Facts of the Case

In 1981, the Alabama State Legislature passed a law authorizing a one-minute period of silence in all public schools “for meditation or voluntary prayer.” This statute was an amendment to a previous law that allowed for a moment of silence for meditation. Ishmael Jaffree, a parent of three children attending public schools in Mobile, Alabama, challenged the law, arguing that it was an attempt to reintroduce prayer into public schools, thus violating the Establishment Clause of the First Amendment.

Constitutional Question

Does a state law authorizing a one-minute period of silence in public schools “for meditation or voluntary prayer” violate the Establishment Clause of the First Amendment?

Arguments

For Jaffree:

• The law’s specific mention of “voluntary prayer” endorses religious activity and is an unconstitutional government endorsement of religion.
• The primary purpose of the law was to reintroduce prayer into public schools, which breaches the separation of church and state.
• The law has no secular purpose and is intended to promote religious practices in public schools.

For Wallace (Governor of Alabama):

• The moment of silence is a neutral act that accommodates both religious and non-religious students without coercing anyone to participate in religious activities.
• The law allows for voluntary prayer, which does not constitute an endorsement of religion but rather protects individual freedoms.
• Similar practices have historical precedence and reflect the religious heritage of the nation.

The Decision

The Supreme Court, in a 6-3 decision, ruled in favor of Jaffree. Justice John Paul Stevens, writing for the majority, held that the Alabama law violated the Establishment Clause of the First Amendment. The Court found that the statute lacked any clear secular purpose and was enacted to promote prayer in public schools, thus endorsing religion. The decision applied the Lemon test from Lemon v. Kurtzman, which requires laws to have a secular legislative purpose, not advance or inhibit religion, and avoid excessive government entanglement with religion. The Court concluded that the law failed this test.

Significance

Wallace v. Jaffree is a significant case in the interpretation of the Establishment Clause, reinforcing the principle that government actions must remain neutral regarding religion. The ruling underscored that any state action perceived as endorsing or promoting religious activities in public schools is unconstitutional. This decision further solidified the application of the Lemon test in evaluating the constitutionality of laws concerning religion and maintained the strict separation of church and state in the educational context. Wallace v. Jaffree played a crucial role in defining the boundaries of religious expression and government involvement in public schools.