Women of the Wall

Dear friends and family,

Disclaimer: This email contains material which may be somewhat upsetting to those of my friends and family who are Reform and Conservative. Please read what I say carefully, and note that I am making a legal and logical argument, and nowhere do I state that a Reform or Conservative Jew is not a Jew, or that I am somehow "better" for being Orthodox.
A couple of weeks ago I read a piece in Findlaw disparaging the ruling by the Israeli Supreme Court to disallow a group known as "Women of the Wall" from praying at the Western Wall in Jerusalem, the holiest site to which Jews have access. The piece is written by a lawyer named Sheryl Colb (http://writ.news.findlaw.com/colb/), who is a Professor at Rutgers Law School in Newark. Upon seeing the piece, I felt the need to respond, which began a short-lived dialogue.
Before I begin, for those who don't know, the Women of the Wall is a group of non-Orthodox women who pray at the Western Wall every Rosh Chodesh (the first day of each Jewish month) wearing the traditional masculine garments of Tefillin and Talit, praying and singing very loudly, praying as a minyan (quorum,) and reading from the Torah, all of which are the traditional role of men and not women in an Orthodox synagogue.

While this may all sound very technical, it is important to understand that when women pray in this manner, it makes it impossible for the men to pray according to halachah (Jewish Law.) Legal arguments aside, the real fight here is by the non-Orthodox movements for recognition, not by the Israeli state, which already recognizes their religion as Jewish, but by Orthodox Jews who do not. The goal is to make a media spectacle which will attract attention and bring down scorn upon we obstinate Orthodox Jews who refuse to modify our beliefs and practices to make room for the "moral flavor of the month." It is important to make clear that while Orthodox Jews do not believe that the religion that the women are practicing is true to Torah, we still believe that they are Jews and are commanded to love them as sisters regardless of our disagreements.

To get their perspective, go to http://www.womenofthewall.org/ . Two interesting observations on their web page: while the English section is very thorough and well done, and has been up for three and a half years, the Hebrew section still says "Under Construction," indicating that this movement is not integral to Israeli society, in which something like 0.1% of Jews are Reform and Conservative, but imposed by English-speaking American Jews, in which the Refom and Conservative movements attract the majority of Jews. Also, it is noteworthy that while they claim to be acting within Halachah, glaringly absent from the section on their website labeled "Halachah" is any Halachic justification or backing for their actions.

Please bear with me, as the exchange was quite long. If you fall asleep while reading, I won't blame you.

The original article written by Sheryl Colb is as follows:

The Israeli Supreme Court Denies Women The Right to Pray at the Western Wall:A Misguided Decision Parallels the U.S. "Fighting Words" Doctrine

Wednesday, Apr. 23, 2003

Earlier this month, the Israeli Supreme Court, in a 5-4 decision, refused to permit women to pray out loud at the Western Wall ("the Wall") in Jerusalem. Known in Hebrew as the "Kotel Ha'Maaravi," the Wall is all that remains of the second Jewish Temple destroyed by the Romans almost 2000 years ago. It is one of the holiest sites in existence for Jews around the world.
The plaintiffs in the case called themselves the "Women of the Wall." They asked the Israeli Court to recognize their right to pray out loud at the Kotel, after they had repeatedly encountered physical and verbal abuse from the Ultra-Orthodox each time they tried to do so on their own.The women had hoped and expected the Court to agree that they, as a matter of equality, should be able to assemble and pray just like men have done for as long as the Wall has stood. Besides formalizing the legal equality of women, such a ruling could help fortify the resolve of police who must invariably come to the women's aid and repel acts of aggression.
On April 6, the women's hopes were dashed. The Israeli High Court concluded that because of the violence that plaintiffs' religious practice provokes on the part of Ultra-Orthodox spectators, the Women of the Wall would have to conduct their services elsewhere. In the estimation of the Court, female assembly and vocal prayer at the Wall could endanger public order and lead to rioting by Ultra-Orthodox Jews.


Fighting Words: An American Counterpart to the Israeli Concern

American Law has an analogue to the Israeli Court's public order concern: the "fighting words" doctrine. The First Amendment ordinarily protects people's right to speak or assemble in a public forum, without censorship by the government. Under such cases as Chaplinsky v. New Hampshire, however, an exception exists for "fighting words," defined to include "those personally abusive epithets which, when addressed to the ordinary citizen, are, as a matter of common knowledge, inherently likely to provoke violent reaction."

