Engel v. Vitale
|Engel v. Vitale|
|Argued April 3, 1962|
Decided June 25, 1962
|Full case name||Steven I. Engel, et al. v. William J. Vitale, Jr., et al.'|
|Citations||370 U.S. 421 (more)|
|Prior||191 N.Y.S.2d 453 (Sup. Ct. 1959), aff'd, 206 N.Y.S.2d 183 (App. Div. 1960), aff'd, 176 N.E.2d 579 (N.Y. 1961); cert. granted, 368 U.S. 924 (1961).|
|Subsequent||186 N.E.2d 124 (N.Y. 1962)|
|Government-directed prayer in public schools violates the Establishment Clause of the First Amendment, even if the prayer is denominationally neutral and students may remain silent or be excused from the classroom during its recitation.|
|Majority||Black, joined by Warren, Douglas, Clark, Harlan, Brennan|
|Frankfurter and White took no part in the consideration or decision of the case.|
|U.S. Const. amend. I|
Engel v. Vitale, 370 U.S. 421 (1962), was a landmark United States Supreme Court case in which the Court ruled that it is unconstitutional for state officials to compose an official school prayer and encourage its recitation in public schools, due to violation of the First Amendment. The ruling has been the subject of intense debate.
The state of New York approved a piece of legislation which encouraged students to start their school days with the Pledge of Allegiance and a prayer with the text:
The case was brought by a group of families of public school students in New Hyde Park from the Herricks Union Free School District who sued the school board president William J. Vitale, Jr. The families argued that the voluntary prayer written by the state board of regents to "Almighty God" contradicted their religious beliefs. Led by Steven I. Engel, a Jewish man, the plaintiffs sought to challenge the constitutionality of the state's prayer in school policy. They were supported by groups opposed to the school prayer including rabbinical organizations, Ethical Culture, and Jewish organizations.
The acting parties were not members of one particular religious persuasion, or all atheists. Their religious identities were legally identified in court paperwork as two Jews, an atheist, a Unitarian church member, and a member of the New York Society for Ethical Culture. However, despite being listed in the court papers as an atheist, plaintiff Lawrence Roth, who was raised Jewish, later denied that he was an atheist and described himself as religious and a participant of prayer. When religious affiliation was discussed during preparations for the case, Roth claimed he was "a very religious person, but not a churchgoer" and that he said prayers but was unsure of what prayer could accomplish. This resulted in the group's lawyer telling him "You're the atheist." Roth later stated "apparently, you have to have an atheist in the crowd, so we started from there."
The plaintiffs argued that opening the school day with such a prayer violates the Establishment Clause of the First Amendment to the United States Constitution (as applied to the states through the Fourteenth Amendment), which states, in part, "Congress shall make no law respecting an establishment of religion". The governments of twenty-two states submitted an amicus curiae brief to the Supreme Court urging affirmance of the New York Court of Appeals decision that upheld the constitutionality of the prayer. The American Jewish Committee, the Synagogue Council of America, and the American Ethical Union each submitted briefs urging the Court to instead reverse and rule that the prayer was unconstitutional.
Opinion of the Court
In a 6–1 decision, the Supreme Court held that reciting government-written prayers in public schools was unconstitutional, violating the Establishment Clause of the First Amendment.
In his opinion for the Court, Justice Black explained the importance of separation between church and state by giving a lengthy history of the issue, beginning with the 16th century in England. He noted that prayer is a religious activity by its very nature, and that prescribing such a religious activity for school children violates the Establishment Clause.
The Court rejected the defendant's arguments that students were not asked to observe any specific established religion, that the traditional heritage of the nation was religious, and that the prayer was voluntary. The Court held that the mere promotion of a religion is sufficient to establish a violation, even if that promotion is not coercive. The Court further held that the fact that the prayer is vaguely-enough worded not to promote any particular religion is not a sufficient defense, as it still promotes a family of religions (those that recognize "Almighty God"), which still violates the Establishment Clause.
