Florida State Chaplains and Bowden

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Sent via U.S. Mail and Email to: [email protected] September 12, 2014 Ms. Carolyn Egan General Counsel, FSU PO Box 3060000 Tallahassee, FL 32306-1470 Re: Chaplain and First Amendment violations in FSU football program Dear Attorney Egan: We corresponded in December 2012 regarding FSU football’s team chaplain, Clint Purvis, his role, and the chaplaincy generally. At that time, I requested records under the Florida Sunshine Law (Fl. Stat. §119). By way of reintroduction, the Freedom From Religion Foundation is a national non- profit with more than 21,000 members including more than 1,000 members in Florida. We protect the constitutional separation between state and church. I write again for two reasons: (1) the records request remains unfulfilled; and (2) we have reason to believe that the chaplaincy, Purvis’s role, and his qualifications are different than you were led to believe. In fact, it appears that this chaplaincy is nothing more than a longstanding violation of the First Amendment that began during Bobby Bowden’s tenure. Bobby Bowden began a culture of disrespect for the separation of state and church On August 27, Bobby Bowden appeared on Fox News to discuss his new book, The Wisdom of Faith. 1 Bowden admitted to proselytizing his players. We also understand he instituted the chaplaincy to further that goal. It appears that this culture, which elevates coaches’ Christianity over the strictures laid out in our Constitution, continues. Elizabeth Hasselbeck gushed that Bowden “will feel himself a failure if he doesn’t share that message of Christ with others.” She continued, “But now teams are not going to be allowed—Orange County right now saying no place for faith in football. So that message that you’re giving coach, is not going to perhaps be allowed on the football field anymore, what do you think about that?” “Well, I do it anyway. I did it anyway at Florida State. I don’t care about political correctness,” Bowden responded. “I want to be spiritually correct.” This is a clear admission that he violated the Establishment Clause of the First Amendment. Mark Richt, Bowden’s former assistant coach, joined the interview and said that Bowden “did share his faith, actually, with the entire football team after the death of Pablo Lopez… He basically presented the Gospel to the team … He was talking to the team, but I was a young graduate assistant coach … right there I was convicted [sic] to go see coach the next morning and pray to receive Christ as my Lord and savior.” 1 August 27, 2014 appearance, at http://bit.ly/1ooX1tQ .

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The Freedom From Religion Foundation sent these letters to Florida State.

Transcript of Florida State Chaplains and Bowden

  • Sent via U.S. Mail and Email to: [email protected]

    September 12, 2014

    Ms. Carolyn Egan General Counsel, FSU PO Box 3060000 Tallahassee, FL 32306-1470

    Re: Chaplain and First Amendment violations in FSU football program

    Dear Attorney Egan:

    We corresponded in December 2012 regarding FSU footballs team chaplain, Clint Purvis, his role, and the chaplaincy generally. At that time, I requested records under the Florida Sunshine Law (Fl. Stat. 119). By way of reintroduction, the Freedom From Religion Foundation is a national non-profit with more than 21,000 members including more than 1,000 members in Florida. We protect the constitutional separation between state and church.

    I write again for two reasons: (1) the records request remains unfulfilled; and (2) we have reason to believe that the chaplaincy, Purviss role, and his qualifications are different than you were led to believe. In fact, it appears that this chaplaincy is nothing more than a longstanding violation of the First Amendment that began during Bobby Bowdens tenure.

    Bobby Bowden began a culture of disrespect for the separation of state and church On August 27, Bobby Bowden appeared on Fox News to discuss his new book, The Wisdom of Faith.1 Bowden admitted to proselytizing his players. We also understand he instituted the chaplaincy to further that goal. It appears that this culture, which elevates coaches Christianity over the strictures laid out in our Constitution, continues.

    Elizabeth Hasselbeck gushed that Bowden will feel himself a failure if he doesnt share that message of Christ with others. She continued, But now teams are not going to be allowedOrange County right now saying no place for faith in football. So that message that youre giving coach, is not going to perhaps be allowed on the football field anymore, what do you think about that?

    Well, I do it anyway. I did it anyway at Florida State. I dont care about political correctness, Bowden responded. I want to be spiritually correct. This is a clear admission that he violated the Establishment Clause of the First Amendment.

    Mark Richt, Bowdens former assistant coach, joined the interview and said that Bowden did share his faith, actually, with the entire football team after the death of Pablo Lopez He basically presented the Gospel to the team He was talking to the team, but I was a young graduate assistant coach right there I was convicted [sic] to go see coach the next morning and pray to receive Christ as my Lord and savior.

