Wallace v. Jaffree
| Wallace v Jaffree | ||||||
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 Supreme Court of the United States |
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| Argued December 4, 1984 Decided June 4, 1985 |
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| Full case name | Wallace, Governor of Alabama, et al. v. Jaffree, et al. | |||||
| Citations | 472 U.S. 38 (more) 105 S. Ct. 2479; 86 L. Ed. 2d 29; 1985 U.S. LEXIS 91; 53 U.S.L.W. 4665 |
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| Prior history | Appeal from the United States Court of Appeals for the Eleventh Circuit | |||||
| Holding | ||||||
| State endorsement of prayer activities in schools is prohibited by the First Amendment. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Stevens, joined by Brennan, Marshall, Blackmun, Powell | |||||
| Concurrence | Powell | |||||
| Concurrence | O'Connor | |||||
| Dissent | Rehnquist | |||||
| Dissent | Burger | |||||
| Dissent | White | |||||
| Laws applied | ||||||
| U.S. Const. amend. I | ||||||
Wallace v. Jaffree, 472 U.S. 38 (1985), was a United States Supreme Court case deciding on the issue of silent school prayer.
An Alabama law authorized teachers to set aside one minute at the start of each day for a moment of "silent meditation or voluntary prayer," and sometimes the teacher of the classroom asked upon a student to recite some prayers.
Ishmael Jaffree, an American citizen, was a resident of Mobile County, Alabama and a parent of three students who attended school in the Mobile County public school system; two of the three children were in the second grade and the third was in kindergarten. On May 28, 1982, Jaffree brought suit naming the Mobile County School Board, various school officials, and the minor plaintiffs' three teachers as defendants. Jaffree sought a declaratory judgment and an injunction restraining the defendants from "maintaining or allowing the maintenance of regular religious prayer services or other forms of religious observances in the Mobile County Public Schools in violation of the First Amendment as made applicable to states by the Fourteenth Amendment to the United States Constitution."
Jaffree's complaint further alleged that two of his children had been subjected to various acts of religious indoctrination and that the defendant teachers had led their classes in saying certain prayers in unison on a daily basis; that as a result of not participating in the prayers his minor children had been exposed to ostracism from their peer group classmates; and that Jaffree had repeatedly but unsuccessfully requested that the prayers be stopped.
The United States District Court for the Southern District of Alabama allowed the practice and found in favor of the defendants. The United States Court of Appeals for the Eleventh Circuit reversed, holding the law unconstitutional. The Supreme Court ruled, 6-3, that the Alabama law violated constitutional principle. Justice John Paul Stevens wrote the majority opinion and was joined by Justices William J. Brennan, Jr., Thurgood Marshall, Harry Blackmun, and Lewis Powell. Justice Powell wrote a separate concurring opinion, and Justice Sandra Day O'Connor wrote an opinion concurring in the judgment. Chief Justice Warren E. Burger and Associate Justices William H. Rehnquist (later Chief Justice) and Byron White issued dissenting opinions. Rehnquist asserted that the Court's Establishment Clause reasoning was flawed in as much as it was based on the writings of Thomas Jefferson, who was not the author of the Clause.
From the court opinion:
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- Section 16-1-20.1 is a law respecting the establishment of religion and thus violates the First Amendment.
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- (a) The proposition that the several States have no greater power to restrain the individual freedoms protected by the First Amendment than does Congress is firmly embedded in constitutional jurisprudence. The First Amendment was adopted to curtail Congress' power to interfere with the individual's freedom to believe, to worship, and to express himself in accordance with the dictates of his own conscience......
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- (b) One of the well-established criteria for determining the constitutionality of a statute under the Establishment Clause is that the statute must have a secular legislative purpose. The First Amendment requires that a statute must be invalidated if it is entirely motivated by a purpose to advance religion.
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- (c) The record here not only establishes that 16-1-20.1's purpose was to endorse religion, it also reveals that the enactment of the statute was not motivated by any clearly secular purpose." "...The State's endorsement, by enactment of 16-1-20.1, of prayer activities at the beginning of each schoolday is not consistent with the established principle that the government must pursue a course of complete neutrality toward religion.
[edit] See also
[edit] Further reading
- Kurland, Philip B. (1961), "Of Church and State and the Supreme Court", University of Chicago Law Review 29 (1): 1–96, doi:10.2307/1598520.
- Redlich, Norman (1985), "Separation of Church and State: The Burger Court's Tortuous Journey", Notre Dame Law Review 60: 1094.
- Schwarz, Alan (1968), "No Imposition of Religion: The Establishment Clause Value", Yale Law Journal 77 (4): 692–737, doi:10.2307/795008.
- Smith, Rodney K. (1985), "Now is the Time for Reflection: Wallace v. Jaffree and Its Legislative Aftermath", Alabama Law Review 37: 345.
