Isabella Carter
In the landmark 1962 case of Engel v. Vitale, the U.S. Supreme Court ruled that voluntary prayer in public schools violated the U.S. Constitution's First Amendment prohibition of a state establishment of religion. The case centred on the Establishment Clause, which states that Congress shall make no law respecting an establishment of religion. The Court decided that reciting government-written prayers in public schools was a violation of the Establishment Clause, as it flouts the Constitution and establishes an official religion.
| Characteristics | Values |
|---|---|
| Year | 1962 |
| Court Decision | The Supreme Court ruled that it is unconstitutional for state officials to compose an official school prayer and encourage its recitation in public schools |
| Court Decision Rationale | The Supreme Court's decision was based on the Establishment Clause of the First Amendment, which states that "Congress shall make no law respecting an establishment of religion." |
| Court Vote | 6-1 |
| Dissent | Justice Stewart argued that the Establishment Clause was meant to prohibit the establishment of a state-sponsored church, not all types of government involvement with religion. He also believed that the nondenominational nature of the prayer and the option to be absent removed constitutional concerns. |
| Public Reaction | The decision was highly controversial and provoked outrage, with 79% of Americans disapproving of the ruling according to a Gallup poll. |
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What You'll Learn
The Supreme Court's ruling
The Court ruled that it is unconstitutional for state officials to compose an official school prayer and encourage its recitation in public schools. The ruling was based on the Establishment Clause of the First Amendment, which states that "Congress shall make no law respecting an establishment of religion." The Court interpreted this clause as prohibiting the government from establishing or sponsoring a particular religion. In the context of Engel v. Vitale, the Court found that the state-written and authorized prayer in public schools violated the Establishment Clause, even though participation in the prayer was voluntary and the prayer was nondenominational.
Justice Hugo L. Black wrote the majority opinion for the Court, concluding that any prescription of religious activity by the state, regardless of its voluntary or nondenominational nature, flouts the Constitution and violates the principle of separation of church and state. The Court's ruling emphasized the importance of keeping government and religion separate, citing historical examples of the negative consequences that arise when the two become allied. This ruling was a firm limit on the individual states' establishment of religion and a significant moment in the history of religious freedom in the United States.
However, the decision was not unanimous, with Justice Potter Stewart dissenting. He argued that the majority had misapplied a great constitutional principle and disagreed that the nondenominational prayer established an "official religion." He believed that denying the wish of school children to recite the prayer denied them the opportunity to share in the spiritual heritage of the nation. The dissent highlighted the complexity of interpreting the Establishment Clause and the ongoing debate surrounding the role of religion in public life.
The ruling in Engel v. Vitale had far-reaching implications and continues to shape the understanding of religious freedom and the separation of church and state in the United States. It sparked intense debates and efforts to overturn the decision, reflecting the strong emotions and differing perspectives on the role of religion in public education.
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The Establishment Clause
In Engel v. Vitale, the Supreme Court ruled that voluntary prayer in public schools violated the Establishment Clause. The case centred on a New York State law that required public schools to open each day with a nondenominational prayer in which students acknowledged their dependence on God. The prayer was written by the state and was voluntary, but a group of parents argued that it violated the Establishment Clause. The Supreme Court agreed, finding that any prescription of religious activity by the state violated the Constitution.
Justice Black, who wrote the majority opinion, described the long history of church and state and concluded that prayer is inherently religious. He argued that any form of prayer was sufficient to trigger the principle of separation of church and state. The lone dissent came from Justice Stewart, who argued that the Establishment Clause was only meant to prohibit the establishment of a state-sponsored church and that the nondenominational nature of the prayer removed constitutional challenges.
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Justice Black's opinion
Justice Hugo L. Black wrote the majority opinion for the Supreme Court in Engel v. Vitale, which ruled that school-sponsored prayer in public schools violated the Establishment Clause of the First Amendment. Black's opinion described the long history of church and state, concluding that prayer is inherently religious and that any prescription of such activity by the state violates the Constitution.
