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Lee v. Weisman

Citations: 120 L. Ed. 2d 467; 112 S. Ct. 2649; 505 U.S. 577; 1992 U.S. LEXIS 4364Docket: 90-1014

Court: Supreme Court of the United States; June 24, 1992; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

This case addresses the constitutionality of clergy-led prayers at public school graduation ceremonies under the Establishment Clause of the First Amendment. A middle school principal in Providence, Rhode Island, invited a rabbi to deliver nonsectarian prayers at a graduation ceremony, prompting a legal challenge from the Weisman family, who argued that this practice violated the Establishment Clause. The District Court agreed, applying the Lemon test to find that the inclusion of prayers constituted state endorsement of religion. This decision was affirmed by the Court of Appeals and ultimately upheld by the Supreme Court. The Supreme Court emphasized that such practices exert indirect coercion on students, particularly through peer pressure, and that the principal's role in selecting and overseeing the prayers amounted to state endorsement of religion. The Court rejected the argument that attendance at graduation was voluntary, noting the significance of the event for students and their families. The case distinguished itself from Marsh v. Chambers by highlighting the unique coercive pressures in a school setting, which are absent in legislative contexts. The ruling reinforced the principle that public school-sponsored religious exercises violate the Establishment Clause, as applied to the states through the Fourteenth Amendment.

Legal Issues Addressed

Distinction from Legislative Prayer

Application: The case distinguished itself from Marsh v. Chambers by highlighting the unique coercive pressures present in a school setting, which are absent in legislative contexts.

Reasoning: The case also distinguishes itself from Marsh v. Chambers due to the inherent differences between the public school system and a state legislature, where the latter allows greater freedom of attendance and departure.

Establishment Clause of the First Amendment

Application: The Supreme Court ruled that including clergy-led prayers at public school graduations constitutes a violation of the Establishment Clause, as it represents state endorsement of religion.

Reasoning: The Supreme Court ruled that including clergy-led prayers at public school graduations violates the Establishment Clause.

Lemon Test Application

Application: The District Court applied the Lemon test and found that the practice of including prayers at graduation ceremonies failed to pass the test, thus violating the Establishment Clause.

Reasoning: The District Court ruled that the inclusion of prayers violated the Establishment Clause of the First Amendment, applying the three-part test established in Lemon v. Kurtzman.

State Coercion and Religious Exercises

Application: The Court emphasized that state involvement in selecting and overseeing religious exercises at school events exerts indirect coercion on students, violating constitutional principles.

Reasoning: The Court highlighted the risks of indirect coercion inherent in school-led prayer, particularly the potential for peer pressure on students to conform during such ceremonies.

Voluntariness and Coercion

Application: The argument that non-attendance at a graduation ceremony absolves the State of responsibility for coercive practices was rejected, as the Court determined that the choice to abstain from such an important event is not genuinely voluntary.

Reasoning: The argument that non-attendance at a graduation ceremony absolves the State of responsibility for coercive practices is rejected. Graduation is a vital occasion, and the choice to abstain is not genuinely voluntary for students.