Wallace v. Jaffree
Encyclopedia
Wallace v. Jaffree, , was a United States Supreme Court
case deciding on the issue of silent school prayer
.
An Alabama law authorized teachers to set aside one minute at the start of each day for a moment
of "silent meditation
or voluntary prayer
," and sometimes the teacher of the classroom asked upon a student to recite some prayers.
Ishmael Jaffree, an American citizen
, was a resident of Mobile County, Alabama
and a parent of three students who attended school in the Mobile County public school system; two of the three children were in the second grade
and the third was in kindergarten
. On May 28, 1982, Jaffree brought suit naming the Mobile County School Board
, various school officials, and the minor plaintiffs' three teachers as defendants. Jaffree sought a declaratory judgment
and an injunction
restraining the defendants from "maintaining or allowing the maintenance of regular religious prayer services or other forms of religious observances in the Mobile County Public Schools in violation of the First Amendment
as made applicable to states by the Fourteenth Amendment to the United States Constitution."
Jaffree's complaint further alleged that two of his children had been subjected to various acts of religious indoctrination and that the defendant teachers had led their classes in saying certain prayers in unison on a daily basis; that as a result of not participating in the prayers his minor children had been exposed to ostracism from their peer group classmates; and that Jaffree had repeatedly but unsuccessfully requested that the prayers be stopped.
The United States District Court for the Southern District of Alabama
allowed the practice and found in favor of the defendants. The United States Court of Appeals for the Eleventh Circuit reversed, holding the law unconstitutional. The Supreme Court ruled, 6-3, that the Alabama law violated constitutional principle. Justice John Paul Stevens
wrote the majority opinion
and was joined by Justices William J. Brennan, Jr.
, Thurgood Marshall
, Harry Blackmun
, and Lewis Powell. Justice Powell wrote a separate concurring opinion, and Justice Sandra Day O'Connor
wrote an opinion concurring in the judgment
. Chief Justice
Warren E. Burger
and Associate Justices William H. Rehnquist (later Chief Justice) and Byron White
issued dissenting opinion
s. Rehnquist asserted that the Court's Establishment Clause reasoning was flawed in as much as it was based on the writings of Thomas Jefferson
, who was not the author of the Clause.
From the court opinion:
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case deciding on the issue of silent school prayer
School prayer
School prayer in its common usage refers to state-approved prayer by students in state schools. Depending on the country and the type of school, organized prayer may be required, permitted, or prohibited...
.
An Alabama law authorized teachers to set aside one minute at the start of each day for a moment
Moment of silence
A moment of silence is the expression for a period of silent contemplation, prayer, reflection, or meditation. Similar to flying a flag at half-mast, a moment of silence is often a gesture of respect, particularly in mourning for those who have recently died or as part of a commemoration ceremony...
of "silent meditation
Meditation
Meditation is any form of a family of practices in which practitioners train their minds or self-induce a mode of consciousness to realize some benefit....
or voluntary prayer
Prayer
Prayer is a form of religious practice that seeks to activate a volitional rapport to a deity through deliberate practice. Prayer may be either individual or communal and take place in public or in private. It may involve the use of words or song. When language is used, prayer may take the form of...
," and sometimes the teacher of the classroom asked upon a student to recite some prayers.
Ishmael Jaffree, an American citizen
Citizenship in the United States
Citizenship in the United States is a status given to individuals that entails specific rights, duties, privileges, and benefits between the United States and the individual...
, was a resident of Mobile County, Alabama
Mobile County, Alabama
Mobile County[p] is a county of the U.S. state of Alabama. Its name is in honor of a tribe of Indians, the Maubila tribe . As of 2011, its population was 415,704. Its county seat is Mobile, Alabama...
and a parent of three students who attended school in the Mobile County public school system; two of the three children were in the second grade
Second grade
In the United States, second grade is a year of primary education. Second grade is the second school year after kindergarten. Students are traditionally 7–8 years old, depending on when their birthday occurs....
and the third was in kindergarten
Kindergarten
A kindergarten is a preschool educational institution for children. The term was created by Friedrich Fröbel for the play and activity institute that he created in 1837 in Bad Blankenburg as a social experience for children for their transition from home to school...
. On May 28, 1982, Jaffree brought suit naming the Mobile County School Board
Mobile County Public School System
Mobile County Public School System is a school district based in the Mobile County Public Schools Central Office Campus in an unincorporated area in Mobile County, Alabama United States....