    1 August 27, 2014 appearance, at http://bit.ly/1ooX1tQ.

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    Bowden doubled down on trampling the constitution a few days later, I had to be like a father to these boys. Well, my father taught me about the Bible, my father taught me about church2 He complained about Orange County Public Schools correctly abolishing their football chaplains, Why in the world would we want to prevent God from being in these schools?3 On his Christian Broadcasting Network biography Bowden notes that he told his players they would be encouraged to attend church on Sunday.4 According to his pastor, Doug Dortch, God has given him a tremendous window of opportunity and Coach Bowden uses it faithfully and obediently. Virtually every message he shares contains the plan of salvation, and his heart is truly to see people come to a saving knowledge of Jesus Christ.5 Bowden would tell players, I don't want to offend your family or your parents, but I have a relationship [with Jesus], and if I don't tell you about it then I'd be doing wrong.6 Bowden assumed the title evangelist. [I]t is a good name, he said. I think more of it as trying to give my witness, but it does involve evangelizing thats what God wants me to do.7 Bowden established the chaplaincy to help spread his particular brand of Christianity We understand that Bowden established the team chaplain position, appointing Ken Smith to the position, in 1981. After hearing Smith speak at an FCA event, Bowden asked him to be the team chaplain. Not many people had chaplains and no one was sure what a chaplain did, said Smith. Coach Bowden just wanted someone who would work with Christian athletes.8 Purvis took over from Smith in 1988. Bowden hired Purvis from his own church.9 And Purvis, has come to mirror Coach Bowdens highly effective philosophy of ministry.10 In one of his books, Bowden wrote, I really tried to point the boys in the right direction. Our team chaplain, Clint Purvis, had Bible study during the week. We had a team chapel. We had a devotional before every coaching staff meeting. I had Christians speak to our teams before games. One time, Billy Graham spoke to my team before one of his revivals11 Incidentally, the former chaplain, Smith, confirmed Richts story above:

    Out of Pablo Lopezs death, assistant coach Mark Richt became a Christian, reminded Ken Smith, alluding to Georgias current head coach. Bobby became stronger in how he shared faith. When Lopez died, Ill never forget being in the hospital. Coach Bowden told me that night I will never again coach a kid where I dont know where he stands in his faith. And he

    2 Mike Bianchi, Bobby Bowden on Orange County schools: Why are we trying to kick God out of everything? Orlando Sentinel (Sept 3, 2014) at http://bit.ly/1rGBKl5 3 Id. 4 700 Club Guest Bio, at http://www.cbn.com/700club/guests/bios/Bobby-Bowden-090210.aspx 5 Allen Palmeri, Fla. State coach develops ministry masterpiece on gridiron, Baptist Press (Jan. 10, 2003) available at http://bpsports.net/bpsports.asp?ID=3710. 6 Id. 7 Id. 8 Don Leypoldt, Seminoles Run Recalls Strong FCA Roots, FCA.org (Jan. 4, 2014) at http://bit.ly/1Af62Mk; Ken Smith biography at Chaplains Connect, http://bit.ly/1u6Q6fr 9 Palmeri supra note 5. 10 Id. 11 Bobby Bowden, Called to Coach: Reflections on Life, Faith and Football, 143 (Simon & Schuster, 2011).

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    didnt. From there on, [Bowden] was very bold in sharing his faith and what it meant. He was never coercive or intimidating. He didnt hit anyone over the head with a Bible but he was very explicit in his relationship with Christ.12

