Petitioner
Lamb's Chapel, et al.
Respondent
Center Moriches Union Free School District, et al.
Petitioner's Claim
That the Center Moriches Union Free School District violated the First Amendment rights of the Lamb's Chapel by not allowing them to use the school facilities for the showing of a religious-based film series on family values.
Chief Lawyer for Petitioner
Jay Alan Sekulow
Chief Lawyer for Respondent
John W. Hoefling
Justices for the Court
Harry A. Blackmun, Anthony M. Kennedy, Sandra Day O'Connor, William H. Rehnquist, Antonin Scalia, David H. Souter, John Paul Stevens, Clarence Thomas, Byron R. White (writing for the Court)
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
7 June 1993
Decision
Overturned the trial court and appeal's court decisions by stating that the claim by Lamb's Chapel alleging that they had been discriminated against on basis of religion was accurate.
Significance
By ruling in favor of the Lamb's Chapel, the Court sent a firm message regarding the role of "content" in First Amendment issues as well as taking what some viewed as a conservative stand on the freedom of religion.
In 1971 the Supreme Court, in Lemon v. Kurtzman, issued a standard onchurch and state relations that held government programs to three regulations. The programs: (1) had to have a secular (or nonreligious) purpose, (2) could not "advance or inhibit" religious practice, and (3) could not "lead to excessive governments entanglements in religion." This ruling has been used since to determine whether or not the right to free speech should come before theidea of the separation of church and state in the United States.
Over the years, this so-called Lemon Test has been called into service in many additional cases, but one that brought the controversy of the test to lightdramatically was heard in 1993. The case revolved around the fact that New York State law allowed school districts to regulate the use of public school buildings after hours. The Center Moriches school district regularly allowed groups such as the Girl Scouts and the local Parent-Teacher Association to meet in its school buildings but decided to turn down any requests from religious organizations.
In 1988, John Steigerwald, the pastor of Lamb's Chapel, an evangelical Christian church in Long Island requested use of the school space. He wanted to host a six-part film series that would feature Dr. James Dobson, the president of the group Focus on Family. The school district asked for more information on the program and they were provided a pamphlet by Steigerwald, which included a description of Dobson as a licensed psychologist, author, and radio commentator. The brochure went on to say that Dr. Dobson's belief was that the media's influence on the American family could only be countered by a return toChristian values. The films, titled, "A Father Looks Back," "Power in Parenting: The Young Child," "Power in Parenting: The Adolescent," "The Family UnderFire," "Overcoming a Painful Childhood," and "The Heritage," focused on the"civil war of values" that Dr. Dobson felt was being waged in this country and Dr. Dobson's belief that a Christian perspective could strengthen the family.
The request by Lamb's Chapel to use the school facilities was turned down onthe basis that the films were church-related. Their second application to usethe space to show the films, which were described this time as "family-oriented movie[s]--from a Christian Perspective," was also turned down for the same reasons. During this time, the school district did allow, however, a New Age religious group called the "Mind Center" to sponsor a lecture series titled"Psychology and the Unknown," which was based on parapsychology and the unconscious mind. When asked by the district whether this was a religious series,its creator responded, "It was all science." This prompted the church to file suit in the district court. They asserted that by turning their request down, the school system was in violation of the Freedom of Speech and Assembly Clauses, the Free Exercise Clause, and the Establishment Clause of the First Amendment, as well as the Equal Protection Clause of the Fourteenth Amendment.
Was the School District Discriminatory?
When the church brought the case to the district court, it alleged that the school district had broken state law by discriminating against them on the basis of religion and restricting their right to free speech--two actions not allowed to be taken by a public institution. The court, however, ruled in favorof the district, affirming that the school facilities constituted a "limitedpublic forum," that the laws that allowed usage of school facilities did notinclude "religious worship or instruction," and that the church had admittedthat the films were to promote religious ideas, which, as a public institution, the district had no responsibility to do. It further ruled that if the school district had at any time granted space to other groups for religious purposes the church would have a case. Since the district had categorically disallowed all religious requests, the denial was within their rights.