, various school officials, and the minor plaintiffs' three teachers as defendants. Jaffree sought a declaratory judgment
Declaratory judgment
A declaratory judgment is a judgment of a court in a civil case which declares the rights, duties, or obligations of one or more parties in a dispute. A declaratory judgment is legally binding, but it does not order any action by a party. In this way, the declaratory judgment is like an action to...
and an injunction
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
restraining the defendants from "maintaining or allowing the maintenance of regular religious prayer services or other forms of religious observances in the Mobile County Public Schools in violation of the First Amendment
First Amendment to the United States Constitution
The First Amendment to the United States Constitution is part of the Bill of Rights. The amendment prohibits the making of any law respecting an establishment of religion, impeding the free exercise of religion, abridging the freedom of speech, infringing on the freedom of the press, interfering...
as made applicable to states by the Fourteenth Amendment to the United States Constitution."
Jaffree's complaint further alleged that two of his children had been subjected to various acts of religious indoctrination and that the defendant teachers had led their classes in saying certain prayers in unison on a daily basis; that as a result of not participating in the prayers his minor children had been exposed to ostracism from their peer group classmates; and that Jaffree had repeatedly but unsuccessfully requested that the prayers be stopped.
The United States District Court for the Southern District of Alabama
United States District Court for the Southern District of Alabama
The United States District Court for the Southern District of Alabama is the Federal district court whose jurisdiction comprises the following counties: Baldwin, Choctaw, Clarke, Conecuh, Dallas, Escambia, Hale, Marengo, Mobile, Monroe, Perry, Washington, and Wilcox...
allowed the practice and found in favor of the defendants. The United States Court of Appeals for the Eleventh Circuit reversed, holding the law unconstitutional. The Supreme Court ruled, 6-3, that the Alabama law violated constitutional principle. Justice John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
wrote the majority opinion
Majority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision....
and was joined by Justices William J. Brennan, Jr.
William J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
, Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
, Harry Blackmun
Harry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
, and Lewis Powell. Justice Powell wrote a separate concurring opinion, and Justice Sandra Day O'Connor
Sandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
wrote an opinion concurring in the judgment
Concurring opinion
In law, a concurring opinion is a written opinion by one or more judges of a court which agrees with the decision made by the majority of the court, but states different reasons as the basis for his or her decision...
. Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Warren E. Burger
Warren E. Burger
Warren Earl Burger was the 15th Chief Justice of the United States from 1969 to 1986. Although Burger had conservative leanings, the U.S...
and Associate Justices William H. Rehnquist (later Chief Justice) and Byron White
Byron White
Byron Raymond "Whizzer" White won fame both as a football halfback and as an associate justice of the Supreme Court of the United States. Appointed to the court by President John F. Kennedy in 1962, he served until his retirement in 1993...
issued dissenting opinion
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
s. Rehnquist asserted that the Court's Establishment Clause reasoning was flawed in as much as it was based on the writings of Thomas Jefferson
Thomas Jefferson
Thomas Jefferson was the principal author of the United States Declaration of Independence and the Statute of Virginia for Religious Freedom , the third President of the United States and founder of the University of Virginia...
, who was not the author of the Clause.
From the court opinion:
-
- Section 16-1-20.1 is a law respecting the establishment of religion and thus violates the First Amendment.
-
- (a) The proposition that the several States have no greater power to restrain the individual freedoms protected by the First Amendment than does Congress is firmly embedded in constitutional jurisprudence. The First Amendment was adopted to curtail Congress' power to interfere with the individual's freedom to believe, to worship, and to express himself in accordance with the dictates of his own conscience......
-
- (b) One of the well-established criteria for determining the constitutionality of a statute under the Establishment Clause is that the statute must have a secular legislative purpose. The First Amendment requires that a statute must be invalidated if it is entirely motivated by a purpose to advance religion.
-
- (c) The record here not only establishes that 16-1-20.1's purpose was to endorse religion, it also reveals that the enactment of the statute was not motivated by any clearly secular purpose." "...The State's endorsement, by enactment of 16-1-20.1, of prayer activities at the beginning of each schoolday is not consistent with the established principle that the government must pursue a course of complete neutrality toward religion.
See also
- List of United States Supreme Court cases, volume 472
- Engel v. VitaleEngel v. VitaleEngel v. Vitale, 370 U.S. 421 , was a landmark United States Supreme Court case that determined that it is unconstitutional for state officials to compose an official school prayer and require its recitation in public schools....
(1961)