Wallace v. Jaffree
472 U.S. 38 (1985)
By
Julie Ingram

Facts:

Ishmael Jaffree lived in Mobile County, Alabama. Three of his children (two in second-grade, one in kindergarten) attended Alabama public schools. Jaffree challenged the constitutionality of a 1981 Alabama Statute (§ 16-1-20.1) that authorized a one-minute period of silence in all public schools “for meditation or voluntary prayer.”  He named the Mobile County School Board, school officials, and three teachers as defendants. He also claimed that his children had been subjected to acts of religious indoctrination and that all students were supposed to say the prayers out loud. Initially, the United States District Court for the Southern District of Alabama allowed the meditation and prayer to continue and found in favor of the school. Then, the United States Court of Appeals for the Eleventh Circuit reversed this decision and found the Alabama law to be unconstitutional. The Supreme Court ruled 6-3 that the Alabama law violated the First Amendment and was unconstitutional.

Decision:

The Court decided that the Alabama prayer and meditation statute (§ 16-1-20.1) violated the First Amendment’s Establishment Clause. The Court determined the constitutionality of the Alabama statute by using the Lemon test and by applying the secular purpose prong. This test questioned if the state’s true purpose was to approve of religion. The Court determined that the Alabama prayer and meditation statute differed from the state’s original plan to maintain complete neutrality toward religion. The statute also appeared to positively endorse religion. Therefore, the statute was non-secular and it sought to establish religion in Alabama public schools, and so it violated the First Amendment’s Establishment Clause.

Basis of Decision: