Bd. of Educ. v. Grumet - 512 U.S. 687, 114 S. Ct. 2481 (1994)

Rule:

A proper respect for both the Free Exercise and the Establishment Clauses (U.S Const. amend. I) compels the state to pursue a course of neutrality toward religion, favoring neither one religion over others, nor religious adherents collectively over non-adherents.

Facts:

Members of the Satmar Hasidic sect, practitioners of a strict form of Judaism, incorporated the village of Kiryas Joel within the town of Monroe, New York, pursuant to a New York statute which gave almost any group of residents who satisfied various procedures the right to form a new village. Children in the village generally were educated in private religious schools, but the public school district within which the village fell provided special services to the village's handicapped children at an annex to one of the private schools. After this arrangement was ended in response to United States Supreme Court decisions holding unconstitutional a state's provision of supplemental educational services in sectarian schools, village children in need of such services were sent to public schools outside the village. However, parents of most of these children withdrew them from such schools on the ground that the children suffered panic, fear, and trauma in leaving their own community and being with people with different ways. In 1989, the New York state legislature passed a statute constituting the village as a separate public school district (1989 N. Y. Laws, ch. 748). The Governor of New York, in signing the bill into law, acknowledged that the village school district's residents were all members of the same religious sect. Although the village district had plenary legal authority over the elementary and secondary education of all school-aged children in the village, the district ran only one public school, which provided a special education program for handicapped children. An action challenging the statute's constitutionality was brought in the New York State Supreme Court for Albany County by the state school boards association and officers of the association against the state education department and various state officials. The state Supreme Court, in granting summary judgment to the association and its officers, concluded that the statute violated the Establishment of Religion Clause of the Federal Constitution's First Amendment. Both the intermediate appellate court and the New York Court of Appeals affirmed, ruling that Chapter 748's primary effect was impermissibly to advance religion. The United States Supreme Court granted certiorari.

Issue:

Did 1989 N.Y. Laws, ch. 748 violate the Establishment of Religion Clause of the Federal Constitution's First Amendment?

Answer:

Yes.

Conclusion:

The Court affirmed the judgment of the lower courts, and held that 1989 N.Y. Laws, ch. 748 departed from a course of neutrality toward religion by delegating the state's discretionary authority over public schools to a group defined by its character as a religious community, in a context that gave no assurance that government power had been or would be exercised neutrally. According to the Court, a state may not delegate its civic authority to a group chosen according to a religious criterion. Authority over public schools belonged to the state and cannot be delegated to a local school district defined by the state in order to grant political control to a religious group. The Court further held that the statute was not a constitutionally permissible accommodation of the sect members' religiously grounded preferences.