1. I am a resident of the State of New Hampshire and over the age of 18. In this declaration I have set forth my expert opinion based on my own research and studies of religion and religious practice. If called as a witness, I could and would testify competently under oath thereto.
2. I am an ordained minister of the United Methodist Church, a graduate of Denver University and the Iliff School of Theology in Denver, and I have taken graduate work in sociology at Columbia University. I am the author of a book on sociology of religion entitled Why Conservative Churches Are Growing (Harper & Row 1972, 1977, Mercer University Press, 1984), editor of several other works, such as The Uneasy Boundary: Church and State, Annals of the Academy of Political & Social Science, Vol 446, Nov. 1979; Government Intervention in Religious Affairs (1982); Government Intervention in Religious Affairs II (1986); and author of numerous articles in periodicals and chapters in anthologies and compilations. From 1960 until 1990 I was the executive for the office of Religious Liberty in the National Council of Churches, and since 1990 I have continued on retainer as Counselor on Religious Liberty to the National Council of Churches. I am providing this statement without remuneration or other inducement beyond my interest in and concern for the subject-matter discussed hereinunder.
3. I am not a member of the Church of Scientology or otherwise affiliated with it. I am, however, generally familiar with its beliefs and practices and have made a study – at the invitation of the Church – of whether it is a religion. After interviewing a number of members of that group chosen at random by me in various parts of the country selected by me, I came to the conclusion that Scientology is a religion because it was performing the function of religion, as I define it, for the persons I interviewed, viz., providing an explanation of the ultimate meaning of life to its adherents. In what follows I am not attesting to the truth or falsity of Scientology beliefs or the efficacy or inefficacy of its practices, which are not the business of others than its adherents and practitioners. What I am undertaking to do is to compare its efforts to maintain the confidentiality of some of its doctrinal and inculcative materials with those of other religions.
4. I have been asked to address particularly the contention by counsel for Uwe Geertz that the claimed confidentiality of the materials in question renders them non-religious. Nothing could be further from the truth. Confidentiality of religious material is a common historical phenomenon seen in many religions, including Christianity. It takes at least two forms -(1) preserving sacred doctrines and practices from profanation or ridicule by unbelieving outsiders, and (2) keeping advanced spiritual knowledge from adherents who are not yet ready to understand or utilize it. The later type of sequestration is reflected in the New Testament under the signs of “milk” and “meat” ("solid food” in RSV).
But I, brethren, could not address you as spiritual men, but as men of the flesh, as babes in Christ. I fed you with milk, not solid food: for you were not ready for it; and even yet you are not ready, for you are still of the flesh.(I Corinthians 3:1-2, Revised Standard Version)
For though by this time you ought to be teachers, you need someone to teach you again the first principles of God's word. You need milk, not solid food; for every one who lives on milk is unskilled in the word of righteousness, for he is a child. But solid food is for the mature, for those who have their faculties trained by practice to distinguish good from evil. (Hebrews 5:12-14, RSV)
5. This separation between the immature and the mature in the faith was reflected in the division during services of worship between the catechumens (those being trained in the catechism in preparation for baptism) and the fully initiated:
Public worship in the fourth and fifth centuries stood wholly under the influence of the conception of secret discipline, the so-called disciplina arcani, derived, it is probable, from... the mystery religions [discussed at #7 below].... Under these impulses the services were divided into two parts. The first was open to catechumens and the general public, and included Bible reading, singing, the sermon and prayer. To the second, the true Christina mystery, none but the baptized were admitted. It had its crown in the Lord's Supper, but the creed and the Lord's Prayer were also objects of reserve from those uninitiated by baptism. (Walker, Williston, A History of the Christian Church, Scribners, 1945, p. 167, emphasis added)
6. Because of this secrecy about their most sacred teachings and practices, the early Christians were viewed with suspicion by their Greek and Roman neighbors, who “made them the targets of extraordinary accusations, including charges of obscenity and even of cannibalism,” [perhaps because of rumors that they “ate” the flesh and blood of their divinity]. (Grant, M., History of Rome, Scribners, 1978, p. 403)
7. Among the rivals of early Christianity were the “mystery” religions, so-called because they each revolved around a secret myth and rite that were imparted to initiates after due preparation. Among these religions were the worship of Cybele, the Great Mother; of Mithra, the Sun God; of Isis and Osiris; of Dionysius; the Eleusinian Mysteries of Demeter, etc. Initiates into the religion of Cybele were bathed in the blood of a bull sacrificed above a trench called the taurobolium in which they huddled. Gods like Serapis and Osiris, Attis and Isis... joined a myth and a ceremony together: the compound was particularly strong in cults which kept their “myth” secret.... In a mystery cult... the relation between a mythical “secret” and a cult act was very close. By definition, we do not know what the particular mystery was, but plainly, it varied from cult to cult, as people continued to be initiated into many mysteries, not only one. (Fox, Robin Lane, Pagens and Christians, Knopf, 1983, p. 93, emphasis added.)
