Preliminary Reaction to Mass SCCA Draft K-12 Findings & Recommendations

July 9, 2025

On Wednesday July 2, the Massachusetts Special Commission on Combatting Antisemitism (MSCCA) released its Draft K-12 Education Findings and Recommendations. Concerned Jewish Faculty and Staff – Boston Area (CJFS-B) writes now to offer our initial analysis of the draft findings and recommendations. We write as scholars with expertise on antisemitism in fields including K-12 Education, law (including civil rights, Title VI, and academic freedom/free speech), Jewish studies, the Holocaust, Arabic literature, public health, political science, human rights, Middle East history, and American Jewish thought. Given the limited time available to review the draft recommendations before the MSCCA’s July 9 hearing, our response is preliminary and summary in style.

The MSCCA’s draft recommendations offer a useful start. But as outlined below, the draft findings and recommendations should not be approved in their current form. Though certain recommendations are promising, the report as a whole rests on inadequate and unreliable data; relies on an unnecessarily narrow range of testimony that omits critical experts on K-12 pedagogy and education; and reinforces a widely-contested and counterproductive definition of antisemitism.

Given the gravity of these concerns, we urge the MSCCA NOT to approve the draft recommendations at the July 9 hearing but instead to create meaningful opportunities for public and scholarly input to address the issues identified below. We commend the MSCCA for rising to the urgency of the moment. We also recognize that the Commonwealth would benefit from engaging in additional deliberation, and specifically utilize a more deliberate and inclusive approach designed to promote the MSCCA’s mission.

The draft findings rely on inadequate and unreliable data, obscure Jewish diversity, and conflate Jewish identity with the State of Israel.

The draft report does not substantiate its leading claim that “Antisemitism in Massachusetts K-12 schools is a pervasive and escalating problem.” Like other forms of bias and bigotry, antisemitism exists, demands our collective attention, and is likely to rise under the Trump administration. But the draft report’s core claim about antisemitism and its scope in K-12 schools relies on inadequate and unreliable statistics from the Anti-Defamation League (ADL), which conflates anti-Jewish bias with legitimate criticism of Israel and thereby creates the false impression that pro-Palestinian advocacy constitutes antisemitism. The ADL’s untrustworthy data compromises our collective ability to combat antisemitism and should not shape policy decisions in Massachusetts. Moreover, with the exception of limited anecdotes, the draft findings offer no data specific to K-12 schools.

The draft report reproduces misleading approaches to antisemitism by linking Jewish identity to the State of Israel (e.g., conflating“Jewish and/or Israeli students” and assuming that “curricula on the history of Israel” will educate about antisemitism). Even if unintended, this conflation (a) invites the misconception that criticism of Israel is anti-Jewish; (b) obscures the significant numbers of Jewish Americans who criticize Israeli state policies and/or its present formation; and (c) erases non-Jewish Israelis.

Likewise, the draft report improperly relies on—and often extends beyond—the widely contested IHRA Working Definition of Antisemitism. An ever-growing number of scholars have criticized the IHRA Working Definition. This includes over 1,000 scholars who signed a July 4, 2025 letter from the Genocide and Holocaust Studies Crisis Network and Kenneth Stern, who co-authored the IHRA Working Definition and cautions against its codification in governmental or institutional contexts because it was never intended for that purpose and is often weaponized to silence legitimate criticism of Israel. The MSCCA should not promote the IHRA Working Definition or recommend that it shape state educational policy.

The draft report makes it more difficult to identify and address antisemitism by, for example, conflating antisemitism with national origin discrimination. For example, the draft lists “harassment or discrimination based on perceived relationship to Israel or actual Israeli citizenship” as a form of antisemitism alongside swastika graffiti and Holocaust jokes or denial. Massachusetts should of course foster a school culture where no one faces harassment or discrimination based on their actual or perceived national origin. However, the MSCCA should clarify that (perceived) national origin bias or discrimination involving Israel, analogous to anti-Russian or anti-Iranian sentiment that peaks in periods of conflict, does not necessarily constitute antisemitism. Failing to do so can actually amplify antisemitism by fusing a conceptual link between Jewish identity and the State of Israel.

