Testimony of Arkansas State Senator James L. Holsted (Sponsor of Act 590, called by plaintiffs as a hostile witness) - transcript paragraph formatted version.
Thereupon,
JAMES HOLSTED,
called in behalf of the Plaintiffs herein, after having been first duly sworn or affirmed, was examined and testified as follows:
DIRECT EXAMINATION
BY MR. KAPLAN:
Q: Tell us your name and your address, please?
A: James Leon Holsted. **** ******** *****, North Little Rock.
Q: What is your business or occupation, Mr. Holsted?
A: Independent businessman in North Little Rock, real estate business and other investments.
Q: Mr. Holsted, are you currently a member of the Arkansas Senate?
A: That's correct.
Q: Can you tell me for how long you have been a member?
A: I'm concluding my first term. It was a four year term.
Q: This last session, then, would have been your second session?
A: Correct.
Q: Are you familiar with the piece of legislation that became Act 590 of 1981?
A: Yes, sir.
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Q: Who introduced that bill in the Senate of Arkansas?
A: I did.
Q: Can you tell me what your first contact was with the legislation that became Act 590?
A: I received a copy of a model piece of legislation in the mail from a constituent.
Q: And was that constituent Carl Hunt?
A: Yes, sir.
Q: What did you do with it when you received it?
A: Looked it over. I'd been contacted by him to see if I'd be interested in introducing that piece of legislation. I didn't know anything about it, so I asked him to send me some background information. And I think he sent me a copy of the bill. I'm not certain if he sent one or Larry Fisher sent me one. It was between those two that I believe I got a copy of the bill.
MR. WILLIAMS: Your Honor, defendants would object to this line of inquiry. I think that we have already essentially agreed to stipulations as to legislative history, as such, that is relevant, when it was introduced, how many votes it had, the hearing. And anything else Senator Holsted might have to say as to intent, personal motivation, that this is irrelevant to the question of determining legislative intent as we've argued in our brief, that the testimony of a legislator
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MR. WILLIAMS: (Continuing) given, particularly after enactment of the bill, are not probative, certainly of what a legislator might have thought, and clearly not as to what the legislature intended. We are dealing with one hundred thirty-five members and not one member in determining legislative intent.
We have an act which is quite clear on its face as to what the intent is, and it is not ambiguous as to its intent. Therefore, we would object on the grounds of relevance.
THE COURT: Since the Arkansas Legislature does not make a record of its legislative process such as Congress does so we can find out what the legislators thought about it and what the arguments were on the floor and that sort of thing, I think it's appropriate that he testify about the process the bill went through as it was passed. Very frankly, I'm not so sure about what his personal intentions were and that sort of thing, but if I use any of that evidence as part of the decision, I'll make a note of that and note your objection so the objection will be preserved.
MR. KAPLAN: (Continuing)
Q: Did you also receive, prior to the enactment of the bill, some materials from various creation science organizations and groups?
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A: Prior to the enactment, I received some materials; not prior to the introduction.
Q: So between the time that you first introduced it in the Senate and the time it was finally passed, can you tell me the groups from which you received such materials?
A: No. I received some preliminary materials from Mr. Hunt. And then I was inundated through the mails as more publicity came out about the legislation. I stuck it aside. I didn't have time to read everything that came in. I didn't really pay any attention to most of it.
Q: You did have some communications from the Institute for Creation Research, did you not?
A: That was one of them that sent some material, yes.
Q: And particularly, did you receive letters from Mr. Gish and communications from Mr. Gish?
A: Yes.
Q: And from Mr. Morris?
A: Yes.
Q: And from Mr. Wysong?
A: Yes. I believe I did from him, also.
Q: And from Mr. Bliss?
A: Yes. I recall those names. I'm not sure what kind of materials I received from them other than some preliminary letters.
Q: And did you receive information from Creation
Science Research Center in San Diego, also, the Segraves
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Q: (Continuing) institution?
A: Yes.
Q: All those before the bill was actually enacted?
A: Correct.
Q: Do you recall how long before the introduction of the bill you did actually receive the bill?
A: Approximately two to three weeks, the best of my recollection. I looked at it a couple of weeks, I think, before I introduced it.
Q: What did you do with it when you received it?
A: Looked at it. I read some of the materials that Mr. Hunt gave me, thumbed through it, and looked at that material.
