American Experiment’s official comments opposing proposed social studies standards

An administrative law judge (ALJ) is considering proposed changes to Minnesota’s K-12 academic standards in social studies. He will weigh the changes against statutory requirements for revising academic standards and will hold public hearings on
November 8 from 6-8 p.m. and November 9 from 1-4:15 p.m.

American Experiment submitted comments — which you can read below — opposing the changes, calling attention to state law that requires academic standards to be clear, objective, measurable, and grade-level appropriate. [Minn. Stat. 120B.021, subd 2]

The Minnesota Department of Education’s proposed K-12 social studies standards fail in all these respects and should be disapproved.


The proposed standards are not measurable

The standards, taken as a whole, are not measurable because they lack clarity and specificity. The following examples illustrate this:

  • Subp. 4. Geography. B. Places and Regions: The student will describe places and regions, explaining how they are influenced by power structures.
  • Subp. 4. Geography. E. Culture: The student will investigate how a sense of place is impacted by different cultural perspectives.
  • Subp. 5. United States and world history. A. Context, Change, and Continuity: The student will ask historical questions about context, change, and continuity in order to identify and analyze dominant and nondominant narratives about the past.
  • Subp. 3. Economics. B. Fundamental Economics Concepts: The student will analyze how scarcity and artificial shortages force individuals, organizations, communities, and governments to make choices and incur opportunity costs. The student will analyze how the decisions of individuals, organizations, communities, and governments affect economic equity and efficiency.

What does “sense of place” mean? What is a “nondominant” narrative? How is “economic equity” defined, and how will we know when it has been achieved? Minnesota law requires students to “demonstrate attainment” of required state academic standards. But without clear and specific content to assess, meaningful measurement is not possible.

The proposed standards are not objective

Nor are the standards, as a whole, objective. Merriam-Webster defines “objective” as “expressing or dealing with facts or conditions as perceived without distortion by personal feelings, prejudices, or interpretations.”

Subp. 6. Ethnic Studies. A. is typical of the subjective, ideologically skewed nature of the standards:

Identity: The student will analyze the ways power and language construct the social identities of race, religion, geography, ethnicity, and gender. The student will apply understandings to one’s own social identities and other groups living in Minnesota, centering those whose stories and histories have been marginalized, erased, or ignored.

This standard is not objective. On the contrary, it employs vocabulary and concepts rooted in a controversial political ideology, which assumes that students’ “social identity” is a function of their race, ethnicity, and other immutable traits. Terms such as “marginalized,” “erased” and “ignored” are undefined. A finding of “mastery” is conditioned on a student’s framing his or her answers in the politically laden concepts and language of the standard.

The proposed standards are not grade-level appropriate

Standards must also be grade-level appropriate. But MDE’s proposed standards employ identical language for every grade, K through 12, in each subject area. Benchmarks “are the way the standards (the rules) are carried out at specific grade levels,” as MDE’s Statement of Need and Reasonableness (SONAR) acknowledges. [p. 63] As a result, any assessment of grade-level appropriateness requires taking into account the related benchmarks.

The following first-grade benchmark for Ethnic Studies illustrates the multiple levels on which the 2021 Social Studies standards’ benchmarks are flawed:

Identify examples of ethnicity, equality, liberation and systems of power. Use those examples to construct meanings for those terms. []

Can a 6-year-old grasp abstract concepts such as “liberation” and “systems of power”? How will a teacher measure whether a student of this age has successfully “constructed meaning” for these concepts?

This benchmark, and many others like it, are not only unmeasurable and lacking in objectivity but grade-level inappropriate.

The standards’ failure is a function of the ideology that frames them

There is an overarching reason for the 2021 standards’ failure on all these fronts. It is a function of the nature of the standards themselves.

MDE proposes to repeal and replace our state’s current Social Studies standards, drafted in 2011, instead of revising them, as Minn. Stat. 120B.021, subd. 4 contemplates. In doing so, it seeks to replace academic standards that are measurable and objective with subjective, politically fraught standards that are, in essence, impossible to measure.

MDE’s aim, according to its SONAR, is no less than to “shift” or “reframe” the entire approach to K-12 Social Studies education (citizenship and government, economics, geography and history) used in Minnesota schools.

MDE claims the 2011 standards are deficient because they organize student learning around “content” — i.e., the detailed, specific factual knowledge that serves as a foundation for learning in each discipline. While MDE acknowledges that content knowledge sometimes plays a role, in general it intends to replace our schools’ current “content-based” approach to instruction with what it calls “inquiry-based” pedagogy. [p. 58] Under this approach, students are asked to “construct” their own meaning — based on “asking difficult questions” — instead of mastering specific factual knowledge. [p. 60] (The first-grade Ethnic Studies benchmark quoted above is an example.)