By defining anti-Israel sentiment as hostility to Jewish people, the draft report makes it more difficult for students and teachers to distinguish between Jewish people and the State of Israel and its military actions. Rather than combat antisemitism, this message will produce environments in which Jewish people are more likely to be held collectively responsible for Israel’s policies and deeds. Even if unintended, this dynamic would buttress harmful initiatives like the Heritage Foundation’s Project Esther, which cynically admits that its campaign against “antisemitism” could “‘reinforce a ‘blood libel’ narrative, potentially lending credence to [a] ‘Blame the Jews’ mantra, followed by expanded antisemitism across the United States.” To mitigate this dynamic, the final report should recommend curricular materials that highlight Jewish diversity by, for example, foregrounding that Jewish people hold varied perspectives with respect to Israeli government policy, the State of Israel and Zionism.

Aside from a brief mention of halal food, the draft report does not meaningfully engage anti-Arab or anti-Muslim bias. Antisemitism and Islamophobia (in addition to anti-Black racism) are similar in structure, often grow in tandem with each other, and are most effectively addressed together. Treating anti-semitism as exceptional or unique runs contrary to decades of research about the origins of prejudice and the most effective practices to mitigate discrimination. The final report and Massachusetts policy should explicitly incorporate the connection between antisemitism and other forms of bigotry.

The draft recommendations offer a useful start but include multiple concerning flaws.

The draft recommendations contain much to applaud, such as the proposal to fold antisemitism education into curricula and training about discrimination writ large. Likewise, one can see the value in an Advisory Council on Holocaust and Genocide Education that draws on a rich range of scholarly expertise from the Commonwealth and beyond; this council should include scholars across the whole range of Genocide Studies, including an expert on the Palestinian people of Gaza.

By contrast, we caution against recommendations that treat antisemitism as exceptional or deserving more attention than other forms of bias and bigotry, or that call for a punitive approach–particularly vis-a-vis students in the K-12 setting. Instead, schools should work on creating environments that foster inclusion and respect for people of diverse backgrounds in every sense of the word, and employ restorative justice practices to address incidents of antisemitism when these occur.

The IHRA definition, as mentioned above, is controversial and unclear; the draft recommendations at times go beyond it in ways that amplify confusion and will likely chill critical classroom conversation. Rather than create more confusion or invite self-censorship, a more helpful approach would be to clarify that the following acts and positions, for example, are not themselves antisemitic: (a) criticism of Israel; (b) calling for economic boycotts of Israeli entities; (c) advocating for an Israeli state that extends equal rights to all inhabitants; (d) antizionism and other viewpoints critical of Zionism. We urge you to heed the testimony of Ambassador Solomont on this point.

We applaud the call for the state’s Bias Reporting Program to count incidents of antisemitism. But we strongly caution against any new policy or infrastructure that operates as a mechanism to unduly surveil, police and/or burden K-12 educators and administrators. Our schools and educators are already strapped and overextended – a dynamic that will only be heightened under a Trump administration that seeks to defund public schools. The recommendations should therefore propose commensurate measures that (a) ensure educators have the resources they need to support all students and (b) protect educators from actors who misuse any bias reporting infrastructure to target individual teachers or curriculum that provides instruction on concepts related to any form of racism and bias and/or is critical of a nation’s government (whether that be Israel or the United States). It should also be noted that political beliefs, whether it be Zionism, anti-Zionism or Christian Nationalism, do not constitute a protected category under state or federal antidiscrimination law.

We are similarly concerned about aspects of the recommendation for broad DESE control over individual school districts and classroom materials. Albeit well-intended, the recommendation to “develop a mechanism for reporting problematic curriculum in use in class,” alongside the calls for increased surveillance, shares traits with recent laws and regulations in southern states designed to censor educators and deny students access to important information about racism in the United States. These policies threaten students’ right to receive information and threaten teachers’ freedom of expression. As the MSCCA works to keep Jewish students—and indeed all Massachusetts students—safe, we urge the MSCCA not to overcorrect in ways that preclude students of their right to experience the discomfort that is a necessary part of learning and personal development.

We are relatedly concerned that the draft report lumps together “bullying, harassment, discrimination, protests, walkouts, postering, vandalism/graffiti, and social media.” Protests and walkouts, for example, have a storied place in First Amendment-protected student movements in the United States. Clumping this legitimate and protected speech with bullying, harassment, and discrimination sends a disturbing message and creates a chilling effect with First Amendment implications.

Concerned Jewish Faculty and Staff

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