Board of Education of Kiryas Joel v. Grumet

The Court's ruling in Board of Education of Kiryas Joel v. Grumet failed to confirm or abandon the Lemon test of constitutionality under the Establishment Clause. Although it relied most heavily on Larkin in reaching its decision, the Court also did mention that Chapter 748 had a primary effect of advancing religion, in violation of one prong of the Lemon test. Perhaps the most significant portion of the Court's decision was that contributed by Justice O'Connor, which was used as a basis for rewriting of New York State Law Chapter 748 by Governor Cuomo and legislative leaders so as to make the statute equally applicable to any municipality. As of 1999, the constitutionality of this new statute had yet to be determined.