Facts of the case

A student was elected as a chaplain of the student council at Santa Fe High School approaching 1995. Being a student council chaplain, this student was mandated to deliver a Christian prayer during home varsity football games, and the prayer was said before the games using the public address system. Two families, one Catholic and another Mormon filed suit in a District Court to challenge the practice among others under the First Amendment Establishment Clause. The public Santa Fe Independent School District, the District was enjoined from its policy implementation as it stood by the District Court. As the suit was still pending in the District Court, a new policy was adopted by the district. According to this new policy, it permitted but did not require that prayer that was student-initiated and led be said at all home games. It further authorized that two student elections be held. The first student election was to help determine if invocations need to be delivered during the games. The second election was to help select the student spokesperson who could deliver the invocations on the student’s behalf. The students then authorized such prayers after which they selected a spokesperson. Following the move, the District Court ordered to modify the policy in which it only permitted non-proselytizing and non-sectarian prayer to be delivered. When the case moved to the Court of Appeal, the Court in its decision held that, even though the District Court had modified the new policy, the football prayer policy in place was invalid. Unsatisfied with the Court of Appeal decision, the District mover to the Supreme Court to petition for a certiorari writ in which it claimed that the football prayer policy did not violate the Establishment. They argued that the messages in the football game prayer were not public speech but rather the speech of private students.

Issue

The question for determination was whether the Santa Fe Independent School District’s policy that permits student-led and student-initiated prayer before the football games violated the First Amendment Establishment Clause.

Decision

Yes, the Court that the football prayer policy of the District permitting student-led, student-initiated prayer at the home football games was a violation of the First Amendment Establishment Clause.

Reasoning

In its opinion, the Court concluded that prayers at the football games were regarded as public speech following the fact that they were authorized by government policy. Additionally, the prayers were taking place at the school; a property that belongs to the government and the events of football games was official. The football prayer policy, in this case, involved both the perceived and the perceived endorsement from the government to say the prayer during such an important event at the school. The Court argued that it was then easy that any other student or other people in attendance would inevitably conclude that the school and the district representing the government was in support of the prayer policy despite being deemed as private. Therefore, accurately characterizing such speech as private could be wrong.

Further, the Court indicated why in its opinion it felt like this was coercion and unconstitutional by stating that football games were not voluntary events. Supporting this, the Court noted that many students would attend such events either as cheerleaders, band members, players as a requirement since they are part of the games. Additionally, the Court expressed that extracurricular activities play essential roles in the school and the state, thus the country. By this reason, it was likely that many students would develop the desire to attend or participate at the same time involved in social pressure. Thus, it was wrong that the state could take advantage of the social pressure to coerce the students and others in attendance to participate in the religious exercise.

Further supporting its decision, the Court made a conclusion that still declared football prayer policy as invalid. The Court noted that the sole and evident purpose of the prayer policy was to promote the said prayer during the football games. However, this was against the requirement of the establishment of the clause that the acts of the government should indicate secular purpose somewhat religious purpose. But according to the prayer policy adoption history and terms, it was not doubted that the school district had an endorsement of the prayer practice before games. In its final remarks, the Court said that it found the policy invalid based on the way the election was conducted which permitted the view of the majority to be imposed on the view of the religious minorities.

Analysis

The decision of the court was based on the principles that were endorsed in Lee v. Weisman, 505 U. S. 577 case. In this case, the Court ruled that the constitution does not allow the government to coerce to participate or support any religion and its exercise or act in a way that suggests establishing or endorse a religious faith. In the case of Lynch v. Donnelly, 465 U. S. 668, 694, the principle was established that Court has the mandate to guard different other and equally critical constitutional injuries caused to the members of the public like in this case.  The First Amendment Establishment Clause prohibits Congress from making any law that respects establishing religion or limits exercising of religion.

 
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