    According to players, after that, [e]very meeting and practice started with a devotional. When I asked Coach why he did this, he said he wanted to make sure that every one of his players spot in Heaven was secure.13 Bowden sent the chaplain to players, not vice versa, he inevitably had a list of kids where he would ask [the chaplain] Can you go check on? and then hed give me some kids to check on.14 Bowden stated his goal most boldly in his book, Gods purpose for me was to go into coaching and try to influence young men for Jesus Christ. He wanted me not only to teach them to be good people but also to surrender their lives to Him. Disrespect for the rule of law and using fear to proselytize We are aware the Bowden retired after 2009 season, but we understand that this culture of disrespect continues. The coverage of Bowdens last Gator game is instructive. Bowden huddled with offensive coordinator and coach-in-waiting [and now head coach] Jimbo Fisher as players made their final preparations. Bowden and Fisher [joined] in a private prayer with team chaplain Clint Purvis. Fisher gave the pre-game talk to the players; Bowden led the team in prayer.15 There is a photo available online.16 In your previous letter, you wrote There is no evidence that Mr. Purvis or any FSU coaches proselytize or discuss religion absent a request from a student athlete. As you can see from the above admissions, there is ample evidence. Bowden and the chaplaincy he established show a shocking disrespect for this great nations founding document, the Constitution. Particularly disturbing are Bowden and the chaplains proselytizing, which can only be described as fear-mongering. Bowden and the chaplain used the death of a beloved teammate to terrify students, who looked to them as leaders, into believing in their particular religious brand. Lopezs horrifying murder is tragic, but no tragedy is an excuse to violate the Constitution. (Bowdens new team, the Fellowship of Christian Athletes, thinks differently. They publicly stated that God used the horror of Pablo Lopezs murder to advance His Kingdom.17) Chaplains travel with the team We also know that Bowden had chaplains travel with the team, Coach Bowden called and asked [Pastor Ken Smith] to come speak to the team. The next week he was invited to travel with the team to LSU. He sat in the stands until the third quarter when Coach asked him to come and stand with

    12 Leypoldt supra note 8. 13 Id. 14 Id. 15 Dan Coble, Emotional day begins, ends with walk for Bobby Bowden, Florida Times-Union (Jan. 1, 2010) at http://bit.ly/1vXcEBv; See also Garry Smits, Bowdens final practice ends with special huddle, Florida Times-Union (Dec. 31, 2009) at http://bit.ly/1CysLal 16 Available at http://bit.ly/1tyR997. 17 Leypoldt supra note 8.

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    him. That lasted for eight years as he became the volunteer chaplain. 18 Purvis continued this hands-on approach and even went on an FSU cruise with other coaches.19 Purvis appears to have a role in recruiting In 2012, you also wrote, Purvis does not recruit players or accompany coaches on recruitment visits. This appears fallacious: FSU wide receiver commitment C.J. Worton competed and looked good. He spoke well of his relationship with coach [Lawrence] Dawsey and team chaplain Clint Purvis.20 Purvis has also been photographed with recruits.21 He has talked extensively about FSUs recruiting, As we recruit athletesthen when we get them to Florida State22 He gave this sermon, introduced as Florida State Chaplain and wearing a shirt sporting Florida State University and the FSU logo. We remind you that this is FSU is a state institution that cannot affiliate with or endorse any church over another. Purvis does lead and has led the team in prayers You also stated that Purvis does not lead the team in prayers and that he only responds suitably to requests or inquiries from [those] who seek him out. It also appears that this is wrong given that coaches kept lists of players who the coaches instructed the chaplain to visit. Purvis has publicly said that he does a team devotional before every game.23 There are photographs of Purvis leading not only the Seminoles, but other teams in prayer.24 The caption even reads Purvis leads the Seminoles and the Bruins in a prayer. When discussing the religious activities of his athletes last year, Coach Fisher said that Purvis goes through the Scripture during chapel and that Purvis does our chapel.25 During Bowdens last practice, Purvis urged all of the players to come forward and had as many of them as possible put their hands on Bowden's shoulders and back, Purvis said later [the act] was a prayer of thanksgiving.26 Purviss religious training and the clear favoring of Christian students amounts to discrimination against non-Christian students. Purviss employment opens FSU to a discrimination lawsuit. No doubt Purvis intends, at least nominally, to assist people of all faiths as your last letter indicated. But employing only a Baptist chaplain is not non-denominational. It alienates nonreligious and non-Christian players and staff: 19% of adult Americans are nonreligious27 and 32% of Americans under the age of 30all FSU athletesare nonreligious.28

    18 Ken Smith biography at Chaplains Connect, http://bit.ly/1u6Q6fr 19 Jim Joanos, 2009 Seminole Cruise, Seminole Spotlight (April 2009) at http://bit.ly/1Bgnm6g 20 Bud Elliott, Florida State football recruiting, SB Nation (June 17, 2013) at http://bit.ly/1rGGDui 21 FSU great Deion Sanders inducted into college football Hall of Fame, Tallahassee.com (June 1, 2011) at http://bit.ly/ZaLbyC 22 Purvis sermon at Cross Church, Ark. (Sept. 29, 2011) at http://bit.ly/1reDzBB at 12:45 23 Id. at 10:30 24 See enclosed screenshot or http://bit.ly/1Cyx6dr; also, http://bit.ly/1rGOWWX 25 Scott Kotick, A Golden Promise, Seminoles.com (Jan. 26, 2013) at http://bit.ly/1qtNpDi 26 Smits supra note 15 27 Pew Forum, Asian Americans: A Mosaic of Faiths, 148 (July 2012) at http://pewrsr.ch/WlH40w 28 Nones on the Rise: One-in-Five Adults Have No Religious Affiliation, Pew Research Center, The Pew Forum on Religion & Public Life (October 9, 2012) available at http://pewrsr.ch/1lFciM7