The importance of content

In fact, content-based instruction is vital for both comprehension in learning and meaningful assessment. But the SONAR repeatedly disparages methods of instruction that are designed to teach knowledge of this kind. It depicts students in today’s classrooms as merely spouting disconnected facts and fails to recognize that good teachers use such knowledge as the foundation for the inference and analysis on which critical thinking is based.

For example, the SONAR asserts that, because of the 2011 Social Studies standards, today’s students primarily engage in “rote memorization” — or “simply reiterat[e] content”— as “promoted by standards that list discrete facts.” [p. 62] It concludes that MDE’s proposed “shift” towards “disciplinary inquiry” will remove a significant barrier to teachers’ implementation of long-established best practices.” [pp. 62-63]

MDE is wrong. The SONAR seems to suggest that it’s possible for students to think seriously and fruitfully about nothing, as if they can somehow develop “historical thinking” or “literacy” or analysis skills without underlying factual knowledge from which to make inferences or draw conclusions. In reality, facts — embedded in a context — are not dead, discrete things. Cognitive scientists have long known that facts are the fundamental building blocks of background knowledge, which enhances the cognitive processes of reasoning and problem-solving. It is well established that the ability to read a text and comprehend it is highly correlated with background knowledge.

MDE’s revealing comparison of 2011 and 2021 standards

The SONAR illustrates the way the 2021 Social Studies standards will transform Minnesota classrooms by comparing a content-based 2011 standard in citizenship and government with its “inquiry-based” replacement. [p. 54]

The 2011 Citizenship and Government standard (2011 K–12 Academic Standards in Social Studies, standard 3) reads as follows:

The United States is based on democratic values and principles that include liberty, individual rights, justice, equality, the rule of law, limited government, common good, popular sovereignty, majority rule and minority rights.”

Its proposed replacement, Subp. 2. Citizenship and Government B., reads as follows:

The student will explain democratic values and principles that guide governments, societies, and communities and analyze the tensions within the United States constitutional government.

The current standard sets forth basic factual content about American constitutional principles, and students’ grasp of the principles listed can be measured. MDE justifies its replacement this way: “The rephrasing allows and encourages critical thinking versus leading students in a certain direction to a certain conclusion,” according to the SONAR. [p. 54] MDE appears unaware of the irony that its reframing of constitutional principles in terms of “tensions” undeniably leads students to a “certain conclusion.”

The SONAR continues: “Analyzing value tensions and how well principles are ‘working’ better allows students to examine contemporary issues (with historical context) and tap into their lived experiences.” [p. 54] 

What “values and principles,” in what context? On what basis are students to “analyze tensions”? Instead of acquiring factual background, students are expected to rely on — to “tap into” — their “lived experience.” Under these circumstances, what does “mastery” of this standard mean, and how can it be measured?

Again and again, the SONAR emphasizes MDE’s central theme: Replacing content with “inquiry” is a primary goal of the 2021 Social Studies standards. For example,

  • In citizenship and government, MDE envisions “a shift away from the way that most schools have taught history and civics: from a model based on the learning of long, detailed and practically unteachable sets of state standards to inquiry process.” [p. 67]
  • In history, “The focus in the history standards has shifted away from memorization of content to historical thinking skills and historical literacies.” [p. 77] 
  • In geography, schools “need to move beyond the memorization of geographic facts” to “think spatially.” While the SONAR pays lip service to the importance of facts in geography, its benchmarks include no specifics of this kind. By contrast, the 2011 benchmarks include extensive references to geographical characteristics like mountain ranges, bodies of water and rivers, and specific ecosystems in grades K-5, 8, and high school.

In sum, the SONAR makes clear that the 2021 standards’ rejection of content makes meaningful assessment difficult or impossible.

Lack of objectivity

MDE’s shift to “inquiry-based” pedagogy not only seriously impedes the measurement of student mastery, required by statute. The 2021 Social Studies standards are also incompatible with the statutory requirement that standards be objective. The reason is that they replace content with ideology.

The central role of “anchor standards”

MDE’s new model for Social Studies education reorients instruction around 25 “anchor standards,” which MDE describes as the “big ideas” around which all student learning is organized. [p. 27] According to the SONAR, MDE has reduced the number of standards to concentrate on these “big ideas,” as opposed to specific factual knowledge and content. (For example, the 2011 history standards had four substrands and 23 standards, whereas the 2021 history standards have just five anchor standards, according to the SONAR, p. 78.)