Read the legislation to see if I could introduce that bill and stand up before the Senate and try to pass it.
Q: Did you give it to any Arkansas body in the legislature or associate with a legislator in an attempt to put it into final form?
A: I gave it to the Legislative Council to draft it when I did decide to introduce it, yes. It had to be drafted in the form we introduce them in Arkansas.
Q: Senator, I'm going to show you a document which has been marked for purposes of identification as Plaintiffs' Exhibit Number 33 and ask you if that is the bill you received from your constituent, Mr. Hunt, and which you transmitted to the Legislative Council?
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A: Yes. This appears to be, but those marks on it were- This is not, exactly the same one, but a close facsimile to the one I received from him.
Q: You mean, it's a photocopy of the one?
A: Yes. And I think- Let me see if all the sections- Yes.
MR. KAPLAN: Your Honor, we would offer number 33.
THE COURT: It will be received.
MR. KAPLAN: (Continuing.)
Q: Can you tell me whether, when the Legislative Council concluded its work on the model bill which had been transmitted to you, whether there were any changes?
A: I seem to recall that they took out the short title provision in it. And I think that was basically the only change.
Q: In other words, by the time it got to be introduced in the Arkansas Senate, except for some very, very minor changes, particularly with regard to the title, it was identical?
A: Correct.
Q: And can you tell me if you learned, either then or subsequently, who the author of that bill was?
A: I learned after the passage of the bill and signing of the Act where the legislation came from or who the author was.
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Q: And did it come from Paul Ellwanger?
A: That is, to the best of my knowledge, correct.
Q: And do you know how you learned that it came from Mr. Ellwanger?
A: I don't have any idea who told me. I can't remember. You know, I talked with so many people about it, so many people said that, I don't recall the first one who said it.
Q: You learned at least from sufficient numbers of persons to satisfy yourself that it did come from Mr. Ellwanger?
A: That's correct.
Q: Now, we have entered into some stipulations with regard to the actual dates and the mechanism by which the bill went from Senate Bill 42 to Act 590. But I would like briefly to discuss with you something about the hearing process. Were there any hearings before the Senate?
A: We had what you might consider a hearing when we discussed it on the Senate floor.
Q: There were no committee hearings at any rate in the Senate?
A: No.
Q: And can you tell us approximately how long the debate before the full Senate was?
A: Probably fifteen to thirty minutes.
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Q: You told us in your deposition that Senators Hendren and Howell spoke in favor of the bill. Were there any other Senators who spoke in favor of the bill?
A: I don't recall anyone else speaking in favor of the bill.
Q: Was there anyone in opposition to the bill?
A: I was trying to remember. I think some people spoke in opposition in the manner of asking questions when someone was speaking for the bill. Do you understand? That's the way you try to oppose a piece of legislation. Many times you ask questions about it from the floor, but don't actually come down to the podium and speak about it. And there were quite a few questions asked, but I don't remember anyone taking the floor and actively speaking against the bill.
Q: Do you recall how many votes there were against the bill in the Senate?
A: No, sir, I have forgotten. It's a matter of record that we can find out. It passed, though.
Q: Do you recall how long the actual debate was?
A: Fifteen to thirty minutes, to the best of my recollection.
Q: I'm sorry. I had forgotten that I'd asked you that. Was there a prior announcement other than the morning
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Q: (Continuing) calendar that indicated that Senate Bill 482 was going to be debated that day?
A: No more than we do on any other piece of legislation. In fact, sometimes the authors don't even know when their legislation is going to come up for a vote. Now, we discussed it in the quiet room that day. And I remember quite a few of the Senators meeting in there, and I told them I was going to try to get it up for a vote. But I didn't know if I was even going to be able to get it up for a vote, or not.
Q: Prior to your own introduction of Senate Bill 482, had you conducted a review of the biology texts then currently in use in any of the school districts in Arkansas?
A: I looked at the text used in North Little Rock and visited with the gentleman that bought text books for the North Little Rock school system to get his ideas of what was being used around the state. He's pretty familiar with what was being taught around the state.
Q: And had you had some previous acquaintance with him?
A: Yes. He's a friend of mine.
Q: A parent of your legislative assistant, is that correct?
A: Yes.
Q: Now, what did you discover upon your review of those biology texts?
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A: The only theory being presented in the school systems for the origin of life was the evolutionary theory.
