The juxtaposition of the views of President Obama and President Sarkozy on the wearing of the veil by Muslim women can tempt us into easy condemnation of one position and praise of the other. Through one prism, their positions could be characterised as respect for religious freedom on the one hand, and unwarranted interference in religious matters on the other. Through another prism, those same positions could be seen as naïve multicultural liberalism versus a pragmatic understanding of the perils facing the secular French state.
We too easily conflate the notion of the separation of church and state in France and the United States, when in fact the different histories of these two nations have given rise to subtle and important differences in how that separation is understood.
President Obama's conviction that the state should not impede "Muslim citizens from practicing religion as they see fit" is rooted in the Free Exercise and Establishment clauses of the First Amendment to the Constitution. The history of these clauses is that of the pilgrims who fled from state-sanctioned constraints on their religious liberty in the Old World.
Thomas Jefferson's 1802 letter to the Danbury Baptist Association expressed this conviction thus: "Believing with you that religion is a matter which lies solely between man & his god, that he owes account to none other for his faith or his worship, that the legitimate powers of government reach actions only, and not opinions, I contemplate with sovereign reverence that act of the whole American people which declared that their legislature should make no law respecting an establishment of religion, or prohibiting the free exercise thereof, thus building a wall of separation between church and state."
The evil that is meant to be excluded in the US notion of the separation of church and state is the tyranny of the state over "church" or religion.
President Obama's position regarding the clothes that Muslim women should be allowed to wear is entirely consistent with this conception of church-state separation: the state should not dictate what a religion requires of its followers.
French laïcité, on the other hand, developed not out of a fear of the power of the state, but out of anxiety regarding the power of the Catholic Church. It is the history of the wars of religion in France, and then the later campaigns of the Catholic Church against the republic, that inform the separation of church and state in France. The evil that this separation is meant to exclude is that of the power of organised religion against the civil rights of the citizen.
President Obama's efforts to reach out to Muslims have much to commend them, but his broad-brush approach can sometimes leave us wondering at the depth of his understanding of the issues at stake. His rhetoric regarding the religious freedom to wear veils may make a wonderful sound bite, but it also disregards the reality of coercion and intolerance in some Muslim communities.
When the independent Stasi Commission appointed by President Chirac in 2003 voted by a near-unanimous majority in favour of a statute to ban the headscarf in French schools, the most powerful and cogent argument its members proffered was that the new law protects girls who do not want to wear headscarves from pressure to do so.
Such pressure is real and present in many Muslim societies. In Malaysia, for instance, Muslim girls who do not wear veils in schools are subject to intense social pressure from teachers and fellow students alike. The International Islamic University in Malaysia introduced a rule in 2004 compelling even non-Muslim female students to wear veils.
This kind of coercion is a reflection of the highly-policed state-sponsored Islam in Malaysia, where an individual who attempts to renounce Islam can be detained in so-called rehabilitation centres, and compelled to pay fines as well as serve a prison sentence. In short, Muslims in Malaysia do not have the right to determine their own religion or to exercise freedom of conscience.
It may well be the case that some Muslim women take on the veil voluntarily, as a visible and proud sign of identity, or out of genuine belief that their faith requires such dress. Such conviction and absence of coercion are by no means a universal phenomenon in Muslim communities.
President Obama may be concerned about the state dictating what clothes a Muslim woman may wear, but what should be done about religious authorities, or family patriarchs, dictating such terms to women?
Protect Muslim believers from the power of the state? Or protect Muslim citizens from the power of the Muslim establishment? This is the real issue, one that is ducked by President Obama, but also perhaps too brutally resolved by President Sarkozy: how is the state to ensure that the consciences of Muslim women be respected, not just by the state but also by their own religious authorities? The concerns of those who defend the French model of laïcité should not be too easily dismissed as advocates of unwarranted state interference in religious matters.
The wearing of the veil is never just a simple expression of faith on the part of Muslim women.
On the positive side, it can be an expression of female empowerment, whereby women refuse to be viewed as sexual objects by men, and take control of their own bodies. Putting on the veil can also be a defiant and necessary marker of identity in a world where distrust of Muslims is widespread.
On the other hand, the veil can also be a means of control in patriarchal and conservative societies, and for some women who claim to put it on voluntarily it can be an expression of an internalised suspicion of their own sexuality.
We have to understand this before we propose or criticise the banning of the veil.

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* Aloysious Mowe, S.J., is a Jesuit priest and a scholar of Islam. He is a researcher and writer at the Middle-Eastern Graduates Center in Malaysia. This article is distributed by the Common Ground News Service (CGNews) with permission from Washington Post/Newsweek's On Faith .