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Robert M. Altman and Victoria L. Altman, His Wife, Individually and as Parents of Minor Children, Russell Altman and Ross Altman Mary Ann Dibari, Individually and as Lawful Guardian of Minor Children Krystal M. Dibari and Tiana N. Dibari Joseph M. Dinozzi and Cecile D. Dinozzi, His Wife, Individually and as Parents of Minor Children, Jon M. Dinozzi, Daniel J. Dinozzi, Steven M. Dinozzi, and Joseph A. Dinozzi, Plaintiffs-Appellees-Cross-Appellants v. Bedford Central School District Dr. Bruce Dennis, in His Capacity as Superintendent of Schools of the Bedford Central School District and Agent/administrator of Its Board of Education Jane Doe (Name Unknown, Post Currently Vacant), in His or Her Capacity as Assistant Superintendent in Charge of Curriculum and Instruction for the Bedford Central School District and Agent/administrator of Its Board of Education Deborah Timberlake, in Her Capacity as President of the Board of Education of Bedford Central School District Board of Education of the Bedford Central Schoo

Citation: 245 F.3d 49Docket: 99-7969

Court: Court of Appeals for the Second Circuit; March 26, 2001; Federal Appellate Court

Narrative Opinion Summary

This case involves a legal dispute between plaintiffs, consisting of several families, and the Bedford Central School District over alleged violations of the First Amendment's Establishment and Free Exercise Clauses. The plaintiffs challenged various school activities that they believed infringed upon their religious rights, including the promotion of certain religious themes and practices in school programs. The district court initially found some activities unconstitutional, such as those involving the Hindu god Ganesha and Earth Day celebrations. However, upon appeal, the United States Court of Appeals for the Second Circuit reversed several of these findings, determining that the activities did not violate constitutional principles. The court also addressed issues of legal standing and mootness, concluding that many of the plaintiffs' claims were moot as they had either graduated or moved away from the district. Consequently, the appellate court vacated parts of the lower court's decision, reversed the declaration of First Amendment violations, and annulled the award of attorneys' fees, leading to a mixed outcome for both parties.

Legal Issues Addressed

Attorneys' Fees under 42 U.S.C. §1988

Application: The reversal of the district court's findings on First Amendment violations led to the reversal of the award of attorneys' fees to the plaintiffs, as they did not prevail on their civil rights claims.

Reasoning: The reversal of the district court's rulings on First Amendment claims necessitates the reversal of the award of attorneys' fees to the plaintiffs, as fees under 42 U.S.C. 1988 are not warranted for parties who do not prevail on civil rights claims.

Establishment Clause under the First Amendment

Application: The court found that certain activities in the school district, such as Earth Day celebrations and the creation of worry dolls, violated the Establishment Clause by promoting religious beliefs, but later reversed this finding for Earth Day celebrations, ruling that these did not constitute an endorsement of religion.

Reasoning: The district court found violations of the Establishment and Free Exercise Clauses concerning activities involving the Hindu god Ganesha, worry dolls, and nature celebrations... The court vacated the earlier judgment declaring these celebrations in violation of the Establishment Clause.

Free Exercise Clause under the First Amendment

Application: The court initially found that certain school activities infringed on the plaintiffs' rights under the Free Exercise Clause, but later reversed this finding, indicating that the activities did not impose a substantial burden on religious practices.

Reasoning: The court ruled that the sponsorship of worry dolls... violated the First Amendment's religion clauses, despite arguments that the tape's volume was lowered... the court reversed the prior judgment declaring the ceremonies a violation of the Free Exercise Clause.

Legal Standing and Mootness in Federal Court

Application: The court determined that the plaintiffs lacked standing in certain claims as they had moved out of the school district or graduated, rendering those claims moot.

Reasoning: The court concluded that the district court should have dismissed the challenges regarding activities at Pound Ridge Elementary due to lack of subject matter jurisdiction and mootness... Altmans and DiNozzis no longer have standing in this case.