In his opinion, Justice Black argued that the First Amendment's Establishment Clause, which states that "Congress shall make no law respecting an establishment of religion," prohibits the government from interfering with religion. He wrote that the Establishment Clause stands as an expression of principle by the Founding Fathers of the Constitution that religion is too personal, sacred, and holy to be "perverted" by the government.
Justice Black also addressed the argument that the prayer was voluntary and promoted the free exercise of religion, which is also protected by the First Amendment. He wrote that the mere promotion of prayer by the state was sufficient to trigger the principle of separation of church and state. The fact that students could choose to absent themselves from the prayer did not make the law constitutional because the purpose of the First Amendment was to prevent government interference with religion.
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Justice Stewart's dissent
In the case of Engel v. Vitale, Justice Potter Stewart's dissenting opinion argued that the recitation of a voluntary prayer in school did not violate the US Constitution. He contended that the Establishment Clause, which is part of the First Amendment, was originally written to abolish the idea of a state-sponsored church and not to prevent a non-mandatory, brief, non-denominational prayer. Stewart expressed that he could not understand how an "official religion" was established by allowing those who wished to say a prayer. He believed that prohibiting the prayer denied school children the opportunity to share in the spiritual heritage of the nation.
In his opinion, Justice Stewart also criticised the use of metaphors like the "wall of separation" in constitutional adjudication. He argued that the history of religious traditions in the United States, reflected in the practices of government institutions and officials, was more relevant to the issue than the historical context of the established church in sixteenth-century England or eighteenth-century America.
The case of Engel v. Vitale centred around a group of parents in Hyde Park, New York, who objected to a voluntary non-denominational prayer authorised by the New York State Board of Regents in 1958–59. The prayer, known as "The Regents' Prayer", was to be recited at the beginning of each school day and read: "Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers, and our country". The parents argued that this prayer, even though voluntary, violated the Establishment Clause of the First Amendment, which prohibits the establishment of religion by the state.
The Supreme Court's decision in Engel v. Vitale established a precedent that states cannot hold prayers in public schools, even if they are voluntary and non-denominational. This ruling and subsequent related decisions have had a significant impact on limiting government-directed prayer in schools.
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The public reaction
The ruling infuriated the American public, provoking outrage and public denunciations, picketing, billboards, letter-writing campaigns, editorials, resolutions, and pay retaliation. The negative reaction of Congress was overwhelming, with only John Lindsay and Emanuel Celler supporting the decision. Frank J. Becker, for instance, called it "the most tragic decision in the history of the United States".
The Senate Judiciary Committee, led by James Eastland, held hearings on five measures to overturn the Engel decision. Bishop James Pike, a religious moderate and lawyer, opposed the Court's interpretation of the Establishment Clause, arguing for a constitutional amendment to limit the establishment of religion. The Catholic clergy also expressed strong disapproval, with Cardinal Spellman claiming that the decision went against the Godly tradition in which American children had been raised.
On the other hand, the decision was celebrated by most American Jewish groups, with the American Jewish Congress calling the case "a great milestone". The Christian Century was critical of southern politicians who opposed the ruling, accusing them of using the school prayer controversy to criticise the desegregation of public schools.
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Frequently asked questions
The constitutional principle in Engel v. Vitale was that school-sponsored prayer in public schools violates the Establishment Clause of the First Amendment.
The Establishment Clause, found in the First Amendment, reads, "Congress shall make no law respecting an establishment of religion." It was intended to prohibit federal power over religion, leaving the matter to the states.
In a 6-1 decision, the Supreme Court ruled that it is unconstitutional for state officials to compose an official school prayer and encourage its recitation in public schools.
The ruling was highly controversial and provoked outrage in the American public, with many denouncing it as an attack on religious tradition. There were calls to amend the Constitution and impeach the Justices.
