Lynch v. Donnelly

Brief Fact Summary.

A city’s Christmas display in a park located in the heart of the city’s shopping district was held by the Supreme Court of the United States (Supreme Court) to not be in violation of the Establishment Clause of the United States Constitution (Constitution).

Synopsis of Rule of Law.

In this case, the inquiry must be on the display in the context of the Christmas season. Viewed in this context, the question is whether there is sufficient evidence to establish that the inclusion of the display is a purposeful or surreptitious effort to express some kind of governmental advocacy of a particular religious message.

Facts.

Each year, in cooperation with the downtown retail merchants’ association, the City of Pawtucket, Rhode Island, erects a Christmas display as part of its observance of the Christmas holiday season. The display is situated in a park located in the heart of the city’s shopping district and is owned by a nonprofit organization. The display reads, “SEASONS GREETINGS” and includes many figurines including Mary, Jesus and Joseph. Costs for erecting and maintaining the display are nominal to the city. The District Court held that the city’s inclusion of the display violated the Establishment Clause of the Constitution and a divided panel of the First Circuit Court affirmed.

Issue.

Whether there is sufficient evidence to establish that the inclusion of the display is a purposeful or surreptitious effort to express some kind of governmental advocacy of a particular religious message?

Held.

No. Judgment of the First Circuit Court reversed. The Government has long recognized and subsidized holidays with religious significance. Rather than mechanically invalidating all governmental conduct or statutes that confer benefits or give special recognition to religion in general or to one special faith, the Supreme Court has scrutinized challenged legislation or official conduct to determine whether, in reality, it establishes a religion or religious faith, or tends to do so. In this case, the inquiry must be on the display in the context of the Christmas season. Viewed in this context, there is insufficient evidence to establish that the inclusion of the display is a purposeful or surreptitious effort to express some kind of governmental advocacy of a particular religious message. Here, whatever benefit to one faith or religion or to all religions, is indirect, remote and incidental. To forbid the use of this display, at the very time people are singing hymns and carols i
n our public schools, is contrary to our history and our holdings.

Dissent.

The city’s maintenance and display of these symbols cannot be squared with our prior cases. There is no evidence that the framers would have approved a Federal celebration of the Christmas holiday. The city’s action is a coercive step toward establishing the sectarian preferences of the majority at the expense of the minority.
The import of this decision is to encourage the use of such displays in a municipally-sponsored fashion, a setting where Christians feel constrained in acknowledging its symbolic meaning and where non-Christians feel alienated by its presence.
Concurrence. There needs to be a clarification of the Establishment Clause of the Constitution. Further, the display at issue cannot be fairly understood as to convey a message of government endorsement of religion.

Discussion.

Interestingly, the majority upheld a Christmas display erected and maintained by a municipality and not being in violation of the Establishment Clause of the Constitution. This case shows how the Supreme Court looks at each challenge based on the Establishment Clause of the Constitution individually.