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    These players should not be encouraged to compromise their beliefs and use religious support services. Nonreligious players are still on the team, but if they want help free from judgment by their superiors, they are forced to do so on their own time, or risk being subjected to the ministry of a Christian chaplain. All in all, this program discriminates against players by providing a Baptist chaplain who is only equipped to handle the needs of some. This program alienates and discriminates against nonbelievers and non-Christians. It is simply not true that chaplains can meet the needs of nonbelievers and believers of other faiths. If chaplains were adept at providing secular therapy, they would be therapists, not chaplains. There is no reason to think a nonbelieving player would be comfortable dealing with a person who provides comfort from a religious viewpoint. Chaplains cannot simply set aside their religion in order to assist a nonbeliever, and are often unwilling to even try to do so. Chaplains view the world and its problems through the lens of religion and a god, a view inapposite to nonbelievers. Claims that someone is in a better place or that a god works in mysterious ways may be the bedrock of religious consolation, but are meaningless and even hurtful trivialities to nonbelievers. A secular counselor would be equipped to counsel all players, and would be actually licensed to do so. Favoring religious players with free, on-field counseling and ignoring the needs of non-Christians or the nonreligious is discriminatory. Purviss qualifications may be significantly less than you have been told. Your last letter claims that Purvis holds masters degrees in counseling and psychology. In none of Mr. Purviss public biographies is it suggested that he has a degree in psychology. As for his counseling degree, other bios indicate that he attended Southwestern Baptist Theological Seminary where he got his MA in Counseling.29 Southwestern Baptist Theological Seminary does not offer an MA in Counseling. They do offer an MA in Biblical Counselinga significant difference

    The Masters of Arts in Biblical Counseling is a 66-hour program of study designed primarily to equip Christian men and women to minister Gods Word through counseling in the context of the local church or other Christian ministries. The degree includes 29 hours of theological preparation vital for effectively interpreting and ministering the Word of God. The counseling courses (37 hours) will prepare students to apply Gods Word in both formal and informal counseling settings.30 Most of these counseling courses are religious, like Principles of Biblical Counseling.31

    There is nothing in this description, and apparently nothing in Purvis background that equips him to deal with any non-Christian or non-religious players.

    Moreover, this counseling is a form of proselytizing that only exacerbates the constitutional problems with allowing Purvis access to students. In a recent expos of biblical counseling, Matthew Stanford, a professor of psychology and neuroscience at Baylor University, weighed in: I can honestly tell you, as someone whos been doing this for 20 years, that Ive never seen someone who has a serious mental illness that went to a biblical counselor and didnt actually get worse and get hurt, Stanford says. Ive never seen them get better.32 29 See Purvis, supra note 23; Florida Turfgrass Association speaker bio, at http://bit.ly/1ql6V56 30 See SWTBS website at http://bit.ly/ZaNem4 31 SWBTS course requirements for MA in Biblical Counseling, at http://bit.ly/1rGSit4 32 Kathryn Joyce, The Rise of Biblical Counseling, Pacific Standard Sept. 2, 2014) at http://bit.ly/1lFclaM

