structures, and their interactions. Frequently, the workings of power lie buried within layers of tradition and culture, so a critical narrative must penetrate below the surface and into history. In such a situation, the movement of power becomes evident in the sometimes intact, sometimes cracked, sometimes twisted, sometimes jumbled strata of a historical sediment. Power lies here within its own formations. Two points, then, bear emphasis. First, although the concepts of symbol and structure frequently help explain or interpret the formations or manifestations of power, if one follows a postmodern approach, then power should be conceptualized in multiple, flexible, and tentative ways. One should not attempt to neatly cabin power merely to facilitate simple explanations of complex social developments. Hence, in the course of my narrative of church and state, the workings of power often emerge most clearly through the details of the story rather than through any predetermined framework of analysis. Second, to be reasonably complete, a critical social narrative should consist
INTRODUCTION 7 of two parts: a critical history and a synchronic critique. A critical history explores how particular but contingent symbols and structures arose and evolved, while a synchronic critique analyzes how those symbols and structures work to orient power within society at a certain point in time, particularly the present.”
Therefore, I first present a critical history of the separation of church and state as it developed in western society, followed by a synchronic critique or analysis of the separation of church and state in the United States of the later twentieth century. The critical history constitutes the bulk of the book. This history begins in chapter 2 by focusing on the discourse of the New Testament in the context of the emergence of Christianity as it separated from Judaism. Most important, the New Testament for several reasons designated Jews for special religious condemnation by, for example, opposing a hellish world of Jewish carnality to a heavenly world of Christian spirituality. Throughout western history, the peculiar condemnation of “the Jews” not only has been the root source of antisemitism but also has been enormously important to the development of Christianity and the state. In particular, the opposition between Jewish carnality and Christian spirituality served as the symbolic framework for the development and understanding in Christendom of the secular power of the state in relation to the spiritual power of the church. Moreover, because Jews have constituted an insular and frequently despised outgroup within Christian societies, the institutions of both the church and the state often have sought to use Jews, each to its own advantage. Since, partly for this reason, Jews frequently have been manipulated and persecuted, if one is interested in accurately gauging the degree of religious freedom and equality in western societies, then the status of Jews—the prototypical religious outgroup—can serve as a convenient barometer. Consequently, whereas the twin foci of my critical social narrative are the institutions of the church and the state, the common thread weaving between the two is the treatment of Jews—in particular, the manifestations of antisemitism. Thus, while I do not intend this book to be a history of antisemitism per se, the story of antisemitism in western society necessarily plays a large role in my critical history of church and state. Of importance, then, I understand antisemitism from a postmodern perspective, consistent with my generally postmodern approach to the problem of power. Unlike someone with a more typically modernist conception of antisemitism, I do not limit the definition of antisemitism to intentional or conscious anti-Jewish actions and attitudes. Instead, in this book, “antisemitism” refers broadly to the intentional or unintentional, conscious or unconscious, hatred, dislike, oppression, persecution, domination, and subjugation of Jews qua Jews for whatever reason or motivation, whether it be religious, cultural, ethnic, racial, or political.”
After the initial discussion of the New Testament and the emergence of Christianity, the critical history continues in chapters 2 through 5 by following the evolution of church and state in Europe through the Roman establishment of Christianity, the Christian Middle Ages, the Christian Renaissance and Reformation in continental Europe, and the English Reformation, Civil War, and Revolution.’ Chapters 6 through 8 follow the development of church and state in North America: from the colonial era, to the American Revolution and the framing of the Constitution, and through the nineteenth and early twentieth centuries. In chapter 9, I focus on America after World War II. During this time, the Supreme Court first became heavily embroiled in issues of church and state; much of this chapter therefore is devoted to reviewing and analyzing the Court’s decisions and opinions in the particular social context of the second half of the twentieth century. Finally, chapter 10 completes the critical social narrative by presenting a synchronic critique of the separation of church and state in the postwar era. I diagnose or critically analyze how the constitutional principle of separation of church and state contributes to the current orientation of power within American society. In so doing, I elaborate the threefold perspective on power by explaining and focusing on symbolic power, structural power, and their interaction in the context of exploring church and state in late-twentieth-century America.
