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A recent Third Circuit case reminds us that facts do matter and that, at least in the world of public education, fictional “history” and conspiracy theories may not be foisted on the public in the guise of a history lesson. Ali v. Woodbridge Twp. School District, 957 F.3d 174 (April 22, 2020). In the Ali case, a non-tenured public high school teacher who taught in New Jersey in the Woodbridge High School from September 2015 to September 2016, was teaching Holocaust denial to his students and was posting links to articles on the school’s website saying things like, “The Jews are like a cancer” and expressing conspiracy theories accusing the United States of planning a 9/11-style attack.

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