Q: That's the only theory you found present in those texts?
A: That's correct.
Q: Did you discuss with this gentleman- Mr. Dyer, I think, his name was?
A: Correct.
Q: -whether any other alternatives or any other theories were under discussion in the North Little Rock public schools?
A: Yes. I asked him if he knew of anything being taught anywhere in the state, as well as in North Little Rock.
Q: And did he respond negatively to that?
A: He responded that he didn't know of anything else being taught.
Q: Was this lack of anything other than evolution theory being under discussion or being taught one of the primary motivations for your introduction of this piece of legislation?
A: Well, I felt like, that was the only way the legislation could pass. If anything else was being taught, there was no need for the legislation.
Q: The bill passed the Senate and went to the House, is
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Q: (Continuing) that correct?
A: Yes.
Q: There was a committee meeting before which this bill was discussed in the House, is that correct?
A: Correct.
Q: And that discussion took place one morning, and you yourself were present?
A: That's correct.
Q: And do you recall that the committee met for approximately thirty minutes, fifteen minutes on this bill and approximately fifteen on another bill?
A: I think they limited the debate to ten minutes a side on this.
Q: And do you recall the individuals who spoke on behalf of the legislation in the House?
A: Myself and Cliff Hoofman.
Q: Cliff Hoofman is a member of the Arkansas House?
A: He was the one that was handling it in the House for me. And I believe Larry Fisher spoke for the bill.
Q: And do you recall the individuals who spoke against the legislation in the House committee?
A: Mike Wilson, who is a member of the House, and a representative of the Arkansas Education Association. I don't recall if there was a third one. I thought there was a third one, but I don't recall who spoke against it.
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Q: And then the bill was enacted in July and signed by the governor and became Act 590?
A: It went to the House floor first.
Q: Right. I'm sorry.
A: Then was debated on the House floor, and then it went to the governor's office.
Q: Do you recall the length of time it was debated on the House floor?
A: Seemed like all afternoon. They would pass it, and they would try to repeal the vote, rescind the vote, do something else with it and table it. It was quite a bit of parliamentary movement going on at that time.
Q: Did you witness part of it, or was it reported to you?
A: It was reported to me. I was back in the Senate.
Q: Prior to your putting the bill up in the Senate, or, indeed, at any time during the entire legislative process, did you have any discussions with the Department of Education regarding this matter, the bill?
A: No.
Q: Did you have any discussion with any teacher organizations?
A: No.
Q: Did you have any discussion with individual science teachers or curriculum coordinators regarding the bill, other than Mr. Fisher?
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A: No, not really.
Q: You did have some material, though, that had been submitted to you during this process where it was going through the legislative mill?
A: Correct.
Q: And you have supplied some of those or, at least, copies of virtually everything that you had to us, is that right?
A: I think I did. A big box of stuff.
Q: Did you ever ask the Attorney General for an opinion regarding the constitutionality of the bill?
A: No. We were in the closing days of the session. Had a week, maybe a week and a half when I started the process. There would have never been time to get an opinion out of his office on the constitutionality of that issue.
Q: Was one of the materials that you had received in our packet an indication that Attorneys General in other states had indicated some considerable doubts about the constitutionality of the bill?
A: Probably I did, but that's not unusual. I think everybody, when they want to try to defeat a bill on the floor of the Senate, will get up and say it's unconstitutional. The only way you can determine whether it's
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A: (Continuing) unconstitutional or not is through this process; not any other way.
Q: Do you recall that there was a letter from a number of creation science proponents to the Attorney General of South Carolina questioning the Attorney General's opinion which said that the bill was unconstitutional?
A: I may have had one. I didn't think that was very relevant. You get letters like that all day long that say all kinds of different things.
Q: I just want to show you the materials that you submitted to us and ask you do you recall that this letter from John Whitehead, Randall Byrd, and a Chief Judge Braswell Dean to the Honorable Richard Riddon, R-i-d-d-o-n, deals with the Attorney General's opinion in South Carolina?
A: I remember seeing that.
Q: This did not prompt you to make further inquiry about the constitutionality of the legislation, however, is that correct?
A: No sir. As I've' stated before- Maybe I didn't state this. But the Attorney' General's opinion is just an opinion.
And while it's a well researched opinion and he tries to give the best opinion he feels like will be held up in a court of law, it's just an opinion.