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    In other words, if he does not have degrees in secular counseling or psychology, Purvis presence probably harms student-athletes in need of genuine counseling. This makes the discrimination, establishment clause concerns, and factual allegations above significantly more egregious. We request that you further investigate and explain his qualifications. Athletic chaplains at public universities are unconstitutional Government chaplains may only exist as an accommodation of a public employees religious beliefs when the government makes it difficult or impossible to seek out private ministries. See Carter v. Broadlawns Medical Center, 857 F.2d 448 (8th Cir. 1988), cert. denied, 489 U.S. 1096 (1989) For instance, it may be difficult for military service members to find a place of worship while on mission in a foreign country or for an inmate in a prison to find a way to worship. Katcoff v. Marsh, 755 F.2d 223 (2d. Cir. 1985). Chaplains are meant to lighten the government-imposed burden on religious exercise. FSU football players have no government imposed burden on their religion so there is no needor legitimate legal reasonfor FSU to provide chaplains for them. Purviss employment, even if volunteer, demonstrates endorsement of religion, which is a violation of the Constitution. This violation cannot be cured by claiming that the players can voluntarily seek out Purvis (especially given the admissions that coaches tell Purvis which players to visit). First, players can seek out religious guidance at any of the other campus ministries or in the local community. The football team does not need to employ or host a volunteer chaplainindeed, it cannot legally do so. Second, voluntariness has never been used to excuse a constitutional violation. At the college level, voluntary prayers are unconstitutional if organized by university staff and if students would feel pressure to join, as any team member would. Mellen v. Bunting, 327 F.3d 355, 372 (4th Cir. 2003) (finding practice of holding religious prayers at dinner at state-operated military college was unconstitutional, though participation was voluntary). Given the serious and longstanding entanglement of the FSU football program with Purvis and other Baptist chaplains, we have no reason to believe this situation has changed. Your previous letter neglects does not comport with coaches statements or other public information. Clearly, the relationship between Seminole football and Christianity is out of bounds. In conclusion, we ask for (1) a full investigation into Purvis role and that FSU abolish athletic chaplaincies (2) the records in the attached request, and (3) that General Counsel issue a memo to FSU athletics teams outlining the appropriate boundaries between state and church. Sincerely,

    Andrew L. Seidel Attorney Freedom From Religion Foundation Enclosures: Open Records Request

    2012 Open Records Request never fulfilled screenshot of Purvis leading team in prayer FSU letter to FFRF, Dec. 21, 2012.

  • Sent via U.S. Mail and Email to: [email protected] September 12, 2014 Ms. Carolyn Egan General Counsel, FSU PO Box 3060000 Tallahassee, FL 32306-1470 Re: Open Records Request Dear Ms. Egan: I represent the Freedom From Religion Foundation (FFRF), a national nonprofit organization with members in Georgia that advocates for the separation of state and church. We request certain records related to chaplain Clint Purvis and the Florida State University (University) football program. If you do not maintain these records, please forward this letter to the appropriate records custodian and inform us that you have done so. For the purposes of this request, Chaplain refers to any of the chaplains predecessors, successors, assistants, co-chaplains, or anyone who fills the role of spiritual or religious counselor; Football Program means the University football team, which includes all coaches and football personnel, paid or unpaid, who regularly access the teams facilities; records, communications, or similar terms are meant to include, but not be limited to emails. Pursuant to the Florida Sunshine Law, Fla. Stat. 119.01, I hereby request the following records, from 2010 to the present:

    1. All Football Program, University, or Athletic Department policies concerning coach or clergy-led prayers for student athletes; this includes any policies regarding restrictions on coach or clergy-led prayers before athletic competitions, practices, or team functions;

    2. All Football Program, University, or Athletic Department schedules, notices, memos, emails, or announcements related to religious services, prayer gatherings, bible studies, Fellowship of Christian Athletes meetings, or other religious activities in which the Chaplain was involved;

    3. All communications, including but not limited to email, between Football Program staff

    and the Chaplain concerning the scheduling, planning, advertisement, or sponsoring of religious services, prayer gatherings, bible studies, bible distributions, or other religious activities for football players, staff, or their families;

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    4. All Football Program, University, or Athletic Department records related to theChaplains travel with the football team. This includes all travel plans, itineraries, andfinancial records, including any plane tickets, meals, or hotel stays arranged by theFootball Program, University, or Athletic Department;

    5. All Football Program, University, or Athletic Department records related to financialpayments or reimbursements made to the Chaplain;

    6. All Football Program, University, or Athletic Department job postings, or jobdescriptions concerning Football Program chaplains, or any other position primarilyrevolving around the spiritual development of football players; and

    7. Any other Football Program, University, or Athletic Department records related to theChaplains official or unofficial football team duties or activities.

    Please respond to this request without delay as required under Florida law. If more time is needed to gather information responsive to one or more of the items above, please indicate that in your response. If you choose to deny any part of this request, please provide a written explanation of the denial including any references to statutory exemptions or case law upon which you rely. If any of these records are available electronically, they may be e-mailed to [email protected].

    FFRF is a 501(c)3 non-profit that works to ensure government bodies comply with the First Amendment. As a non-profit working for the public interest, we request any fees associated with this request be waived or, at the very least, discounted.

    Thank you for your time and attention to this matter. Please feel free to contact me with any questions, concerns, or clarifications at [email protected] or 608-256-8900.