To assess whether particular speech qualifies as "fighting words," courts must determine when the likely response will be an assault. Words that predictably provoke immediate violence do not enjoy constitutional protection. Like the Women of the Wall, the speaker in such cases is classified as disruptive of public order.Implicit Gender Bias in the Fighting Words Doctrine
Feminist authors have argued persuasively that the fighting words doctrine focuses on the wrong party in attributing responsibility for outbreaks of violence. To attach the label "fighting words" is, at least to some extent, to mitigate the seriousness of the violence that may follow such speech, on the theory that the speaker "asked for" or provoked the aggression.

Such labeling literally "blames the victim" for violence that is directed against him. It permits the government to punish his speech in addition to (or even instead of) punishing the person who would use his fists in response to words.

On top of unfairly attributing blame, moreover, the fighting words doctrine could conceivably turn on the gender of an audience to offending speech. When a woman, for example, listens to abusive remarks, the odds are relatively slim that she will physically assault the speaker. However hurtful the words that she hears, a woman ordinarily will not lash out in physical violence, even in situations in which men predictably would.


At best, this reality suggests that the fighting words doctrine is built around a masculine conception of speakers and listeners that disregards female modes of interaction and accommodates a stereotypically male way of responding to provocation.

At worst, as some authors have suggested, the doctrine provides that a person speaking abusively to a woman may enjoy greater First Amendment protection than a person speaking abusively to a man, by virtue of the likelihood that each respective listener will respond with violence.

Another way of putting this is that, as a matter of First Amendment doctrine, the worse the listener's temper, the more limited the speaker's freedom.


Explicit Gender Bias

The gender bias implicit in the American fighting words doctrine becomes explicit and pronounced in the decision handed down by the Israeli Supreme Court. The provocative speech (and worship) in that case is the prayer of women at a holy site. It is precisely the speakers' gender that triggers violent disorder on the part of onlookers.

By taking the abusive conduct of Ultra-Orthodox Jews as inevitable and silencing the praying women to restore order, the Court effectively condones violence as a strategy for imposing one's religious dogma on others. In the particular case, it does so at the expense of equality.

A Lesson from U.S. Constitutional Law

As noted above, U.S. courts have adopted a troubling fighting words doctrine. In addition, they have in other contexts often failed to resist oppressive private behavior. Yet in the area of race relations, they have embraced a salutary policy that could be instructive for the Israeli Supreme Court.

In Palmore v. Sidoti, decided in 1984, the U.S. Supreme Court confronted a custody battle between a man and woman who had formerly been married and had a daughter together. Both parties and their child were Caucasian.

The mother in the case, Linda Palmore, had originally been awarded custody of the couple's daughter. The father - Anthony Sidoti - later sought a modification of the custody award due to changed circumstances. Since the divorce was finalized, the mother had begun cohabiting with an African-American man (whom she went on to marry), and the child's father believed that this development called for a change in his child's living situation.

The Florida courts agreed with Sidoti and held that his daughter should not have to suffer the social stigmatization that would likely accompany life in a multiracial household. It accordingly awarded custody to the girl's father.

On appeal, the United States Supreme Court reversed the decision of the Florida courts. It held that the Equal Protection Clause of the Fourteenth Amendment prohibits the government from making custody decisions on the basis of race, even if the government's motive is to protect innocent people from exposure to the racial prejudice of society. The Court's decision wisely refused to allow bigots to dictate the structure of society.

The Israeli Supreme Court should have ruled likewise. The fact that some Ultra-Orthodox Jews may become violent and abusive in response to women praying out loud at the Wall is shameful and should be addressed as the hate crime that it is. As the U.S. Court said in Palmore, "[p]rivate biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect." The decision against the Women of the Wall did exactly that: it gave effect to the wishes of the Ultra Orthodox, as expressed through violence.

The Larger Implications of the Ruling for Israeli Policy

The Israeli government should be especially sensitive to the perversity of the argument that prevailed in this case. Terrorists regularly visit death and injury on the people of Israel. They do so, they claim, in response to what they describe as Israel's provocative behavior - including settlement of the West Bank.Rather than alter its settlement policy, however, Israel has chosen to react to suicide bombings by indicating that it will not bow to terrorists, even if it might - in the absence of the violence - have begun the process of dismantling the settlements.