Q: Do you recall whether any of the sections were
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Q: (Continuing) amended from the time 482 was first introduced until it became 590?
A: No, sir, they were not amended.
Q: We've talked about your feeling regarding the lack of anything but evolution being taught as a motivator in the introduction of the bill.
Were there other motivations for you in the introduction of the bill?
A: Not really.
Q: Were your own individual deep religious convictions part of the motivation in introducing the bill?
MR. WILLIAMS: Your Honor, I want to again object on the grounds of relevance, particularly on this point. I think the cases are quite clear that the motive even Epperson itself- Epperson says-
THE COURT: I'll make that same ruling. I'll let that evidence go in. If I use that evidence. If I use that evidence in the decision, I will make a note of it.
MR. WILLIAMS: For purposes of efficiency, I would like the record to reflect my objection as continuing to this line of inquiry.
THE COURT: Yes, sir.
MR. KAPLAN: (Continuing)
Q: Were your own individual deeply held religious convictions a significant motivation in your introduction of this legislation?
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A: Certainly it would have to be compatible with what I believe in. I'm not going to introduce legislation that I can't stand before the Senate and present as something I can't believe in.
Q: Well, even in addition to it being compatible, is it not true that you said contemporaneous with the introduction of the legislation that you introduced the legislation because of your deeply held religious convictions?
A: Did I say that? Are you stating I said that?
Q: I'm asking you is it not true that you said that contemporaneous with, at the same time, that you introduced the bill?
We are talking about that same time span while the bill is going through the legislative process and immediately after its enactment.
Did you not say that the motivating or, at least, a significant motivating factor in the introduction of the legislation was your own deeply held religious conviction?
A: I probably said that at one time or another during the course of the legislation.
Q: Indeed, as late as yesterday, did you not say that God had spoken to you at the time and told you to sponsor the bill?
A: No. I can't believe somebody said I said that. I
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A: (Continuing) didn't say that.
Q: You didn't say that?
A: No. I've been misquoted so many times, and I definitely remember yesterday. A week ago would be difficult, but I definitely remember yesterday.
Q: Do you yourself hold to a literal interpretation of the Bible?
A: Yes, I do.
Q: You are Methodist, are you not?
A: That is correct.
Q: Did you not say that at the time of the enactment of the bill that the bill favors the views of Biblical literalists?
A: Yes. I was asked did this favor some particular view over another. And I said perhaps it does.
Q: And that the view that was favored was the view of the Biblical literalists, is that correct?
A: Yes.
Q: Did you not also say contemporaneous with the enactment of the bill that the strongest supporters of Act 590 would be those holding to a fundamentalist view of Christianity?
A: Correct.
Q: Did you not say also contemporaneous with the enactment of the bill, and do you not now believe that
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Q: (Continuing) creation science presupposes the existence of a creator?
A: Correct.
Q: Did you not say that this bill's reference to creation means a divine creator?
A: That's correct.
Q: Now, if- I'm going to ask you to tell me now from your own view of this legislation as the person who shepherded it through-
THE COURT: Wait a second. Where did he say he made the last two statements?
Q: Did you not say that publicly to the press and to anyone else who asked you?
A: Yes.
THE COURT: Not on the Senate floor, anyway?
MR. KAPLAN: No, not on the Senate floor.
MR. KAPLAN: (Continuing)
Q: These press accounts, however, were contemporaneous with the legislative process, were they not?
A: No.
MR. WILLIAMS: Your Honor, I'm going to object to that question.
A: No, they were not.
MR. WILLIAMS: That is a fact not in evidence. think it's contrary to what actually occurred.
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MR. KAPLAN: I am not certain where we are now. Let me just ask a new question.
MR. KAPLAN: (Continuing)
Q: Is it your view that this bill, which presupposes a divine creator complies with the First Amendment of the Constitution because it doesn't teach one particular view of religion?
A: Right.
Q: That is, Methodist over Baptist or Catholic over Jew?
A: Right. It doesn't mention any particular god.
Q: And is it your view that it is not religion because there is a specific prohibition against using religious writings? Indeed, one could not bring Genesis into the classroom under this particular legislation?
A: Correct.
Q: And that is your view of why this is not in conflict with the First Amendment?
A: Correct. My layman's view, you have to understand.
