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Santa Fe Independent School District v. Doe

Citation. 530 U.S. 290, 120 S.Ct. 2266, 147 L.Ed.2d 295 (2000).

Brief Fact Summary.

Plaintiffs challenged Defendant’s use of prayer in schools, arguing it violated the First Amendment.

Synopsis of Rule of Law.

The religious liberty protected by the Constitution is abridged when the state affirmatively sponsors the particular religious practice of prayer.


A student council chaplain was elected to deliver a prayer over the public address system before each varsity football game for the entire season. This practice was challenged by Plaintiffs.

While the proceedings were pending Defendant adopted a different policy that permitted prayer initiated by a student at all home games. The senior class also voted to include prayer at the high school graduation. Plaintiffs challenged these actions, arguing they violated the First Amendment.


Whether the student-led, student-initiated prayer at football games violates the First Amendment.


Yes. The student-led, student-initiated prayer at football games violates the First Amendment.


Justice Rehnquist

The tone of the Court’s opinion bristles with hostility to all things religious in public life. The fact that a policy might operate unconstitutionally under some conceivable set of circumstances is insufficient to render it wholly invalid.


School sponsorship of a religious message is impermissible because it sends the ancillary message to members of the audience that they are outsiders. Additionally, the choice between whether to attend these games or to risk facing a personally offensive religious ritual is in no practical sense an easy one. The Constitution demands that the school may not force this difficult choice on students.

Lastly, nothing prohibits any student from voluntarily praying before, during, or after the school day by themselves. Judgement affirmed.

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