Michele M. Simmsparris
Excerpted from, What Does it Mean to See a Black
Church Burning? Understanding the Significance of Constitutionalizing
Hate Speech, 1 University of Pennsylvania Journal of Constitutional Law
127-151 (Spring 1998) (Citations and Footnotes Omitted)
A. A Historical Background of the Significance of Black Churches:
Beyond a Monolithic Construct of African-American Religion and
Notions of religious faith and freedom have shaped much of American
political and social philosophy. For many Americans religion is not just
a way of thinking, but a way of life. In African-American history,
"the church" has long stood at the center of Black communities
establishing itself as the pre-eminent source for religious enrichment
and secular development.
To capture a sense of the shared historical experiences of African-
Americans, in particular African-American Christians, the phrase
"the Black Church" evolved. The phrase has developed into a
term of art for expressing the centrality of Black churches in Black
communities. Although the term, "the Black Church" isa bit
misleading, it presents a tangible quality to the intricacies of racial
and religious interstionality unique to African- American history. For
many African-American Christians, despite their denominational
differences, Black churches have always represented a triumvirate of
religion, community, and home. Thus, in an attempt to convey the
significance of Black Churches in Black communities, scholars have
repeatedly asserted that "Black history and Black church history
intersect[ed] at so many points as to be virtually identical."
Hence, despite the presence of myriad factions of Black churches in
America, the depiction of the monolithic Black Church is pervasive
throughout African-American historiography as a matter of historical
Even though history illustrates many moments in which the social and
political experiences of African-Americans either affected or were
affected by Black churches, aspects of Black history and Black church
histories in many ways remained distinct. In essence, the term "the
Black Church" is a misnomer. The term "the Black church"
implies that all Black churches share or have shared the same
aspirations and strategies for creating cohesive African-American
communities. This is far from true.
A deconstruction of the monolithic Black church begins with the
acknowledgment of the innumerable differences found among Black
communities and the reflection of those differences within their
community churches. Black communities differed from region to region.
They were divided along social lines, composed of persons from different
economic levels, and maintained varying political philosophies. Black
communities in the inner cities of the United States have traditionally
differed from those in rural areas. Ultimately, the needs and concerns
of the members of these varying communities were also dissimilar from
area to area. Therefore, like all other Americans, social stratification
was a reality of Black Americans. For African-Americans such
stratification was affected by the wide range of attitudes toward race,
class, gender, education and political affiliation. The social
differences that countenanced each sub- community of the larger Black
community was also reflected in the identities of Black Churches.
The diversity of Black communities was reflected in the variety of
Black Churches. African-American community churches varied in
denominational affiliations, theological practice, and regional
location. In The Negro Church in America, the sociologist E. Franklin
Frazier noted, "Methodist and Baptist denominations were separate
church organizations based upon distinctions of color and what were
considered standards of civilized behavior." Not only did Black
churches differ culturally and ideologically, but each church also
differed in the ways it evolved.
Many Black churches were created in response to racial segregation.
Many African-American churches were established in response to
African-American dissatisfaction with the teachings of "white
churches." Some were established simply to bring varying forms of
Christianity into Black communities which already had either one or
several established Black churches. Consequently, the concerns of
independent Black churches reflected the varying concerns of their
Nevertheless, despite their regional, denominational, and theological
differences, Black churches maintained striking commonalities. Black
churches were consistently at the social and religious centers of Black
communities. The interwoven fabric of the secular and the ecclesiastical
within many Black religious institutions created a base upon which
African-Americans could organize politically and persist spiritually.
Black churches were not only given to the teachings of Christianity but
they were faithfully relied upon to address the specific issues which
affected their members.
Since the establishment of the first independent African-American
church in America in 1773, Black churches have flourished. Even though
many African-American churches were created in reaction to racial
discrimination and segregation, what developed was more than separate
places to worship for African-Americans. Instead, churches became
religious institutions devoted to addressing the needs of members of the
B. Understanding the Church as a Community
The Negro church was not only an arena of political life for the
leaders of Negroes, it had a political meaning for the masses. Although
they were denied the right to vote in the American community, within
their churches, especially the Methodist Churches, they could vote and
engage in electing their officers. The election of bishops and other
officers and representatives to conventions has been a serious activity
for the masses of Negroes . . . . For the Negro masses, in their social
and moral isolation in American society, the Negro church community has
been a nation within a nation.
