Chandler v. Siegleman

Citation: Not availableDocket: 97-6898

Court: Court of Appeals for the Eleventh Circuit; July 13, 1999; Federal Appellate Court

Original Court Document: View Document

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Michael Chandler and Jane Doe, on behalf of their children, initiated a legal case against Alabama officials, including Governor Don Siegelman and Attorney General Bill Pryor. The United States Court of Appeals for the Eleventh Circuit reviewed the case, which had previously seen the court vacate a Permanent Injunction from a lower district court. Following a Supreme Court decision in June 2000 regarding student-led prayer in Santa Fe Independent School District v. Doe, the Eleventh Circuit was directed to reassess its earlier ruling in Chandler I. Upon review, the court determined there was no conflict between its decision and the Supreme Court's findings in Santa Fe.

The key distinction made was that Santa Fe condemns school-sponsored prayer while Chandler condemns school censorship regarding prayer. The court clarified that both cases complement each other. In Santa Fe, it was established that school districts cannot create avenues for prayer at school functions, highlighted by a case where a school policy allowed student-led invocations at football games, which was deemed to represent state sponsorship of religion. The Eleventh Circuit emphasized that the school policy implicitly endorsed a specific religious message, thus failing to maintain neutrality as required by the Establishment Clause of the First Amendment. The court reinstated its earlier judgment in Chandler I, underscoring its compatibility with the Supreme Court's analysis.

The Santa Fe policy's critical flaw was its attempt to maintain neutrality toward religious speech by implementing a student election process. The Court determined that this system effectively silenced minority viewpoints by ensuring that only majority-approved messages could be delivered. This approach, the Court argued, substituted majority views for the required government neutrality mandated by the Establishment Clause, undermining its purpose of protecting against the dominance of a religious majority. As a result, the policy was found not to be neutral; instead, it conveyed both a perceived and actual endorsement of religion, with school involvement making the pre-game prayers appear as state-sponsored rather than private speech. The Court emphasized that such prayer, facilitated via the school's public address system and under faculty supervision, cannot be classified as private speech protected by the Free Exercise and Free Speech Clauses. It ruled that state-sponsored, coercive prayer is unconstitutional while maintaining that not all religious messages in school contexts are government speech. The distinction between government-endorsed religion and private religious expression remains, with the Court indicating that the Santa Fe ruling specifically addresses coercive state-sponsored prayer without resolving the broader question of when religious speech can be considered private and protected in schools. The precedent established in Chandler I further clarifies that student religious expression does not automatically equate to state action merely because it occurs in a school setting.

The legal document emphasizes that the Constitution does not require the suppression of private student religious speech in public settings, asserting that such speech can occur openly, as long as it is genuinely student-initiated and not influenced by school policy. It distinguishes between private religious speech and school-sponsored activities, clarifying that the latter is what the Court condemned in Santa Fe. The text affirms that students have the right to express religious beliefs publicly without state endorsement or coercion. 

The Permanent Injunction against the school district prohibits it from facilitating organized religious activities but incorrectly restricts students from speaking religiously in public contexts. The injunction must not prevent genuinely student-initiated religious expression or impose stricter limitations on religious speech than those applied to secular speech. The document calls for the district court to revise the injunction to comply with constitutional protections for private religious speech, reinforcing the principle of neutrality in religious expression. The court also highlights the need for monitoring to ensure that school personnel do not misuse this permission to engage in proselytizing. The case is remanded for further proceedings consistent with these principles.