Eleanor Finch
In 1951, the Board of Regents of New York proposed that public schools start the day with a non-denominational prayer. Students could opt out with a parent's signature. In 1958, five parents of public school students sued the school board president, William J. Vitale Jr., challenging the constitutionality of the Regents' Prayer. The case, Engel v. Vitale, went to the Supreme Court, which ruled that reciting government-written prayers in public schools was unconstitutional, violating the Establishment Clause of the First Amendment. However, Justice Potter Stewart dissented, arguing that the Establishment Clause was not breached by a non-mandatory, non-denominational prayer.
| Characteristics | Values |
|---|---|
| Non-denominational prayer | "Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers and our country. Amen." |
| Author | New York State Board of Regents |
| Opt-out provision | Students could opt out with a parent's signature |
| Constitutional arguments | Accepted practice at the time the amendments were adopted; the Establishment Clause was meant to prohibit the establishment of a state-sponsored church, not all types of government involvement with religion |
| Court rulings | The New York Court of Appeals upheld the constitutionality of the prayer; the Supreme Court ruled that the prayer was unconstitutional |
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What You'll Learn
The prayer was non-denominational and voluntary
In Engel v. Vitale, the US Supreme Court ruled that the recitation of a government-written prayer in public schools was unconstitutional. The ruling stated that the practice violated the Establishment Clause of the First Amendment, which prohibits the government from establishing a national religion and interfering with religion in the states. However, the decision did not outlaw all prayer in public schools. Instead, it prohibited schools from requiring students to recite a specific prayer.
The case centred around a voluntary, non-denominational prayer authorized by the New York State Board of Regents in 1951. The prayer, known as the Regents' Prayer, was intended to be recited at the beginning of each school day. It read: "Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers, and our country. Amen." Students could opt out of participating with a parent's signature.
The non-denominational nature of the prayer was a key factor in the debate. The prayer was written to be inclusive and did not reference any specific religious beliefs or practices. Proponents of the prayer, including Justice Potter Stewart, argued that it did not establish an 'official religion' and that allowing those who wanted to say a prayer to do so was constitutional. They contended that the voluntary nature of the prayer and the option to opt out removed any constitutional concerns.
However, the Supreme Court majority disagreed, finding that the state-written prayer was inconsistent with the Establishment Clause. Justice Hugo Black wrote that the state had "adopted a practice wholly inconsistent with the Establishment Clause" and that it was not the government's role to compose official prayers for any group. The Court's decision affirmed the importance of separating church and state and recognized that even a non-denominational and voluntary prayer could be a form of government interference in religion.
The ruling in Engel v. Vitale set a precedent for later decisions that struck down other forms of prayer and religious activities in public schools, such as clergy-led prayers at graduation ceremonies and student-led prayers at school events. The case highlighted the complex balance between religious freedom and the separation of church and state in the US Constitution.
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It was an accepted practice at the time
In the case of Engel v. Vitale, the Supreme Court ruled that reciting government-written prayers in public schools was unconstitutional, violating the Establishment Clause of the First Amendment. This clause states that "Congress shall make no law respecting an establishment of religion," and was originally added to the Constitution to prevent the federal government from establishing a national religion and interfering with state religions.
The case was brought about when a group of parents in Hyde Park, New York, objected to the voluntary nondenominational prayer authorized by the state's Board of Regents in 1958-59. The prayer 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 the prayer, despite being voluntary, violated the Establishment Clause, as it constituted a government-sponsored religious activity.
One of the key arguments in defence of the prayer's constitutionality was that it was an "accepted practice" at the time the amendments were adopted. This reasoning was used by Bernard S. Meyer, who wrote the trial court opinion upholding the constitutionality of the prayer. Meyer's reasoning was based on the interpretation that the 'establishment' clause was not breached by non-compulsory prayers in public schools, as they were a common practice at the time.
However, this defence was not universally accepted. George Beldock, for instance, dissented in part from the trial court's judgment, disagreeing that the case should be decided based on morning prayer in public schools being an "accepted practice." Instead, he cited other cases, including Church of the Holy Trinity v. United States, to support his position.
The Supreme Court ultimately ruled in favour of the parents, with Justice Hugo Black writing that the state-sanctioned prayer was "wholly inconsistent with the Establishment Clause." Black emphasized the importance of separating church and state and argued that a school prayer, regardless of its specific wording, constituted a religious activity. This decision set a precedent for later rulings that struck down various forms of prayer and religious activities in schools, such as clergy-led prayers at graduation ceremonies and student-led prayers at football games.
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The Establishment Clause was not breached
The Establishment Clause, which is part of the First Amendment to the United States Constitution, states that "Congress shall make no law respecting an establishment of religion". This clause was originally added to the Constitution to prevent the federal government from establishing a national religion and to stop it from interfering with established religions in the states.