In church-centered Black communities, the relationship between one's
community and one's church was intimate. Far more than just a place to
worship, the Black Church was a nation within a nation. The meshing of
Black community life with the religious experiences of African-
Americans precipitated the birth of the dichotomy between church and
religion found within the construction of Black religions. For many
African- Americans, church was not only a place to receive religious
instruction on the doctrines of Christianity, church was a community in
which to learn about one's world.
Black churches were organizational sites for social and political
activities, centers for economic development and growth. As microcosms
of the larger society, Black churches provided an environment free of
oppression and racism for African-Americans. In Black Churches,
African-Americans were consistently exposed to social, political, and
economic opportunities which could be sought and had by all members
The representational structure of African-American churches confirmed
Black preachers as both religious and community leaders. The sermons of
many Black preachers expounded messages of Christianity analogized to
the daily experiences of African-Americans. Thematic expressions of
overcoming oppression and "lifting while climbing," were first
articulated in church sermons.
Using their authority as religious leaders, Black preachers
incorporated the teachings of Christianity into political manifestos.
Slavery, emancipation, and the continued struggle for civil rights,
provided the context for analysis of Biblical stories such as the escape
of the Jews from Egypt. The idea of "freedom through collective
deliverance," as articulated in the Book of Exodus, gave
African-Americans a sense of political and community direction through
religious belief and expression. The notion of divine intervention which
permeated the lessons of Exodus did not translate seamlessly into a
positive mandate for African-Americans to overcome oppression. Yet, the
teachings of African-American churches nurtured the motivations of Black
people to oppose and overcome racial persecution. African-Americans'
belief in divine intervention, coupled with a community spirit to
struggle and to overcome social, political, and economic hardships,
inspired many Black Church members.
C. Finding a Home in the Church
During the decades of slavery in America, slave associations were a
constant source of concern to slave owners. For many members of white
society, Black churches and religious meetings symbolized the ultimate
threat to white existence. Nevertheless, African-American slaves
established and relied heavily on their churches. "Religion offered
a means of catharsis . . . African-Americans retained their faith in God
and found refuge in their churches." However, white society was not
always willing to accept the involvement of slaves in Christianity. As
one slave recounted "[t]he white folks would come in when the
colored people would have prayer meeting, and whip everyone of them.
Most of them thought that when colored people were praying it was
Religious exercises of slaves were closely watched to detect plans
for escape or insurrection. African-American churches took on an air of
militancy in the eyes of white Americans. Insurrections such as Nat
Turner's in Virginia, born out of the religious inspiration of slaves,
horrified white Americans. Understanding the potential end which could
result from the religious experiences of African-American slaves, many
white Americans opposed the participation of Blacks in Christianity.
Despite the social adversity that opposed their existence, Black
churches were established, and served as integral parts ofBlack
communities. According to E. Franklin Frazier, during times of slavery,
and well after emancipation, "the [Negro] church gave support to
[Negro] family life [and was] the most important agency of social
control [among Negroes]." Insofar as whites could not understand
and were afraid of Black religiosity, "the Negro church with its
[unique] forms of religious worship was a world which the white man did
not invade." Therefore, out of this history of separation and
exclusion, Black Churches rooted themselves as the souls of the
communities in which they stood.
After emancipation, as racial domination thrived in reconfigured
forms, Black churches became virtually the only place for
African-Americans to find refuge. As African-American Christians moved
from slavery to emancipation their religious practices and houses of
worship also changed. They moved away from the "hush-harbors"
that they retreated to for solace as slaves, and built churches. Just as
the prayer meetings which took place in slave "cabin room[s]"
were devoted to countless pleas for deliverance from slavery, the
sermons that were given in Black churches addressed the
post-emancipation needs and concerns of members of Black communities.