Whatever one thinks of Israeli settlements, the value of standing up to terrorists and resisting such extortion is clear. For both practical and moral reasons, Israel must not be perceived as conducting its decision-making at the point of a Palestinian gun.

Women of the Wall: Their Right to Worship

A group of Jewish women has sought to worship at a holy place at which men have worshipped for centuries. The women wish to pray and sing aloud - as the men do - despite the religious opposition of Ultra-Orthodox Jews who contend that the sound of a woman's voice is too sexually alluring to be heard by men.Onlookers - apparently inflamed with desire - have repeatedly set upon the "provocative" women by spitting, shoving, and hurling stones and other heavy objects, causing injuries that have, on occasion, required hospitalization. The Israeli Supreme Court attributes this "public disorder" to the peaceful prayers of the women rather than to the illegal and disgraceful behavior of their assailants.

One could justifiably characterize this decision as representing one step along to road to appeasing terrorists. It is a grave mistake that ought to be recognized as such and overruled.

Ephraim Aryeh's Response of 4/25/03

Dear Ms. Colb,I read your article on the Israeli Supreme Court case in FindLaw, and had a few problems with it. I couldn't figure out how to post this to the message board so I decided to email it to you directly.

First off, I'm not a lawyer.

I agree with your argument that the ruling that the presence of non-Orthodox women praying provokes the Orthodox men and women around them to violence is "blaming the victim," and the court should not have barred the "Women of the Wall" for that particular reason. However, as an Orthodox Jew, I would object to the presence of the women's prayer group not for that reason but because it is imposing a separate religion. The religion to which the women adhere, which calls itself Conservative Judaism, has been in existence for approximately 150 years. The religion to which the Orthodox men and women adhere, which calls itself Traditional or Orthodox Judaism, has been in existence for about 4,000 years. The Temple Mount, and later the Western Wall, has been a holy place for Orthodox Jews for nearly that entire time. Essentially, what the "Women of the Wall" amounts to is the imposition of a foreign religion upon Orthodox Jews in our holiest place. A parallel situation would be if a group of Muslims called itself "Muslims of the Church" and walked into a Catholic Church screaming "Alla Hu Achbar!" on Sunday mornings. Like the women of the wall, the Muslims could fairly make the claim that they were not interfering with the worship of Catholics because the Catholics were free to continue worshipping in their own way. However, realistically there is no way that the Catholics could be expected to reasonably tolerate such a disturbance in their holiest of places.

One could, of course argue, that the "Women of the Wall" are not trying to impose their religion on the Orthodox Jews but pray in their own way, and any offence is unintentional. However, the fact is that the Israeli Supreme Court offered "Women of the Wall" a separate location on the Western Wall to pray in their own way. This section of the wall, unearthed recently, is, in fact, closer to the original location of the Jewish Temple and therefore considered even holier than the current location where the Orthodox Jews pray. Their outright rejection of this solution indicates that their intent is not the practice of their religion but the imposition of their religion on Orthodox Jews.

As a side note, I also object to the following quote, "Terrorists regularly visit death and injury on the people of Israel. They do so, they claim, in response to what they describe as Israel's provocative behavior - including settlement of the West Bank. Rather than alter its settlement policy, however, Israel has chosen to react to suicide bombings by indicating that it will not bow to terrorists, even if it might - in the absence of the violence - have begun the process of dismantling the settlements."

This comment is somewhat disingenuous. While certain English-speaking pundits and European intellectuals use this argument, the terrorists do not. Virtually every terrorist group, from Hamas to Yassir Arafat's Fatach faction, do not claim that they conduct their attacks because of Jewish settlements but because of the existence of a Jewish state.

I would appreciate your input on these comments.

Sheryl Colb's Response of 4/25/03

Dear Mr. Aryeh:

