Summary of Wallace v. Jaffree
Citation: 472 U.S. 38
Relevant Facts: An Alabama law permitted teachers to conduct religious prayer services along with activities in school classrooms during the school day. Three of Jaffree’s children attended public schools in Mobile Alabama. He had vigorously alleged that his children had been religiously indoctrinated at the school, in violation or his and his children’s constitutional rights.
Issues: The legal question presented was whether the law in question violated the petitioners’ constitutional rights per the First Amendment’s Establishment Clause.
Holding: The Supreme Court held that Jaffree’s rights had been violated.
Reasoning: The Court reasoned that Alabama’s law violated the Constitution because it was not religiously neutral. Instead, it promoted a single religion to the detriment of others. The Court’s reasoning included the following three assessments:
(a) The proposition that the several States have no greater power to restrain the individual freedoms protected by the First Amendment than does Congress is firmly embedded in constitutional jurisprudence. The First Amendment was adopted to curtail Congress’ power to interfere with the individual’s freedom to believe, to worship, and to express himself in accordance with the dictates of his own conscience……
(b) One of the well-established criteria for determining the constitutionality of a statute under the Establishment Clause is that the statute must have a secular legislative purpose. The First Amendment requires that a statute must be invalidated if it is entirely motivated by a purpose to advance religion.
(c) The record here not only establishes that 16-1-20.1’s purpose was to endorse religion, it also reveals that the enactment of the statute was not motivated by any clearly secular purpose.” “…The State’s endorsement, by enactment of 16-1-20.1, of prayer activities at the beginning of each schoolday is not consistent with the established principle that the government must pursue a course of complete neutrality toward religion.
Dissent: Justices (Chief) Burger and Rehnquist dissented. Underscoring their dissents, the Justices reasoned that the separation of church and state is not as historically accurate and definitive as the majority asserted. Additionally, by needlessly striking the law down and not being in any way accommodating to morning prayer, the Court was actually intimidating the faithful by penalizing members of a particular religion (Christianity).
Conclusion: This case was significant because the Court ruled that schools cannot impose religion on pupils by continuous indoctrination via morning prayers.