One of the attactions of these competing esoteric faiths was their secrecy – the lure of the unknown but disclosable "mystery" that only the members of the group could attain. The details of the “ritual [are] concealed from us by the discipline of the secret (arcanum).” (Eliade, M., Encyclopedia of Religion, Macmillan, 1987, X, p. 237, emphasis added)
8. Between the mystery religions and Christianity was another tradition that partook of traits of both – Gnosticism, named from the arcane gnosis or “knowledge” possessed by the adept.
God revealed to him the secrets concerning the final age concealed in their prophecies.... This was the secret knowledge that the Gnostics claimed to possess.... It was knowledge that freed, that revealed the mysteries of truth, that rent the veil that concealed how God controlled the creation....
The Gnostics were organized like mystery sects.... Upon initiation the Gnostic received an entirely new relation to spiritual authority. Each sect had its own baptismal ceremony, its passwords, its sacred meal.... Theirs were rites fit for the spiritual elite. These rites, moreover, must be kept guarded from the uninitiated. (Frend, W.H.C., The Rise of Christianity, Fortress, 1984, pp. 198-200, passim)
9. For each of these, the secret gnosis was a great attraction, a prize that drew converts who would pay for the necessary preliminaries and preparations that preceded initiation as well as for the initiation itself. If these were to be disclosed prematurely, the sect would lose one of its greatest assets, not only in financial, but in psychological terms. That which costs much must be worth much. Just as some counselors may believe that counselees will take more seriously the advice for which they must pay a lot, so some religions may believe that what costs little accomplishes little.
10. Similarly, as students pay tuition for advanced degrees, and universities depend upon those payments to support their faculty, so religions may arrange a sequence of spiritual advancement by gradations from one level of insight to the next. As one cannot comprehend the calculus without a foundation of arithmetic, geometry and algebra, so there are prerequisites in the realm of religion as well. I could not become a full-time professional pastor in the Methodist Church until I had been ordained an elder. I could not be ordained an elder until I had been ordained a deacon. I could not be ordained a deacon until I had completed two years of seminary, nor an elder until I had completed three. There are apprenticeships and progressions in all fields of serious human endeavor, and religion is no exception. It is not irreligious to require their sequential attainment and to protect against their being divulged without the necessary preparation.
11. In later ages, various religious groups observed varying degrees of secrecy. Among the Cathari of Southern France in the twelfth century, there were two classes of adherents, the ordinary followers and the perfecti. The latter were elevated through a ceremony known as the consolamentum after a year or more of preparation, including “full revelation of Cathar teaching, which was not accessible to the ordinary adherents.” (Leff, G., “Cathari,” in Eliade, M., supra, III, p. 116) The various orders of Rosicrucians of the last two centuries pledged their members to secrecy. (Ibid.,XII,476-7)
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed at West Swanzey, New Hampshire, this 26th day of November, 1994.
Dean M. Kelley
Counselor on Religious Liberty
National Council of the Churches of Christ in the USA
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