The church appealed the decision to the court of appeals which upheld the ruling "in all respects." The court found that school property was not a traditional public forum when school was not in session and therefore it is subjectto rules for public property only for "specified uses."
Federal Court
Following this ruling, Lamb's Church proceeded to take the case to the Supreme Court. In a unanimous decision, the rulings of the lower courts were overturned. In essence, the Court ruled that the district did violate the chapel'sfreedom of speech by refusing their request to show movies on their propertysolely because the movies had a religious theme. It also stated that grantingpermission to the chapel would not have constituted the district's endorsement of the films since the films would not be sponsored by the school during school hours or closed to the general public. The district acted in violationof the Chapel's First Amendment rights. This was the Supreme Court's main reason for overturning the decisions of the lower courts.
Justice White wrote
In making their determination, the Court invoked the somewhat controversial Lemon Test. Even justices who agreed that the district was in error, were notcomfortable with the strictness of the Lemon Test. Justice Scalia wrote
Right-wing Christian groups perceived the decision as a major victory. TheChristian Science Monitor quoted Michael McConnell from the University of Chicago, whom they called "an expert on church-state relations," as saying"I don't think people realize how common it is for religious speakers to be suppressed in public schools. This decision says public spaces will not be treated as religion-free zones."
Still, the importance of the idea of separation of church and state was not overlooked in this ruling, as the Court drew fine lines between when and wherethe freedom of religious speech crosses the bounds of civic responsibility.
Related Cases
Lamb's Chapel, et al.
Respondent
Center Moriches Union Free School District, et al.
Petitioner's Claim
That the Center Moriches Union Free School District violated the First Amendment rights of the Lamb's Chapel by not allowing them to use the school facilities for the showing of a religious-based film series on family values.
Chief Lawyer for Petitioner
Jay Alan Sekulow
Chief Lawyer for Respondent
John W. Hoefling
Justices for the Court
Harry A. Blackmun, Anthony M. Kennedy, Sandra Day O'Connor, William H. Rehnquist, Antonin Scalia, David H. Souter, John Paul Stevens, Clarence Thomas, Byron R. White (writing for the Court)
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
7 June 1993
Decision
Overturned the trial court and appeal's court decisions by stating that the claim by Lamb's Chapel alleging that they had been discriminated against on basis of religion was accurate.
Significance
By ruling in favor of the Lamb's Chapel, the Court sent a firm message regarding the role of "content" in First Amendment issues as well as taking what some viewed as a conservative stand on the freedom of religion.
In 1971 the Supreme Court, in Lemon v. Kurtzman, issued a standard onchurch and state relations that held government programs to three regulations. The programs: (1) had to have a secular (or nonreligious) purpose, (2) could not "advance or inhibit" religious practice, and (3) could not "lead to excessive governments entanglements in religion." This ruling has been used since to determine whether or not the right to free speech should come before theidea of the separation of church and state in the United States.
Over the years, this so-called Lemon Test has been called into service in many additional cases, but one that brought the controversy of the test to lightdramatically was heard in 1993. The case revolved around the fact that New York State law allowed school districts to regulate the use of public school buildings after hours. The Center Moriches school district regularly allowed groups such as the Girl Scouts and the local Parent-Teacher Association to meet in its school buildings but decided to turn down any requests from religious organizations.
In 1988, John Steigerwald, the pastor of Lamb's Chapel, an evangelical Christian church in Long Island requested use of the school space. He wanted to host a six-part film series that would feature Dr. James Dobson, the president of the group Focus on Family. The school district asked for more information on the program and they were provided a pamphlet by Steigerwald, which included a description of Dobson as a licensed psychologist, author, and radio commentator. The brochure went on to say that Dr. Dobson's belief was that the media's influence on the American family could only be countered by a return toChristian values. The films, titled, "A Father Looks Back," "Power in Parenting: The Young Child," "Power in Parenting: The Adolescent," "The Family UnderFire," "Overcoming a Painful Childhood," and "The Heritage," focused on the"civil war of values" that Dr. Dobson felt was being waged in this country and Dr. Dobson's belief that a Christian perspective could strengthen the family.