Thank you for your thoughtful e-mail. I think you make a number of interesting points. The notion that the women in this case are practicing a different religion altogether puts the case of the Orthodox in a very different light, and I appreciate you're clarifying the issues in this way. Ultimately, though, I am not sure that I agree with the characterization. The analogy between "Muslims of the Church" and "Women of the Wall" strikes me as flawed, in part because the "Women of the Wall" group includes Orthodox Jews as well as Conservative and Reform Jews. Perhaps the Orthodox among them are modern Orthodox, however, and therefore, by your lights, not that different from Conservative. Still, I don't think the belief that women should be able to worship out loud is really enough of a departure from traditional Judaism to make the women's practice of Judaism an entirely different religion (just as a Sephardic Jew's eating peanuts on Passover does not convert the Sephardic Jew into an adherent of another religion from the Ashkenazim, or, to take a closer analogy, an Orthodox rabbi who shakes hands with women is not distinct enough from an Orthodox rabbi who refuses to shake hands (on the grounds that to do so would be "negiyah") to be a leader of different religion. The reason the women wish to worship at the Wall is not, I think, a desire to force a different religion on the Orthodox (as, for example, I would suggest about "Jews for Jesus"). Instead, women -- like men -- are drawn to the traditional association of that Wall with the Jewish religion. My suspicion, for example, is that even though the newly unearthed part of the Wall may be holier in some respects, as you suggest, the Orthodox men who currently pray at the Wall would probably be displeased if they were told by the Israeli Supreme Court that from now on, only women will be permitted to pray at the Kotel but that men (and only men) can pray at the alternative, holier portion of the wall. The women's not being satisfied with the alternative, in other words, is not necessarily proof that they just want to impose a religion on the Orthodox. Neither men nor women would wish to have their worship relegated to an "alternative" forum, even if that location may be "objectively" just as good as or better than the desired one. On the separate question of what gives rise to terrorism, you are right about what various terrorist groups say when claiming "credit" for their murders of Jews. Nonetheless, I think that the question is actually quite complex. While leaders of terrorist groups (and many terrorists themselves) say and believe that the existence of a Jewish State is what provokes them to violence, the reality is that the settlements may contribute to the ability of terrorist groups to recruit followers (each of whom presumably does what he does for his own reasons). If that is so, as I think it is, then a cessation of settlement and progress toward dismantling them could, in fact, reduce the amount of terrorism. Nonetheless, if Israel were to change its settlement policy in an obvious reaction to bus bombings, then the result could be very destructive and the message would be to reward violence (in fact, some Israeli academics in my circle of friends have indicated that pulling out of the Sinai when Israel did was strategically a mistake for that very reason, even though every one of them believes that pulling out of the Sinai was the right thing to do). In any event, I very much appreciate your sharing your thoughts with me, and I hope I have helped clarify my views for you. SFC

Ephraim Aryeh's Response of 5/2/03

(Note: I decided to ignore Ms. Colb's non sequitur stab at the settlements and argue only the merits of the religious arguments)

Dear Ms. Colb,

I have been thinking about the email you sent me and wanted to reply.

First, the supposition that the difference between Conservative/Reform (which I will call "Heterodox" for the sake of argument) and Orthodox is the same as the difference between Sephardi and Ashkenazi does not accurately reflect the basis of the disagreement. The specific example of a Sephardi eating peanuts on Passover while the Ashkenazi does not, is, like all differences between Sephardim and Ashkenazim, a matter of specific interpretation of an ordinance which is universally accepted among Orthodox Jews. Specifically, an Orthodox Jew is forbidden from eating leaven on Passover. In the world of Ashkenazi Jewry, there was a danger of peanuts being carried in the same sack as leaven, and therefore a ruling was made that Peanuts must be treated as leaven lest one inadvertently ingest leaven while enjoying a peanut. In the Sephardi world, leaven was not typically carried in the same sack with Peanuts, and therefore the Sephardi Rabbis ruled that there is no need to avoid peanuts. If the Torah is considered as the Jewish Constitution, then the Ashkenazi and Sephardi rabbis may be thought of as the state legislature and supreme court. While Florida and California may pass different laws and rulings relating to the local implementation of their laws, the United States Constitution will always be the basis of that law.

The thirteen principles of faith, as laid out by Maimonides in the 10th century, have been accepted as the litmus test by Judaism (for the last 200 years, Orthodox Judaism) to determine whether a religion or system of beliefs which claims to be Jewish has drifted far enough that it will be considered a different religion. Heterodox Judaism is in violation of many of these principles, more, in fact, than Christianity. For example, the ninth principle, "…that this Torah will not be changed, and that there will never be another given by G-d," clearly tells us that, for an Orthodox Jew, Torah is immutable. However, a Conservative Rabbi may pass a ruling that one may drive to his temple on the Sabbath, in spite of the fact that this will inevitably lead to the lighting of a fire on the Sabbath, which is expressly forbidden by Torah. An Orthodox Rabbi simply doesn’t have the power to make such a ruling. Because they are operating from the same set of basic principles, the Ashkenazi recognizes the Sephardi who eats peanuts on Passover as legitimate, even though he would never do so himself, and the Sephardi recognizes Ashkenazi leniencies likewise, but neither would dream of recognizing the Heterodox Rabbi’s rulings. Due to the vast chasm in both basic belief and practice which separates Heterodox from Orthodox Judaism, it is difficult to see what grounds there are to say that the two are of the same religion.Indeed a similar situation exists in the Christian world. Mormons will continuously affirm that they are Christians, and indeed they do share many of the same beliefs, but Christian theologians would never agree that Mormons are Christians.