My conclusion, in brief, is that the dominant story of the separation of church and state is woefully simplistic and seriously misleading. The separation of church and state did not magically and suddenly appear in the United States. More important, the separation of church and state does not equally protect the religious freedom of all, including religious outgroups. To be sure, I do not argue that religious outgroups necessarily would do better without the separation of church and state. In some instances, the doctrine of separation has protected religious outgroups from oppression. But all in all, the separation of church and state provides far less shelter for religious outgroups than the dominant story would lead one to expect. Moreover, the separation of church and state imposes particular costs or disadvantages on outgroups that are not similarly borne by the Christian majority. Ultimately, the dominant story of church and state is revealed to be dominant not only because it is commonly accepted, but also because it is told from the perspective of the dominant Christian majority. And telling the story of religious freedom and equality from the perspective of the
INTRODUCTION 9 dominant religion has produced a tale that is both self-congratulatory and lacking in nuance. My critical narrative, told from the viewpoint of an American Jew, reveals the constitutional principle of the separation of church and state to be a highly complex social phenomenon that flows primarily from and helps reproduce the Christian domination of American society and culture.
CHAPTER 2 The Emergence of Christianity and Antisemitism
THE NEw TESTAMENT
In 63 B.C.E., Rome conquered the Jewish homeland of Israel, and from that time through the first century C.E. and beyond, Israel remained an occupied Roman province.! Nevertheless, the Jewish people continued to live according to their professed covenant with God that was articulated in the Jewish laws of the Torah (the first five books of the Hebrew Bible). Many Jewish sects or groups coexisted at that time, with Jesus and his followers (or disciples) constituting merely one of those sundry groups;* Jesus himself never imagined that he was leading or creating a religion separate from Judaism.* His followers, especially Paul, effectively invented Christianity only after Jesus’ death when they declared that they had a new covenant with God— that is, a new testament—which supplanted the old (Jewish) one.’
Jesus’ disciples did not write the Christian Gospels or the remainder of the New Testament until the latter part of the first century, at least one or two generations after his death. Although the New Testament contained (and still contains) many inconsistencies, it decidedly condemned (and still condemns) Judaism as a religion and Jews as a people. Indeed, starting with the Gospel of Mark (written first) and culminating with the Gospel of John (written last), the four Gospels seemed to progressively intensify the condemnation of Jews and Judaism.’ Most broadly, the New Testament directly affronted Judaism by portraying its covenant as having been superseded by the Christian one.? “The Jews”? supposedly had misunderstood their own laws and covenant with God. Even worse, the New Testament
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ORIGINS OF POWER II repeatedly declared that the Jewish covenant always had been defective and that the Jews never had known God: “And the Father himself, which hath sent me, hath borne witness of me. Ye have neither heard his voice at any time, nor seen his shape. And ye have not his word abiding in you: for whom he hath sent, him ye believe not.”!! Most important, according to the New Testament, the Jews were stubbornly and tragically apostate: they not only had killed their own prophets, but ultimately they killed their own Messiah, Jesus.
The charge of deicide against the Jews was (and still is) central to the New Testament narrative.’ The Gospel of Mark effectively indicted the Jews, and the Gospels of Matthew, Luke, and John directly accused the Jews of “intentional murder.”!* Responsibility for Jesus’ death thus was squarely placed on the Jews, who supposedly acknowledged as much by chanting, “His blood be on us, and on our children.” John even portrays the Jews as insisting that Jesus be crucified despite the protestations of the Roman procurator, Pilate.
