Introduction
Mormon and Catholic students of Santa Fe district high schools found themselves offended by prayer practices at schools. Namely, before every home football match, one of the students of the school would deliver a prayer over the school’s public address system (Santa Fe Independent School District v. Doe, 530 U.S. 290 (2000)).
Procedural History
In 1995, students of Mormon and Catholic religious persuasion who attended Santa Fe high schools together with their mothers filed a lawsuit against the school district to the United States District Court of the Southern District of Texas. In the lawsuit, they stated that the schools were engaged in a practice that violated the First Amendment of the US Constitution. During the process, the schools revised their procedure (Santa Fe Independent School District v. Doe, 530 U.S. 290 (2000)). They began referring to the practice as “invocations” rather than prayers, and the students of the school began voting whether or not they want the “invocations” to take place and which student should deliver them (Santa Fe Independent School District v. Doe, 530 U.S. 290 (2000)). The plaintiffs in this case were referred to as Does in order to protect their identity because they could face serious harassment from the community.
Referring to Jones v. Clear Creek, 930 F.2d 416 (1991), Judge Samuel Kent of the Southern District Court of Texas ruled that the practice can be maintained as long as it refrained from sectarianism and attempts to convert others.
Both sides appealed to the United States Court of Appeals. The Independent Santa Fe School District claimed that the refrainment from sectarianism was not necessary while the plaintiffs demanded that the practice be outlawed completely. After the court ruled that the refrainment from sectarianism is necessary, the plaintiffs demanded the US Supreme Court hearing.
Issues
- Issue 1: whether the Santa Fe school district was forcing individuals to participate in a prayer and/or attempting to establish a state religion which would be in breach of the First Amendment of the US Constitution.
- Issue 2: Whether the prayers delivered over the address system constituted public speech.
Holdings
- Issue 1: No. The Court of Appeals decided that as long as there is no sectarianism in the prayers delivered before football matches, there is no attempt at favoring one religion over others or converting individuals from one religion into the other.
- Issue 2: No. The fact that the students who delivered the invocations were elected on the basis of their own reputations suggests that the invocations that they deliver are their private speech.
- Reasoning: in their appeal, plaintiffs provided the following reasoning in support of their appeal.
- Issue 1: The plaintiffs argued that the First Amendment of the US Constitution bans religious practices of any kind in all public institutions. As the Constitution bans the endorsement of any religion by the government, it automatically prevents all government institutions from engaging in any religious practices.
- Issue 2: Plaintiffs argued that the very fact that the prayers were delivered over the public address system in a public school meant that the school had authorized them. These facts alone entailed that these prayers constituted public speech.
Decision
The Supreme Court accepted the reasoning of the plaintiffs and ruled the practice of school prayers unconstitutional. Relying on Lee v. Weisman, 505 U.S. 577 (1992), which banned the school prayers delivered by the clergy, the Judge ruled that school prayer represented public speech and, therefore, public endorsement of religion which is banned by the Constitutions.
Comment
The case illustrates the fact that the US Supreme Court can give a ruling different than those given by the lower courts. This is particularly true for cases involving the assessment of the status of a particular practice with respect to the provisions of the US Constitution.
References
Jones v. Clear Creek, 930 F.2d 416 (1991).
Lee v. Weisman, 505 U.S. 577 (1992).
Santa Fe Independent School District v. Doe, 530 U.S. 290 (2000).