Inevitably, Black churches became sources for Black empowerment.
Black churches, such as H.H. Proctor's Congregational Church housed
schools, employment bureaus, shelters for the aged and orphans, and
meeting places. "In 1886 [African-Americans] organized the National
Baptist Convention, in an attempt to reduce the influence of white
national bodies among blacks." Black churches worked collectively
to deal with Black issues, especially racial discrimination in
segregated schools, neighborhoods, and businesses.
As racially motivated violence and terrorism ran rampant across the
country, Black churches were staunch in their resistance. In 1908, The
Christian Index published the "Colored Methodist Bishops' Appeal to
White America-1908." In their statement, church leaders responded
to the surge of mob violence and lynchings occurring across the country,
denouncing terrorism waged against Black persons and imploring the
country to suppress the spread of anti-Black violence. As anti-Black
terrorism proliferated into the twentieth century, Black churches grew
increasingly vehement in their calls for castigation of racial violence.
However the more involved Black Churches became in sparring against the
racial intolerance and violence targeted against them, the more the
churches and their members were chastised.
By the commencement of the Civil Rights era, Black churches were well
established social and political power bases for African-Americans. The
enormous presence of Black churches in African-American communities,
naturally, sanctioned them with the political power to lead Black people
in the movement for civil rights. Yet, Black Churches were torn on
whether and how best to get involved in the movement. Some churches and
church organizations were completely opposed to any involvement in the
political struggle for civil rights. Yet, those that chose to
participate did so fervently, organizing by rallies, protests, and
marches, while teaching the lessons of Christianity and community
involvement. Ultimately, racism made individual African-Americans the
targets of racial violence. Racism plus the concentrated political power
of African-Americans in Black churches confirmed African-American
churches as the central targets for racial violence waged against the
entire Black community.
D. Sometimes When There's Racial Hate . . . There's Fire
Extra-legal violence has been an effective means of communicating
racial hatred throughout American history, especially as a method of
social and physical control. Fire in particular was used not only to
inflict physical harm upon disfavored persons in communities, but to
send messages which threatened further harm to either persons or
property. The pages of American-African history document an undeniable
record of the racially motivated use of fire to either threaten or
inflict harm upon African- Americans.
During the Civil Rights Movement, "the church functioned as the
institutional center" for Black mobilization. Churches provided
"an organized mass base and meeting place," for
African-Americans to strategize their moves in the fight against racial
segregation and oppression. As Black Churches became the epicenter of
the social and political struggles for African-American equality, they
increasingly became targets for racially motivated violence. Thus, a
broad assault on members of a Black community could effectively take
place by burning a Black church. The bombing and burning of Black
churches translated into an attack upon the core of civil rights
activism, as well as upon the larger Black community.
The most infamous example of church destruction, occurred on Sunday,
September 15, 1963. When the Sixteenth Street Baptist Church in
Birmingham, Alabama, was fire bombed, the explosion was felt by the
entire Black community. Not only were four children killed in the attack
and several people injured, but a community's sense of security within
their church was forever shaken.
The burning of the Sixteenth Street Baptist Church signified the
depths to which racial hatred could fall. Like many other churches
bombed before and after, the Sixteenth Street Baptist Church was
attended predominantly by African-Americans. Throughout the Civil Rights
Movement, the Church was active in the struggle to desegregate southern
public schools and supported the call for equal rights for Black people
in America. Even though the Ku Klux Klan (KKK) was implicated in this
crime, members of the KKK were not the only persons responsible for
similar acts of terror throughout the country. Unfortunately, this was
not an isolated incident.
In January 1957, four Black Churches were bombed in Montgomery,
Alabama. In April, two were burned in Bessemer, Alabama. In 1958, burned
churches were reported in Birmingham and Memphis. In 1959, a church was
reported to have been burned in Roscoe, Georgia. In 1963, a church was
reported to have been bombed in Pine Bluff, Arkansas. In Vicksburg,
Mississippi, two people were killed in a church that had been used to
register for Black voters when it was bombed in 1964.
