Wallace v. Jaffree

At issue in Wallace v. Jaffree (1985) was whether a statute from Alabama could authorize a 1-minute period of silence in all public schools for meditation or voluntary prayer. The U.S. Supreme Court held that this law violated the First Amendment's Establishmen

The original complaint, which did not mention the Alabama statute, alleged that the plaintiff brought the action to seek a declaratory judgment and an injunction restraining the defendants-members of the Mobile County School Board, various school officials, and the minor plaintiffs' three teachers-from maintaining or allowing the practice of regular religious prayer services or other forms of religious observances in the Mobile County Public Schools. The complaint alleged that this practice was in violation of the First Amendment, made applicable to states by the Fourteenth Amendment to the U.S. Constitution. The complaint further alleged that two of the petitioner's minor children had been subjected to various acts of religious indoctrination since the start of the 1981–1982 school year; that their teachers led their classes in saying certain daily prayers in unison; that the complainant's children were ostracized from their classmates if they did not participate in the daily prayers; and that the petitioner, Mr. Jaffree, repeatedly and unsuccessfully requested that the religious activities be stopped. The prime sponsor of the Alabama statute, State Senator Donald G. Holmes, admitted that his introduction of the statute at issue was an initial step toward his hope of returning voluntary prayer to the public schools in Alabama.

On its ruling, the U.S. Supreme Court stressed the fact that the initial ruling in the dispute, in a federal trial court in Alabama, mistakenly concluded that the Establishment Clause did not prohibit state officials from establishing a religion and that the Eleventh Circuit correctly reversed this misinterpretation. In rendering its judgment, the Court applied the so-called Lemon test in evaluating whether the statute violated the Establishment Clause. In Lemon v. Kurtzman (1971), the Court held that, first, a statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion; and, finally, a statute must not foster an excessive government entanglement with religion. The Court ruled that no consideration of the second or third criteria is necessary if a statute does not have a clearly secular purpose.

In applying the Lemon test, the Supreme Court found that the enactment of the statute was not motivated by any clearly secular purpose. In fact, the Court specified that the statute did not have a secular purpose. The Court decided that the legislature had enacted the statute for the sole purpose of endorsing school prayer at the start of every school day, in violation of the established principle of government neutrality toward religion. Taking all of this into consideration, the Court struck the statute down not because it coerced students to participate in prayer, [Page 880]but insofar as the manner of its enactment conveyed a message of state-sponsored approval of prayer activities in public schools.

Wallace v. Jaffree is most often cited for its importance with regard to the body of law stating that public school administrators, teachers, students, and parents may neither mandate nor organize prayer at any time during school activities and events. Yet Wallace is perhaps of even greater significance to First Amendment precedent due to the Court's insistence that the freedom stipulated in the First Amendment embraces the right to choose to follow any religious faith, or none at all. Accordingly, school officials may not indoctrinate students into a particular religion or into any religious activity at all because children have the right to practice any religion they choose, or no religion at all.

...