As to the argument that some of the Women of the Wall are modern Orthodox, well, it seems beside the point. While they may claim to be of the Orthodox persuasion, their actions are clearly in violation of the beliefs and norms of Orthodox Judaism. To use the "Muslims of the Church" argument, it would be as if some of the Catholics decided to join in with the Muslims. This would not necessarily imply that the Muslims were practicing Catholicism.

As to the final argument, that the Western Wall holds a special place in the hearts of the Women of the Wall because of its traditional association with the Jewish religion, one can only take their word for it. And yes, the Orthodox men and women would be quite put out if they were asked to move from the Kotel to an alternate location, but it really comes down to a question of who was there first. Because prayers have been carried out at this location by Orthodox Jews for virtually all of recorded history, they take precedence over Heterodox Judaism. And because Heterodox and Orthodox forms of prayer are mutually exclusive and can’t be done in the same place, the Orthodox Jews have priority. Likewise, there are many Orthodox Jews who would much prefer to pray on the Temple Mount itself because if its traditional association with the Jewish religion, but because that location is currently in use by Muslims, the Israeli Supreme Court has determined that, for the Orthodox Jews, it’s just too bad.

Sheryl Colb's Response of 5/8/03
Dear Mr. Aryeh:

I have enjoyed our exchanges, but unfortunately, time is such that I cannot continue it indefinitely, even though it has been very interesting. I leave you the last word if you want it, but I do want to say a few things in parting.

Our discussion began with your suggestion that Women of the Wall represents a different religion from Orthodox Judaism, and the women's unwillingness to go to an alternative forum is evidence of their bad faith. I responded that the Orthodox men would almost certainly reject the suggestion that *they* go to an alternative forum (even if the forum were just as "holy" as the Western Wall, by many accounts). My point was not that the women should be able to go to the Western Wall and the Orthodox should go elsewhere. I was simply addressing your claim about bad faith by indicating that all Jews, including Women of the Wall, have reason to want to pray at the Western Wall, and that their wish to do so is therefore not proof of a desire to impose their vision of Judaism upon others, but is simply a product of the Wall's status as an important traditional place for Jewish worship. Just as Orthodox would not want to go elsewhere, so the Women of the Wall do not want to go elsewhere, and neither should have to.

Everyone, in other words, can be acting in good faith and nonetheless wish to pray at the Western Wall. If the Women of the Wall were to insist, however, that the Orthodox should be excluded from praying at the Wall, because their prayers and their modes of behavior offend the women and construct women's status in a manner that is profoundly wrong, I would think that such insistence should not be accepted as a basis for excluding the Orthodox. Jews of all different stripes come to the Wall for different reasons, and none should be excluded just because their approach is inconsistent with another's. If they work together, for example, the Ultra-Orthodox can come to an understanding through which particular times will be available to people who prefer not to pray in the presence of women praying aloud or ultra-Orthodox. For you to suggest that the Women of the Wall should not be allowed to pray out loud at what they (and their detractors) view as a holy place for Jews, because their views of Judaism are "heterodox" or otherwise presumptively inferior to that of the Orthodox, shows a lack of humility that all Jews, and indeed all human beings, ought to have in this world of uncertainty.

No one can know exactly what God wants from Jews (or from non-Jews). Everyone religious does his or her best to understand the commandments in a light that coheres with deep impulses about good and evil. Many, perhaps most, Hasidim, for example, believe that the Torah forbids the existence of Israel as a State until the Moshiach comes. For them, the very power of an Israeli Supreme Court or an Israeli prime minister who can make decisions about settlements or anything else is as good as treif. If you think that all Orthodox are united on the important things about halacha, you are thus very much mistaken. Finally, on the matter of who was at the Wall first, I would be very cautious about relying on an argument like that, when Jews have been shunned and worse by outsiders precisely because we weren't there first.