In the case of Engel v. Vitale, the Supreme Court ruled that the recitation of a government-written prayer in public schools was unconstitutional and violated the Establishment Clause. The Court held that the state of New York had "adopted a practice wholly inconsistent with the Establishment Clause" by encouraging the recitation of the Regents' Prayer in public schools. The Court's decision was based on the principle of separation of church and state, with Justice Hugo Black writing that it was "no part of the business of government to compose official prayers".
However, some argued that the Establishment Clause was not breached in this case. Justice Potter Stewart, the lone dissenter in the Supreme Court's decision, contended that the Establishment Clause was originally intended to prohibit the establishment of a state-sponsored church, not to prevent all types of government involvement with religion. He argued that the non-mandatory and non-denominational nature of the prayer, as well as the provision allowing students to opt-out, meant that it did not establish an 'official religion'.
The New York Court of Appeals and the trial court also agreed with this interpretation, ruling that the Regents' Prayer could be recited in public schools without violating the Establishment Clause as long as student participation was voluntary. They based their reasoning on the “accepted practice” of prayer in schools at the time the amendments were adopted. Additionally, nearly half of the state governors in the U.S. contributed to an amicus brief urging the Supreme Court to affirm the lower courts' decisions and uphold the constitutionality of the prayer.
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The prayer promoted the free exercise of religion
The case of Engel v. Vitale centred on the question of whether school-sponsored non-denominational prayer in public schools violated the Establishment Clause of the First Amendment. The prayer in question was proposed by the Board of Regents of New York in 1951 and was as follows:
> Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers and our country. Amen.
The prayer was voluntary, and students could opt out with a parent's signature. However, this opt-out provision was largely seen as insufficient in addressing the constitutional concerns raised.
One of the main arguments in defence of the prayer was that it promoted the free exercise of religion. The First Amendment, which states that "Congress shall make no law respecting an establishment of religion", was originally added to the Constitution to prevent the federal government from establishing a national religion and to stop it from interfering with religious establishments in the states. Over time, the amendment has been used to maintain separation between church and state in government spaces such as public schools.
In the context of Engel v. Vitale, proponents of the prayer argued that it did not establish a national religion or interfere with religious establishments. Instead, they contended that the voluntary nature of the prayer promoted religious freedom by allowing students to choose whether or not to participate. This perspective was reflected in the dissenting opinion of Justice Stewart, who wrote:
> I cannot see how an 'official religion' is established by letting those who want to say a prayer say it. On the contrary, I think to deny the wish of these school children to join in reciting this prayer is to deny them the opportunity of sharing in the spiritual heritage of our Nation.
The dissenting opinion emphasised the non-mandatory nature of the prayer and suggested that allowing willing students to participate in a brief, non-denominational prayer did not violate the Establishment Clause. This interpretation of the First Amendment highlights the complexity of balancing religious freedom and the separation of church and state in the context of public education.
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The prayer was not an 'official religion'
The prayer in question, known as the Regents' Prayer, was proposed by the Board of Regents of New York in 1951 as a non-denominational prayer to start the school day. It read: "Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers and our country. Amen." While the proposal was adopted by school boards, it was not mandatory, and students could opt out with a parent's signature.
In the case of Engel v. Vitale, the Supreme Court ruled that the recitation of this prayer in public schools was unconstitutional, violating the Establishment Clause of the First Amendment. The Court's decision centred on the idea that the government should not establish an official religion or compose official prayers.
The First Amendment states, "Congress shall make no law respecting an establishment of religion." This amendment was added to the Constitution to prevent the federal government from establishing a national religion and interfering with religious establishments in the states. Over time, it has been used to maintain separation between church and state in government spaces, including public schools.
In the dissenting opinion, Justice Stewart argued that the Establishment Clause was intended to prohibit the establishment of a state-sponsored church and not to prevent all government involvement with religion. He contended that the non-mandatory and non-denominational nature of the prayer, along with the option to opt out, removed any constitutional concerns.
While the prayer was not mandatory, the majority opinion recognised that children would likely participate in a teacher-led activity, regardless of their personal beliefs. This practical consideration was a factor in the Court's decision, as it highlighted the potential for government-sponsored prayer to influence students' religious practices.
In conclusion, the Supreme Court's ruling in Engel v. Vitale emphasised the importance of maintaining a separation between church and state, ensuring that official prayers or religious practices are not imposed on students in public schools, even when they are voluntary.
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Frequently asked questions
The case was about whether school-sponsored non-denominational prayer in public schools violates the Establishment Clause of the First Amendment.
The Establishment Clause states that "Congress shall make no law respecting an establishment of religion."
The First Amendment was originally added to the Constitution to prevent the federal government from establishing a national religion and to stop it from interfering with state religions.
The Supreme Court ruled that school-sponsored prayer violated the Establishment Clause of the First Amendment.
Justice Potter Stewart argued that the majority had "misapplied a great constitutional principle" and that an 'official religion' was not established by letting those who wanted to say a prayer. Justice Douglas contended that any type of public promotion of religion violates the Establishment Clause.
