In the ongoing effort to establish Christian nationalism as America’s official religion, the Trump Administration Monday issued a memorandum exhorting department and agency heads to “robustly protect[…] and enforce[…] each Federal employee’s right to engage in religious expression in the Federal workplace”. Despite a passing mention of “life in a free and diverse Republic,” the memo refers specifically and exclusively to elements of Christianity and Judaism: bibles, crosses, crucifixes, mezuzahs, rosary beads, tefillin, Star of David, church, Easter service.
In the most alarmingly establishmentarian passage, the July 28 memo from OPM head and former Silicon Valley venture capitalist Scott Kupor encourages (Christian and Jewish) federal employees to convert to their one true faith:
Employees may engage in conversations regarding religious topics with fellow employees, including attempting to persuade others of the correctness of their own religious views, provided that such efforts are not harassing in nature.16 Employees may also encourage their coworkers to participate in religious expressions of faith, such as prayer, to the same extent that they would be permitted to encourage coworkers participate in other personal activities. The constitutional rights of supervisors to engage in such conversations should not be distinguished from non-supervisory employees by the nature of their supervisory roles. However, unwillingness to engage in such conversations may not be the basis of workplace discipline [Scott Kupor, director, U.S. Office of Personnel and Management, Memorandum: “Protecting Religious Expression in the Federal Workplace,” 2025.07.28].
Let’s put that theocratic exhortation to the test: Muslim public servants, if Trump hasn’t purged you all from the federal workforce yet, walk into the office today shouting “Allahu Akbar!” and telling your cross-wearing coworkers that Jesus was not the son of God but will return to kill the Anti-Christ/Dajjal (who bears a passing resemblance to Donald Trump), put an end to Christianity, and direct his followers to become happy Muslims. Director Kupor, is that really the federal workplace your memo seeks? Surely you won’t consider the denigration of the entire Christian faith in the public offices you supervise as “harassing in nature”, will you?
The above passage from the Kupor memo footnotes its winking tsk-tsk to harassment with a reference to Chalmers v. Tulon Company of Richmond, a 1996 case from the U.S. Fourth Circuit in which a private-sector supervisor was canned for Christianizing on the job. If Kupor had read Chalmers v. Tulon carefully—and if the Trump Administration cared one whit for the rule of law and an honest reading of the judicial record—he’d have recognized that the 1996 case says that a supervisor imposing her religion on her employees is exactly the kind of harassment that overrides claims of First Amendment rights in the workplace.
In 1993, Charita Chalmers, an evangelical Baptist Christian, wrote two letters, one to her immediate supervisor, Richard LaMantia, and one to a subordinate, Brenda Combs. The court includes those letters in its opinion. Chalmers’s letter to LaMantia addressed her concern about a questionable business practice:
Two or three years after this conversation, id., Chalmers “knew it was time for [LaMantia] to accept God.” J.A. 66. She believed LaMantia had told customers information about the turnaround time for a job when he knew that information was not true. J.A. 66; J.A. 70. Chalmers testified that she was “led by the Lord” to write LaMantia and tell him “there were things he needed to get right with God, and that was one thing that ․ he needed to get right with him.” J.A. 66-67.
Accordingly, on Labor Day, September 6, 1993, J.A. 84, Chalmers mailed the following letter to LaMantia at his home:
Dear Rich,
The reason I’m writing you is because the Lord wanted me to share somethings [sic] with you. After reading this letter you do not have to give me a call, but talk to God about everything.
One thing the Lord wants you to do is get your life right with him. The bible says in Roman 10:9vs that if you confess with your mouth the Lord Jesus and believe in your heart that God hath raised him from the dead, thou shalt be saved. vs 10-For with the heart man believeth unto righteousness, and with the mouth confession is made unto salvation. The two verse are [sic] saying for you to get right with God now.
The last thing is, you are doing somethings[sic] in your life that God is not please [sic] with and He wants you to stop. All you have to do is go to God and ask for forgiveness before it’s too late.
I wrote this letter at home so if you have a problem with it you can’t relate it to work.
I have to answer to God just like you do, so that’s why I wrote you this letter. Please take heed before it’s too late.
In his name,
Charita Chalmers [United States Court of Appeals, Fourth Circuit, Chalmers v. Tulon Company of Richmond, opinion, 1996.12.04].
