Lamb's Chapel v. Center Moriches Union Free School District

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 on church 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 the idea 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 light dramatically 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 to Christian values. The films, titled, "A Father Looks Back," "Power in Parenting: The Young Child," "Power in Parenting: The Adolescent," "The Family Under Fire," "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 on the basis that the films were church-related. Their second application to use the 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.