Starting in 1964, Meridian, Mississippi, was added to the list of
places in which Black churches were attacked. In January 1968, two more
Black churches were bombed in Meridian. On February 22, the New Hope
Baptist Church, "site of a Head Start program and civil rights
activities," was torched. On February 23, the parsonage of the
Newell Chapel Methodist Church was finally burned after a previous
As a result of the violence, some churches were forced into social
incapacitation. Members of the First Union Baptist Church in Meridian
were so afraid of being bombed that they opposed using the church for a
much needed Head Start Program. Thus, racially motivated arsons, though
not successful in destroying the souls of Black communities, managed
nonetheless to inflict a significant amount of harm on churches, their
congregants, and surrounding communities. FN110] In the end, the message
of racial hate was burned into the memories of African-Americans and
revisits us every time one of our churches burn.
Black Church fires set by arsonists in the 1990s revivify images of
Black people excluded from participating in the Christian faith, lynched
by angry mobs, and watching their churches torched during the 1950s and
1960s. Images of anti-Black terrorism are so indelible that they are
recreated as African-American churches burn in the 1990s. In places like
Amite County, Mississippi, during the last year, the smoking remains of
burned or burning Black churches have re-inscribed the message of racial
hatred which permeated the 1960s.
In Amite County, Mississippi, racial hate is unquestionably apparent.
Graffiti writings of scrawled racial epithets and swastikas on the walls
of burned Black churches articulate the unrelenting presence of racism.
It is not surprising that Amite County, once deemed one of the two most
notorious "church burning capitals of the world," is again a
major target for attack. In Amite County, "Black residents [here]
have long been the victims of [other] racially motivated
attacks--mailbox shootings, cross burnings, hooded Klansmen yelling
racist slurs while riding through Black neighborhoods." Such
incidents illustrate how far we have not come with regard to eradicating
racial terrorism. Therefore, when the Springhill Freewill Baptist Church
was burned in 1996, the flames rekindled the fear and outrage produced
by the burning of Black Churches a generation earlier.
The arsons of the 1990s inspire fear based not only on what was
learned in Black history books, but rather on the recollections of real
experiences. Margaret Tobias, a current resident of Amite County, not
only "witnessed church bombings of the 1960s, she survived an
attempted arson on her home in 1965." Now, thirty years later, as
member of the Springhill Freewill Baptist Church, Tobias is, again, a
witness and victim of church desecration.
Among the most disturbing aspects of the burning of Black Churches
today is the demolition of the comfortable myth that such acts of
terrorism ended with the Civil Rights Movement. According to the late
Rev. Dr. Mac Charles Jones, former Associate to the General Secretary
for Racial Justice, National Council of Churches, "[o]ver the past
four years (1992-1996) there have been more Black Churches burned than
during the entire Civil Rights Movement." From January of 1995
through July of 1996, more than seventy Black and multiracial churches
were burned. More churches were burned during that eighteen month period
than during the previous five years combined. As one commentator wrote,
the era of "night riders, cross burnings, church burnings, home
burnings, and farm burnings" was thought to have passed. Instead
the burnings of Black Churches across the country teach us that racial
violence is an ugly fact of our American reality.
To burn a Black Church is to conjure up images of past and future
fires set to harm members of Black communities. It is in this context of
violence and the communication of violence that incidents of cross
burning like that which was addressed by our nation's Supreme Court in
R.A.V. must be understood. Contextually the historically racist meaning
of fire as a threat is understood by arsonists and victims alike.
Consequently, whether fire is used to burn a cross or a church such
expression must not be viewed solely as "speech," but rather
as an incontrovertible threat.
Fundamental to the problem of racial terrorism is our government's
willingness to constitutionalize hateful speech, which creates an
environment that nourishes hatred against Black communities and results
in burned churches. By the time a church is burned to the ground the
harm has already been done, and in every case the harm is irreparable.
Although some may argue that there is a clear difference between cross
burning and church burning, given the history of the expressive meaning
of both such argument would stand without merit. R.A.V. v. City of St.
Paul vividly illustrates the consequences of inaction in the face of