Santa Fe Independent School District v. Doe

Brief Fact Summary. The Respondents, Doe and others (Respondents), brought suit to enjoin student-lead prayers at football games, as a violation of the Establishment Clause of the United States Constitution (Constitution).

Synopsis of Rule of Law. School prayer is necessarily a violation of the Establishment Clause when it is conducted in a manner that subjects students to it who do not wish to participate.

Facts. The Respondents began their action in 1995, when they moved for a temporary restraining order, preventing the Petitioner, the Santa Fe Independent School District (Petitioner), from violating the Establishment Clause due to its allowance of school prayer. The District Court held that the school’s action in allowing prayer could not coerce other students into participation. The Court of Appeals agreed with Respondents’ contentions that the allowance of prayers violated the Establishment Clause. The Supreme Court of the United States (Supreme Court) granted writs.

Issue. In allowing certiorari, the Supreme Court limited its inquiry to whether student-led and initiated prayer was a violation of the Establishment Clause.

Held. Affirmed.
The Supreme Court found that pre-game prayer at football games could have the effect of coercion of students to participate in religious worship to which they may or may not proscribe. This, on its face, was a violation of the separation of church and state.
The Supreme Court also enumerated that school sponsorship of a religious message is impermissible because it sends the message to those who do not subscribe to the particular ideology that they are outsiders and not full members of the political community.

Dissent. Judge William Rehnquist (J. Rehnquist) dissented, noting that the Supreme Court’s prohibition on school prayer was a sort of prior restraint because the activity had not taken place since new school regulations had been enacted.

Discussion. This is the landmark decision, which declared prayer in public schools to be unconstitutional as a violation of the Establishment Clause of the First Amendment of the Constitution. While the individual religious freedoms of the students should be recognized, they cannot abrogate the greater policy for the separation of church and state.