Case Brief Santa Fe Independent SD v. Jane Doe
Citation: Santa Fe Independent School District V. Doe, 530 U.S. 290 (2000)
Topic: School Prayer
Relief Sought: Students brought action to prevent school district from having prayer over the PA system atfootball games.
Issue(s): 1) Is a student praying over the PA system at sporting events (football) a violation of the establishment clause of the first amendment. 2) Does the fact that one student will give the invocation all year mean that an open forum has not been created? 3) Does the election of the student giving the speech mean all students’ rights are protected? 4) Is the school district endorsing a particular religion by sponsoring the prayer before the game?
Facts: Two Plaintiff students and their respective mothers brought the suit against the district for student led prayer at the school’s football games. One family was Catholic and one was Mormon. The two plaintiffs were allowed to remain anonymous to protect them. The school passed a policy where an elected student council chaplain would deliver a prayer before each game for the entire year. After the case was pending the school district changed the policy to allow the students to vote in favor of allowing prayer before the game and to elect which student would give the prayer. The new policy allowed prayer but didn’t permit it.
Finding of the Trial Court: For the school district as long as they were nonsectarian.
Finding of the Appellate Court: Court of Appeals overturned the court below and ruled in favor of the students. Both the U.S Court of Appeals for the Fifth Circuit and the U.S. Supreme Court said the practice was in violation of the establishment clause.
Reasoning: The student led prayer violated the establishment clause because it promoted a particular religion by allowing it before the games. The schools argued that it wasn’t a mandatory event but it was for members of the team, band and cheerleading squad. The fact that an election was held to determine whether the prayer should be allowed does not trump the establishment clause either because it still fails to protect the rights of the minority of students. It is therefore irrelevant that a majority of students wanted the prayer. The court relies on Lee v. Weisman as a prior guideline for prayer at school sanctioned events. Another reason for the prayer not to be allowed is because it was only one student giving the prayer and therefore an open forum was not created. Since it was not, the school was in fact sponsoring the prayer by having one student give it before each football game.