The anchor standards are intended to shape students’ “conceptual understanding” — that is, the vocabulary and categories of thought they use to organize learning, and to understand both their personal “identities” and the world. [p. 61] These “big ideas” are repeated each year. In the SONAR’s words, students will “return to the key ideas and concepts throughout a K-12 social studies experience in order to ensure they can continue to apply their understanding at deeper levels…” [p. 61]

Critical Social Justice ideology

The anchor standards serve as the vector for the politicized ideology that undergirds the 2021 Social Studies standards. They are saturated with terms and concepts such as “power structures,” race-based “identity,” “oppression,” “equity” and “resistance.” These and similar notions — including “decolonization” and “settler colonialism,” which appear in the benchmarks — are the core tenets, buzzwords, concepts, and assumptions of what’s known as Critical Social Justice ideology.

Terminology of this kind does not play a significant role in Minnesota’s 2011 Social Studies standards or benchmarks, or the standards the legislature originally approved in 2004. Yet these ideas, and the assumptions behind them, will form the core of the learning of the next generation of Minnesota citizens, if the 2021 Social Studies standards are approved.

Where does this ideology come from? As will be explained below, it is articulated in the writings and advocacy of the Minnesota Ethnic Studies Coalition, whose members played a central role on the MDE committee that drafted the 2021 Social Studies standards.

Critical Social Justice ideology has four fundamental tenets: 1) Human “identity” is a function of immutable traits like race and ethnicity; 2) Human beings are divided into oppressors and victims; 3) Social life is a power struggle between these two groups; and 4) Resistance to fundamental American institutions is necessary to achieve desirable change.

Critical Social Justice ideology is not only politicized in a way that has no place in academic standards that govern public school instruction in a democracy. It is incompatible with the very idea of objectivity or truth. One of the ideology’s primary tenets is that all meaning is “constructed.” It holds that each race- or ethnicity-based identity group “constructs” its own “narrative,” or view of the world. It presumes that people of the same skin color necessarily share the same perspective — not as a result of a search for truth or factual accuracy, but because of their alleged status as oppressor or victim (“lived experience”).

Academic standards that make this ideology their organizing template cannot, by definition, be non-partisan or objective.

Students must “construct” their own meaning

The 2021 history standards emphasize repeatedly that — in inquiry-based instruction — all students are expected to construct their own meaning, that is, to decide what is true for them. The SONAR leaves no doubt: “History,” it declares, “is the construction of a narrative, and the narrative is the product.” [p. 10]

In this context, the SONAR again compares a content-based 2011 standard and the “inquiry-based” standard that will replace it. [p. 78] The contrast makes clear that objectivity is a casualty.

The 2011 history standard reads as follows:

Post-World War II United States was shaped by an economic boom, Cold War military engagements, politics and protests, and rights movements to improve the status of racial minorities, women and America’s indigenous peoples.

Here is its 2021 replacement:

Subp. 5. United States and World History. A. Context, Change, and Continuity: The student will ask historical questions about context, change, and continuity in order to identify and analyze dominant and nondominant narratives about the past.

The current standard sets forth an objective, straightforward list of events and movements about which students are expected to learn in their study of post-war America. The new standard, however, is ideologically framed. To achieve “mastery,” students will be required to frame their thinking in the one-dimensional, ideologically charged terms of “dominant and nondominant narratives.”

If the proposed standards are approved, students will get the message — throughout their 13-year academic career — that if they are of a certain race or ethnicity, they are expected to think as their “identity group” allegedly does.

Ethnic Studies

One of MDE’s most consequential actions was its addition of “Ethnic Studies” as a Social Studies strand, though Minn. Stat. 120B.021, subd. 1 does not include it. MDE appears to regard Ethnic Studies as a legitimate academic discipline, equivalent to history or geography. In fact, it is not an objective, scholarly field of inquiry, but an advocacy movement that arose out of political protests in the 1960s.

MDE’s three proposed Ethnic Studies standards are essentially summaries of the Critical Social Justice ideology that undergirds the 2021 standards as a whole. Their lack of objectivity, and reliance on controversial, ideologically charged vocabulary and concepts, are self-evident.