Though I could say more, other responsibilities call, and I know that whatever I say, you will believe what you believe, and I will believe what I believe. I nonetheless hope that our exchange will prove enlightening as we encounter people unlike ourselves in the future. SFC--End of email

Ephraim Aryeh's Final Response 5/8/03

Clearly, Professor Colb did not want me to respond, so I am forced to reply on my own. Her statement, "I leave you the last word if you want it, but I do want to say a few things in parting," seems to be something of an oxymoron, but I’ll leave it be.The most interesting observation one could make of Professor Colb’s response is that she really doesn’t address the legal or logical arguments I was making. Indeed, from reading her final email, it is not even clear if she read my email of 5/2/03. When she begins railing against my supposed superiority complex, which is a stereotype she seems to have about Orthodox Jews in general and is applying to me in this case, one can’t help but laugh.To go point by point:"Our discussion began with your suggestion that Women of the Wall represents a different religion from Orthodox Judaism, and the women's unwillingness to go to an alternative forum is evidence of their bad faith."

I believe that I conceded the point in my second email of 5/2 that we don’t know whether their motivation for wanting to pray at the more crowded section of the Western Wall is political or religious. "We can only take their word for it," were the words I used.

The legal argument I made was that I can not pray as an Orthodox Jew at the Western Wall in the presence of a Heterodox minyan without violating my own religion, which commands me not to listen to a quorum of lovely young women singing while I’m praying lest I be distracted from talking to my creator and start thinking about Women. Orthodox Judaism makes the honest distinction that men are the weaker gender when it comes to impulse control, concentration, and sexual restraint. For me to pray in the presence of such a minyan is to violate my religion. Whether intentional or unintentional, the actions of Women of the Wall constitute religious coercion, forcing me to either become a non-Orthodox Jew myself or no longer visit the wall. Professor Colb did not address this point.

"For you to suggest that the Women of the Wall should not be allowed to pray out loud at what they (and their detractors) view as a holy place for Jews, because their views of Judaism are "heterodox" or otherwise presumptively inferior to that of the Orthodox, shows a lack of humility that all Jews, and indeed all human beings, ought to have in this world of uncertainty."
The term "Heterodox" does not presume inferiority. The term "Orthodox" is a label which was assigned to people who had always thought of themselves simply as "Jews" by the Reform in the early days of their movement. The term "Ortho" meaning one, "dox" meaning way. It is defined as "Adhering to the accepted or traditional and established faith, especially in religion," by Webster’s dictionary. Therefore "Heterodox" seems appropriate, "Hetero" meaning different or, more specifically, differentiated (like heterogeneous,) since within Reform and Conservative there is no unifying moral code. A careful reread of my emails will show that I was not arguing the merits of one belief system against another (which I would be happy to do,) and I was not stating that one group is somehow superior to another.

"If you think that all Orthodox are united on the important things about halacha, you are thus very much mistaken."

No argument there. Orthodox Judaism is probably the most pluralistic religion in the world. There are Jews who say Tachanun (the prayer of mourning) on Israeli Independence Day, which they see as a disaster, and there are those who say Hallel (the prayer of thanksgiving and praise) on the same day, for what they see as a miracle. Yet all abide by the thirteen principles of faith and regard each other’s beliefs as Jewish. Professor Colb did not address this issue which I brought up in my email of 5/2.

"Finally, on the matter of who was at the Wall first, I would be very cautious about relying on an argument like that, when Jews have been shunned and worse by outsiders precisely because we weren't there first."

The Women of the Wall are still allowed to pray at the Western Wall. This is the unassailable right of every Jew. Provided, of course, that they pray in the traditional manner. At issue is not the right of the individual but the right of the movement. Suppose Jews for Jesus decided to erect a giant cross at the Western Wall. Technically, they are all Jewish, they simply believe that Jesus is the Moshiach. Therefore, by Reform standards, they are just as Jewish as Reform. Would this not be considered religious coercion? Would any court which values tolerance allow such a thing?

To close, I want to make it clear that I do not dislike "Heterodox" Jews. Indeed, I still feel a very strong closeness with all of my Jewish brothers and sisters. I simply do not believe that they have the right to force their religion upon me.

Shabbat Shalom,
Ephraim