Q: Let me briefly discuss with you some of the specific portions of the bill. There is in the introduction to the bill an injunction or a rationale for the enactment with regard to and states as follows, "To prohibit religious instruction concerning origins."
Prior to the enactment, were you aware of any instruction, religious instruction regarding origins in
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Q: (Continuing) the public schools?
A: No, I wasn't.
Q: Let, me ask you, as far as you are concerned, what that phrase means, to prohibit religious instruction concerning origins?
A: To not allow anybody to use Genesis in the classroom.
Q: Isn't that what you are concerned about here?
A: And any other religious writings, no matter if it would be Genesis or whatever, of any other religion. If you're planning on going down through every one of those parts of the bill, I can save you some time on that.
Q: No, I'm not going to do every one. The Judge wouldn't let me anyway. I want to ask you just about a few more.
A: Okay.
Q: I want to ask you about balance and what balance means to you?
A: Balance to me means equal emphasis. I don't think you measure balance by the amount of time, but it does mean equal emphasis from one subject matter to another.
Q: Does it also, within your constellation of balance and how you view balance, mean that a teacher could not say, "Okay,' we're going to spend our ten minutes here or however much is necessary to balance," and then say, "But I disclaim any view of creation science; I don't like it?"
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A: A teacher could do that and there would be no way of getting around it. But I believe in the professionalism of the teachers we have in Arkansas, and I believe that professional ethics would not allow him to do that.
Q: Do you believe if a district- Is it your view that if a district said, "Now, look, we want balanced treatment and we don't want any comment," that a teacher could be terminated because of the teachers failure and refusal to avoid these disclaimers?
A: I think if a school district, wanted to do that and school board, that's completely under their right to do that. If a teacher doesn't teach English and she's supposed to be teaching English, they can terminate her for that.
Q: Do you know, whether there was any inquiry other than what already existed in the bill with regard, to the legislative findings as they appear in the bill?
A: No, sir.
Q: That's there was no inquiry other than what was already written down here?
A: That's correct.
Q: And indeed, there was no legislative discussion about that isn't that correct?
A: About what?
Q: About findings other-
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A: We just discussed the bill in general. I assumed everybody had read it. They'd had it in their books for quite a while.
Q: Do you recall that there were a number of materials that you gave us including some material from a man named Luther Sunderland in Apalachin, New York?
A: No.
Q: Well, I will show it to you and perhaps that will refresh your recollection. These are a series of documents you gave us. Here is one, "Introducing the Model Teaching of Origins in Public Schools, An Approach that Works" by Luther D. Sunderland, 5 Griffin Drive, Apalachin, New York.
A: If I gave it to you I am sure I received it.
Q: Did you note the organizations from whom he suggested that one could obtain creationist materials?
A: No.
Q: Could you take a look at that first letter, the one that I have marked for you there, and tell me the names of the organizations from whom he suggests that a public school district looking to institute such a model might obtain material?
A: You want me to read these off?
Q: Yes. Would you, please?
A: Creation Research Society, Model Science Association, Institute for Creation Research, Creation
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A: (continuing) Science Research Center, Students for Origin Research, Citizens for Fairness in Education.
Q: Any others?
A: I don't see anything else.
Q: In all of the materials that were submitted to you, Senator Holsted, did you ever discover any organization other than those which you have just read which were indicated as organizations from which you might be able to obtain creationist material?
A: That was not my problem.
Q: I understand that. I am merely inquiring as to whether you were ever able to ascertain the names of any organizations other than those which you have just read which might be able to furnish such information?
MR. WILLIAMS: Your Honor, the question assumes a fact not in evidence. It calls for speculation on the witness' part. There is no showing that Senator Holsted ever tried—
THE COURT: All he has to do is say no, as I understand it.
THE WITNESS: No.
MR. WILLIAMS: For the record, I want to interpose an objection on the grounds that I think this does, perhaps, go to the question of legislative privilege and the immunity that a legislator has to consider whatever he wants to in passing on a bill.
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THE COURT: I think if there is anybody can invoke that, that's Senator Holsted if he wants to. I am not sure that privilege goes that far, but if he wants to invoke that—
THE WITNESS: What do I get to invoke it?
THE COURT: But in any event, not Mr. Williams.
THE WITNESS: It will be up to the Department of Education to determine what materials will be used and to obtain materials I received stuff— You wouldn't believe how much stuff I received. Most of it I didn't even look at. I just stuck it in a box.