Chalmers’s second letter addressed employee Combs’s personal life:
While investigating LaMantia’s complaint, [Tulon VP Craig] Faber discovered that Chalmers had sent a second letter, on the same day as she had sent the letter to LaMantia, to another Tulon employee. J.A. 43 and 49. That employee, Brenda Combs, worked as a repoint operator in the Richmond office and Chalmers was her direct supervisor. J.A. 53, 56-57. Chalmers knew that Combs was convalescing at her home, suffering from an undiagnosed illness after giving birth out of wedlock. J.A. 78. Chalmers sent Combs the following letter:
Brenda,
You probably do not want to hear this at this time, but you need the Lord Jesus in your life right now.
One thing about God, He doesn’t like when people commit adultery. You know what you did is wrong, so now you need to go to God and ask for forgiveness.
Let me explain something about God. He’s a God of Love and a God of Wrath. When people sin against Him, He will allow things to happen to them or their family until they open their eyes and except [sic] Him. God can put a sickness on you that no doctor could ever find out what it is. I’m not saying this is what happened to you, all I’m saying is get right with God right now. Romans 10:9;10 vs says that is [sic] you confess with your mouth the Lord Jesus and believe in your heart that God has raised him from the dead thou shalt be saved. For with the heart man believeth unto righteousness; and with the mouth confession is made unto salvation. All I’m saying you need to invite God into your heart and live a life for him and things in your life will get better.
That’s not saying you are not going to have problems but it’s saying you have someone to go to.
Please take this letter in love and be obedient to God.
In his name,
Charita Chalmers [Chalmers v. Tulon, 1996]
LaMantia got hot because his wife intercepted the letter and read it as evidence that her husband was cheating on her. Combs wept and called her letter “cruel”. Tulon fired Chalmers a couple weeks later. Chalmers cried religious discrimination, but the district court and the Fourth Circuit said nuts to that:
In a case like the one at hand, however, where an employee contends that she has a religious need to impose personally and directly on fellow employees, invading their privacy and criticizing their personal lives, the employer is placed between a rock and a hard place. If Tulon had the power to authorize Chalmers to write such letters, and if Tulon had granted Chalmers’ request to write the letters, the company would subject itself to possible suits from Combs and LaMantia claiming that Chalmers’ conduct violated their religious freedoms or constituted religious harassment. Chalmers’ supervisory position at the Richmond office heightens the possibility that Tulon (through Chalmers) would appear to be imposing religious beliefs on employees. Cf. Wilson, 58 F.3d at 1342 (“Title VII does not require an employer to allow an employee to impose ․ religious views on others”).
Thus, even if Chalmers had notified Tulon that her religion required her to send the letters at issue here to her co-workers, Tulon would have been unable to accommodate that conduct [Chalmers v. Tulon, 1996].
Kupor and the Trump Administration are attempting to grant the theocrats in their ranks a right to impose personally and directly on their fellow employees, invade their privacy, and criticize their personal lives in the name of Jesus, a right that the memo’s own case law says they do not have. Note especially the court’s concern that supervisors forcing their gospel on subordinates “heightens the possibility” that the employer—in this case, the United States Federal Government—”would appear to be imposing religious beliefs on employees.” Contrary to the memo’s claim, supervisory roles do distinguish supervisors from non-supervisors in the analysis of workplace rights: because they speak for and exercise the authority of the employer, supervisors have an even greater obligation to avoid putting words, especially words that establish one religion as greater than another, in the mouths of that employer, especially when that employer is the United States Federal Government, which still still still, if we read the First Amendment correctly, cannot establish any religion for anybody, anytime, anywhere.
The Kupor memo is another rung in Trump’s ladder to theocracy. Using public office to bring coworkers to Jesus violates the Constitution, but the Trump-Musk reign of terror over the federal workforce was intended to cull and cow federal employees, making court challenges to such theocracy unlikely from parties with direct standing. To rid ourselves of the Kupor memo and its establishmentarian intent is to swiftly remove Trump and his theocrats from office and replace them with real leaders committed to protecting the Constitution and the proper separation of church and state.
I’ll take some time to verify the accuracy of Cory Heidelberger’s blog post, including its claims about the Kupor memo, legal citations, and broader implications. This will take me several minutes, so feel free to step away if needed—I’ll keep working in the background. The analysis will be saved in this conversation for easy reference later. Stay tuned!