The request by Lamb's Chapel to use the school facilities was turned down onthe basis that the films were church-related. Their second application to usethe space to show the films, which were described this time as "family-oriented movie[s]--from a Christian Perspective," was also turned down for the same reasons. During this time, the school district did allow, however, a New Age religious group called the "Mind Center" to sponsor a lecture series titled"Psychology and the Unknown," which was based on parapsychology and the unconscious mind. When asked by the district whether this was a religious series,its creator responded, "It was all science." This prompted the church to file suit in the district court. They asserted that by turning their request down, the school system was in violation of the Freedom of Speech and Assembly Clauses, the Free Exercise Clause, and the Establishment Clause of the First Amendment, as well as the Equal Protection Clause of the Fourteenth Amendment.
Was the School District Discriminatory?
When the church brought the case to the district court, it alleged that the school district had broken state law by discriminating against them on the basis of religion and restricting their right to free speech--two actions not allowed to be taken by a public institution. The court, however, ruled in favorof the district, affirming that the school facilities constituted a "limitedpublic forum," that the laws that allowed usage of school facilities did notinclude "religious worship or instruction," and that the church had admittedthat the films were to promote religious ideas, which, as a public institution, the district had no responsibility to do. It further ruled that if the school district had at any time granted space to other groups for religious purposes the church would have a case. Since the district had categorically disallowed all religious requests, the denial was within their rights.
The church appealed the decision to the court of appeals which upheld the ruling "in all respects." The court found that school property was not a traditional public forum when school was not in session and therefore it is subjectto rules for public property only for "specified uses."
Federal Court
Following this ruling, Lamb's Church proceeded to take the case to the Supreme Court. In a unanimous decision, the rulings of the lower courts were overturned. In essence, the Court ruled that the district did violate the chapel'sfreedom of speech by refusing their request to show movies on their propertysolely because the movies had a religious theme. It also stated that grantingpermission to the chapel would not have constituted the district's endorsement of the films since the films would not be sponsored by the school during school hours or closed to the general public. The district acted in violationof the Chapel's First Amendment rights. This was the Supreme Court's main reason for overturning the decisions of the lower courts.
Justice White wrote
. . . although a speaker may be excluded from a nonpublic forum if he wishes to address a topic not encompassed within the purpose of the forum . . . or if he is not a member of the class of speakers for whose special benefit the forum was created . . . , the government violates the First Amendment when it denies access to a speaker solely to suppress the point of view he espouses on an otherwise includible subject
In making their determination, the Court invoked the somewhat controversial Lemon Test. Even justices who agreed that the district was in error, were notcomfortable with the strictness of the Lemon Test. Justice Scalia wrote
Like some ghoul in a late-night horror movie that repeatedly sits up in its grave and shuffles abroad, after being repeatedly killed and buried, Lemon stalks our Establishment Clause jurisprudence once again, frightening thelittle children and school attorneys of Center Moriches Union Free School District.
Right-wing Christian groups perceived the decision as a major victory. TheChristian Science Monitor quoted Michael McConnell from the University of Chicago, whom they called "an expert on church-state relations," as saying"I don't think people realize how common it is for religious speakers to be suppressed in public schools. This decision says public spaces will not be treated as religion-free zones."
Still, the importance of the idea of separation of church and state was not overlooked in this ruling, as the Court drew fine lines between when and wherethe freedom of religious speech crosses the bounds of civic responsibility.
Related Cases
- Lemon v. Kurtzman, 411 U.S. 192 (1973).
- Bronx Household of Faith v. Community School District No. 10, 127F.3d 207 (1997).
- The Good News Club v. Milford Center School, 21 F.Supp.2d 147 (1998).
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