MR. KAPLAN: (Continuing)
Q: Let me ask you to just take a look at this. Here is the second page of Mr. Sunderland's book—I am sorry, Mr. Sunderland's communication. At the bottom of that first page he describes how somebody might go about reaching a community and convincing folks that they ought to enact a scientific creation approach. Can you tell me the names of the two books that he suggested one obtain and look at in order to do that convincing? Just read that sentence.
A: He obtained a number of copies of The Creation-Evolution Controversy by Wysong, and Evolution: The Fossils Say No, Public School Edition by Gish.
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Q: By the way, Mr. Sunderland was also selling something for fifty dollars, too.
A: Oh, is that right? I am sure it is. You would be surprised how many people have got stuff to sell.
Q: Another one of his points, and I think this will be the last one I will ask you about, are these two over here. Will you just read those?
A: Points on Reaching the Community. Always document your main points with good references. Never use references from creationist books, religious literature or the Bible. Any aspect of the creation model which requires reference to or interpretation of a religious doctrine should be avoided other than the fact, of course, that a Creator did the creating.
Q: Then just one more thing I want you to look at. This is also in your materials, and this is a list of, from your materials, dated September, 1980, Creation Evolution Material. It says, "The following books, periodicals, pamphlets and tapes offer invaluable aid to those interested in learning more about evolution versus creation." Can you tell me the names of those sources?
MR. WILLIAMS: Your Honor, I object to that. I think the characterization is, this is the witness' writing, that the document is his own. I don't think that is correct. I don't know where that came from.
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THE WITNESS: I never used these in—
THE COURT: Mr. Kaplan, the witness never saw them, never used them. I have a hard time seeing how it is admissible through him.
MR. KAPLAN: Fine, your Honor.
MR. KAPLAN: (Continuing)
Q: Let me ask you as a final matter, Senator Holsted, whether in your experience the Senate has ever considered a bill, for example, to allow Christian Scientists to be released from health classes or discussion of various matters that might conflict with their religious views?
A: No. I think the only thing we did last session that I can remember concerning Christian Scientists is, we released, certain designators in the Christian Science faith from jury duty because they were a minister under their designation. We exempt ministers from jury duty. That was the only thing I can think of that was done like that.
MR. KAPLAN: That's all I have. Thank you.
THE COURT: We will take about a ten minute recess.
(Thereupon, Court was in recess from 4:10 p.m.
until 4:20 p.m.)
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CROSS EXAMINATION
BY MR. WILLIAMS:
Q: Senator Holsted, how long does the Arkansas Legislature meet and how often does it meet?
A: It meets once every two years, constitutionally sixty days. We generally run sometimes eighty, ninety days.
Q: In that period of time, meeting sixty to eighty days every two years, are all bills given a long deliberative and investigative process by the Legislature?
A: In the past session we considered over sixteen hundred pieces of legislation that came through the Senate, to either vote on or for our consideration to vote for, and there's no way possible to have hearings on every piece of legislation that comes through. We'd still be going on on last year's bills.
Q: Is it unusual to have a bill to be considered in committee only for a matter of minutes?
A Not at all. This last special session a lot of bills didn't even go to committee. The only thing the committee process does is try to speed up the flow of legislation, because you have different committees meeting all the time to consider many different bills.
The best hearing, of course, that's possible is to get
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A: (Continuing) it on the floor and all thirty-five senators hear it.
Q: At the time that you introduced what is now Act 590, as to the extent of your knowledge as a layman in science, did you feel that there was and is scientific evidence to support creation science?
A: Yes, I did.
MR. WILLIAMS: No further questions.
THE COURT: May this witness be excused?
MR. KAPLAN: Yes, Your Honor.
MR. CEARLEY: Plaintiffs call Doctor Brent
Dalrymple. Mr. Ennis will handle direct.
Thereupon,
GARY B. DALRYMPLE,
called on behalf of the plaintiffs herein, after having been first duly sworn or affirmed, was examined and testified as follows:
DIRECT EXAMINATION
BY MR. ENNIS:
Q: Doctor Dalrymple, will you please state your full name for the record?
A: Yes. My name is Gary Brent Dalrymple.
Q: I'd like to show you Plaintiffs' Exhibit Ninety-eight for identification, your curriculum vitae.