  • Subp. 6. Ethnic Studies. A. Identity: The student will analyze the ways power and language construct the social identities of race, religion, geography, ethnicity, and gender. The student will apply understandings to one’s own social identities and other groups living in Minnesota, centering those whose stories and histories have been marginalized, erased, or ignored.
  • Subp. 6. Ethnic Studies. B. Resistance: The student will describe how individuals and communities have fought for freedom and liberation against systemic and coordinated exercises of power locally and globally. The student will identify strategies or times that have resulted in lasting change. The student will organize with others to engage in activities that could further the rights and dignity of all.
  • Subp. 6. Ethnic Studies. C. Ways of Knowing and Methodologies: The student will use ethnic and Indigenous studies methods and sources in order to understand the roots of contemporary systems of oppression and apply lessons from the past in order to eliminate historical and contemporary injustices.

The Ethnic Studies benchmarks reveal additional evidence of ideological bias. For example, students will study our justice system in connection with Subp. 6. Ethnic Studies C., which requires them to understand “the roots of contemporary systems of oppression.”

MDE makes no attempt to justify its addition of Ethnic Studies’ ideologically skewed, highly controversial claims to academic standards that all Minnesota students are expected to “master.” Nor does it define the terms the Ethnic Studies standards use. The SONAR merely asserts, without evidence, that these new standards are “needed and reasonable” because they support “national trends and research.” Indeed, there can be no persuasive defense of MDE’s actions in this regard.

The political influence that shaped the standards

The ideological bias evident in MDE’s proposed 2021 Social Studies standards appears to be unprecedented in the history of Minnesota academic standards. This is because the circumstances under which the standards were created are unprecedented. The process employed requires scrutiny.

MDE claims that the changes it is making to Social Studies instruction are intended to increase academic rigor [p. 58] and to better prepare students for career and college, as required by Minn. Stat. 120B.021. In fact, there is strong evidence that a major motive in the replacement of the standards is advancement of a political agenda.

In 2020, the Minnesota Department of Education appointed a Social Studies Standards Committee to draft revised standards. The committee included a core group of leaders of the Minnesota Ethnic Studies Coalition (MESC) and its allies. MESC is an alliance of advocacy groups, which was created in 2019 as a “project” of another advocacy organization called “Education for Liberation Minnesota,” according to the EdLib MN website.

MESC described its goal as “solidifying Ethnic Studies” throughout K-12 education in order to “center” (i.e., shift the instructional focus to) groups “erased from mainstream curricula due to persistent racism, patriarchy, xenophobia, and linguistic imperialism.”

EdLib MN’s mission is “to be a political force” in Minnesota to “contend with the status quo of colonial education that prioritizes Eurocentric curricula” and “predominantly white educators and administrators,” according to its website.

MESC and EdLib MN had a two-pronged strategy: 1) to pass a bill requiring schools to provide Ethnic Studies statewide, and 2) to have EdLib MN members named to MDE’s Social Studies Standards Committee in order to “center” Ethnic Studies “content in Social Studies curriculum,” according to EdLib MN’s website.

EdLib MN’s website states that:

In 2020 the decision was made to pack the MN social studies revision committee, led by the MN Department of Education (MDE), to demand that Ethnic Studies be included in social studies curricula. After a successful multi year campaign the members of the committee were able to successfully include a ‘5th strand’ in the proposed standards focused on Ethnic Studies authored by members of our growing coalition.

In 2023, the Minnesota Legislature created a permanent Ethnic Studies working group at MDE. MDE must appoint the group’s members with “input from the Minnesota Ethnic Studies Coalition.”

In November 2020, Jonathan Hamilton — a member of the Social Studies Standards Committee and a leader of EdLib MN — wrote a MinnPost article entitled, “The Time for Ethnic Studies is Now.” In it, he called for ending “Minnesota’s Eurocentric, white-washed curriculum,” and proposed that this be accomplished by revising “the Social Studies Standards that drive state curricula, guiding educators in terms of what should be taught and assessed.” Hamilton’s co-author was Brian Lozenski, also a leader of EdLib MN. Both are professors at Macalester College.

MDE’s SONAR makes no mention of these facts in its 87 pages.

Prof. Wilfred McClay, an eminent American historian who reviewed the third draft of the 2021 Social Studies standards for Center of the American Experiment, summed up the standards this way:

It is hard to exaggerate the destructiveness of what is being attempted in Minnesota. I cannot think of a single historical example of a nation whose governing authorities would choose to instruct their children in such a corrosive and self-abasing way. 

Inquiry-based learning is a method of instruction, and its imposition on all Minnesota school districts by means of the 2021 Social Studies standards would be a violation of law. [Minn. Stat. 120B (Subd. 2)(3)(2)]