    Sincerely,

    Andrew Seidel Staff Attorney

  • FREEDOM FROM RELIGION foundation P.O. Box 750 . MADI SO N. W I 5370 1 . (608) 256-8 9 00 . WWW. F FRF . OR G

    SENT VIA MAIL & EMAIL to jelishw!fsu.edu

    November 27, 2012

    Ms. Jill Elish Interim Director Florida State University News and Research Communications 008 Westcott Bldg. Tallahassee FL 32306-1430

    Re: Sunshine Law Records Request

    Dear Ms. Elish:

    According to the FSU website (http://www.news.fsu.edu/For-Repo11ers/Publ ic-Records-Requests), public records requests should be directed to your office. If the website is inc01Tect, please forward this records request to the appropriate person or office.

    I understand that Florida State University employs Mr. Clint Purvis as team chaplain for the football and baseball teams and possibly other team sports as well. Pursuant to the Florida Sunshine Law (Fl. Stat. 11 9), I request the following records:

    1) A copy of any agreements between Purvis and Florida State University (or any division or subsidiary thereof) relating to employing or accepting Purvis as a volunteer since 1988.

    2) Any copies of relevant records, including but not limited to emails, from the past five years relating to costs associated with employing or accepting Purvis as a volunteer including, but not limited to, airfare or other travel, lodging, and meals.

    If your office does not maintain these public records, please let me know the proper custodians of these records. If any records are avai I able in electronic fo1mat, they may be emailed to [email protected].

    Thank you in advance for your time and attention to this matter. Please feel free to contact me with any questions, concerns or clarifications.

    Sincerely,

    ~5#1 Andrew L. Seidel Staff Attorney

    D an Barke r and Annie Laurie Gaylo r, Co-Prt!sidmts

  • THE FLORIDA STATE UNIVERSITY GENERAL COUNSEL Caroly11 A. Egan

    December 21 , 2012

    Andrew L. Seidel, Esq. Freedom From Religion Foundation P.O. Box 750 Madison, Wisconsin 53701

    Re: November 27, 2012 letter

    Dear Mr. Seidel:

    JAN 0 8 20i3

    This letter responds to your correspondence to Dr. Eric Barron, dated November 27, 2012. On behalf of Dr. Barron and Florida State University ("FSU") thank you for your letter and the opportunity to clarify some misconceptions about FSU's relationship with Mr. Clint Purvis.

    Mr. Purvis is not an employee of FSU. He serves as a volunteer advisor to student-athletes who seek his counsel. In his 24-year association with the FSU football team, Mr. Purvis has supported players of all faiths and no faith, providing appropriate guidance and directing them to appropriate resources when contacted. He holds master' s degrees in counseling and psychology and utilizes those skills when working with student-athletes far more than any religious-based training. When his counsel is sought by student-athletes, Mr. Purvis' longtime presence in the Tallahassee community provides him a unique ability to connect players who seek religious guidance with churches, synagogues, mosques, and temples in the area, as well as non-religious resources in which they may express interest. At no time does Mr. Purvis approach players, recruits, or family members in his advisory role. Rather, he responds suitably to requests or inquiries from student-athletes and others who seek him out.

    There is no evidence that Mr. Purvis or any FSU coaches proselytize or discuss religion absent a request from a student-athlete to engage in such discussion, as you suggested. Mr. Purvis does not lead team prayers, and participation in player-led prayer is strictly voluntary. He does not recruit players or accompany coaches on recruitment visits. Though it is not appropriate for me to comment on the private beliefs of any particular student-athlete, there is no basis for your conclusion that either of the players named in your letter--or any other players or students, for that matter-were coerced, proselytized, or compelled in any way to pray or briefly meditate with Mr. Purvis or any of the coaches.

    My office has reviewed the case law you cited, none of which involves collegiate athletics, and is confident that FSU' s relationship with Clint Purvis does not violate any applicable Jaws or

    2 12 Wesrcort, 222 Sourh Copeland Street, P.O . Box 3060000, Tallahassee, FL 32306-1470 850.644.3300 Fax 850.644.8973 www.fsu. edu

  • Andrew L. Seidel, Esq. December 21, 2012 Page 2

    unnecessarily entangle religion and public education. Still, we have taken this opportunity to more clearly define Mr. Purvis' role at FSU and engaged the First Baptist Church to ensure that their website accurately describes that role. Again, I thank you for your letter and wish you a good new year.

    Sincerely,

    /~fr, ~ \~G) l lfi)L6--v:'x Carol;n Egan CU General Counsel

    Cc: Dr. Eric Barron Randy Spetman, Director of Athletics

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