In his dissenting opinion, Justice Stewart contended that the Establishment Clause was originally written to abolish the idea of a state-sponsored church, and not to stop a non-mandatory "brief non-denominational prayer".
Since its decision, Engel has been the subject of intense debate. It has become considered one of the Court's "liberal" decisions alongside decisions such as its sequel, Abington School District v. Schempp, Griswold v. Connecticut, Miranda v. Arizona and its sequel, in re Gault, Eisenstadt v. Baird, Roe v. Wade, Miller v. California and Mapp v. Ohio, and has been criticized for its broadness in holding that a showing of coercion is not required to demonstrate an Establishment Clause violation.
Engel has been the basis for several subsequent decisions limiting government-directed prayer in school. In Wallace v. Jaffree (1985), the Supreme Court ruled Alabama's law permitting one minute for prayer or meditation was unconstitutional. In Lee v. Weisman (1992), the court prohibited clergy-led prayer at middle school graduation ceremonies. Lee v. Weisman, in turn, was a basis for Santa Fe ISD v. Doe (2000), in which the Court extended the ban to school-organized student-led prayer at high school football games in which a majority of students voted in favor of the prayer.
One myth of the Engel v. Vitale case was that an atheist leader Madalyn Murray O'Hair was responsible for the landmark ruling of the case. A year after the 1962 ruling there were two separate suits challenging Bible-reading; one by Ed Schemp in Philadelphia and the other by Mrs. O’Hair in Maryland. The court combined the two cases and subsequently ruled consistent with Engel.
- List of United States Supreme Court cases, volume 370
- List of United States Supreme Court cases
- Separation of church and state in the United States
- West Virginia State Board of Education v. Barnette (1943)
- Everson v. Board of Education (1947)
- Abington School District v. Schempp (1963)
- Lemon v. Kurtzman (1971)
- Wallace v. Jaffree (1985)
- Herricks Union Free School District
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- David L. Hudson Jr., First Amendment scholar (August 26, 2005). "Plaintiff in 1962 landmark school-prayer case reflects on his role". www.firstamendmentcenter.org.
- Gold, Susan Dudley (2006). Engel V. Vitale: Prayer in the Schools. Marshall Cavendish. p. 16. ISBN 9780761419402 – via Google Books.
- U.S. Const. Amend. I.
- The amicus curiae brief was submitted by the attorneys general of Arizona, Arkansas, Connecticut, District of Columbia, Florida, Georgia, Idaho, Indiana, Kansas, Maryland, Mississippi, Nevada, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Pennsylvania, Rhode Island, South Dakota, Texas, and West Virginia. Engel v. Vitale, 370 U.S. 421 (1962).
- Engel v. Vitale, 370 U.S. 421 (1962)
- "Facts and Case Summary - Engel v. Vitale". US Courts. Retrieved February 16, 2019.
- Smith, Christopher; Hensley, Thomas (Fall 1994). "Unfulfilled Aspirations: The Court-Packing Efforts of Presidents Reagan and Bush". Albany Law Review. 57: 1111, 1130.
- W., McConnell, Michael (1986). "Coercion: The Lost Element of Establishment". William & Mary Law Review. 27 (5). ISSN 0043-5589.
- Graham, Kristin (Winter 1994). "The Supreme Court Comes Full Circle: Coercion as the Touchstone of an Establishment Clause Violation". Buffalo Law Review. 42: 147, 158.
- "School Prayer Ruling", New York Times, 26 December 1996.
- Dierenfield, Bruce J. (2007). The battle over school prayer: how Engel v. Vitale changed America. University Press of Kansas. ISBN 978-0-7006-1525-4. Retrieved 5 July 2012.
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- Schwarz, Alan (1968). "No Imposition of Religion: The Establishment Clause Value". Yale Law Journal. 77 (4): 692–737. doi:10.2307/795008. JSTOR 795008..
- Sutherland, Arthur E., Jr. (1962). "Establishment According to Engel". Harvard Law Review. 76 (1): 25–52. doi:10.2307/1338663. JSTOR 1338663..