And from thenceforth Pilate sought to release [Jesus]: but the Jews cried out, saying, If thou let this man go, thou art not Caesar’s friend: whosoever maketh himself a king speaketh against Caesar. When Pilate therefore heard that saying, he brought Jesus forth, and sat down in the judgment seat in a place that is called the Pavement, but in the Hebrew, Gabbatha. And it was the preparation of the passover, and about the sixth hour: and he saith unto the Jews, Behold your King! But they cried out, Away with him, away with him, crucify him. Pilate saith unto them, Shall I crucify your King? The chief priests answered, We have no king but Caesar. Then delivered he him therefore unto them to be crucified. And they took Jesus, and led him away.!®
Not only were the Jews accused of killing Jesus, they supposedly condemned Jesus for blasphemy against Jewish law. The Jews, that is, executed Jesus for religious infractions. For instance, the Gospel of John states:
Pilate therefore went forth again, and saith unto [the Jews], Behold, I bring him forth to you, that ye may know that I find no fault in him. Then came Jesus forth, wearing the crown of thorns, and the purple robe. And Pilate saith unto them, Behold the man! When the chief priests therefore and officers saw him, they cried out, saying, Crucify him, crucify him. Pilate saith unto them, Take ye him, and crucify him: for I find no fault in him. The Jews answered him, We have a law, and by our law he ought to die, because he made himself the Son of God. 1”
Historical evidence, however, strongly suggests that the New Testament authors intentionally fabricated this description of Jesus’ death.!® During
I2 PLEASE DoN’rt WISH ME A MERRY CHRISTMAS the first century C.E., many bands of Jewish insurgents opposed Roman rule, and indeed, Jews ultimately rebelled (albeit unsuccessfully) against Rome in 66 C.E.” The leaders of these insurgent corps were often referred to as “kings” or “messiahs”—as many claimed to be the Jewish Messiah. In Judaism, the Messiah often was (and is) understood to be a political leader who will usher in Jewish sovereignty and world peace (Christians later transformed this Jewish concept so that the Messiah became God incarnate).2° Hence, from the Roman standpoint, Jesus was merely another troublesome political agitator (or Messiah), a “dangerous peasant nuisance.”*! Moreover, Pilate was a vicious ruler who brutally massacred countless victims (perhaps thousands); he would not have sympathized with Jesus or any other insurgent.” Most likely, then, the ruling Romans, under Pilate’s command, were solely responsible for killing Jesus: the Romans arrested Jesus, summarily tried him in a military-type proceeding, sentenced him to death, and executed him by crucifixion as they did similarly with hundreds, and perhaps thousands, of other Jewish insurgents.? Under an alternative and weaker reading of the sparse evidence, some Jews might have played, at most, a subsidiary role in Jesus’ death. Two of the major Jewish sects of the time were the rival Sadducees and Pharisees—with the Pharisees being the direct ancestors of modern Jews.2* The Romans allowed the Jews to maintain a governing institution, the Sanhedrin, which was divided into two separate bodies, one political and the other religious. The Romans occasionally ordered the political Sanhedrin, drawn from the Sadducean aristocracy, to examine and surrender Jews charged with sedition against Rome, with the Romans then passing and executing final judgment. The political Sanhedrin thus might have cooperated in the Romans’ condemnation of Jesus as one of many political agitators. Even if this were the case, however, neither the Pharisees nor the religious Sanhedrin contributed to Jesus’ death.”
Why then did Jesus’ followers and the New Testament disingenuously accuse the Jews of killing Jesus, and of doing so for religious reasons? Apparently, Jesus’ disciples were motivated chiefly by political self-interest; in the words of John Dominic Crossan, a Catholic theologian, the passion narratives of the New Testament were, quite simply, “Christian propaganda.”*° Once the disciples realized that few Jews were willing to convert to Christianity, the disciples focused their energies on converting the Roman gentiles. With that goal in mind, the disciples recognized that— regardless of history—they might further their cause by blaming the Jews instead of the Romans for Jesus’ death. Moreover, by blaming the Jews, the
Christians could minimize their antagonization of the powerful and potentially oppressive Roman government. And the Jews were an obvious scapegoat: in an era of Jewish uprisings against the Romans, the disciples could conveniently accuse the Jews of defying the entreaties of the Roman agent, Pilate, even while they pressed for Jesus’ death. Finally, by blaming the Jewish religion itself instead of the political Sanhedrin, the disciples were able to accentuate the differences between Christianity and Judaism.*’
To understand the significance of this final point, one must recognize that Jesus’ sudden death presented his followers with potential ruin. They were compelled either to somehow explain this violent turn of events or to admit that they mistakenly had believed Jesus was the Messiah prophesied in the Hebrew Scriptures (since Jesus had failed to usher in Jewish sovereignty and world peace). The latter choice—admitting a mistake—would ensure humiliation and collapse for the disciples. Not only would they be acknowledging their own fallibility, but, perhaps more important, they would be implicitly conceding that they inadvertently had contributed to Jesus’ death. The Romans executed Jesus because they feared him as a political insurgent, and their fears were based largely on his followers’ own messianic expectations of him. If those messianic expectations were misplaced, then his followers had contributed to Jesus’ death by futilely and falsely calling him a Messiah.7®
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