Law School Case Brief
Lynch v. Donnelly - 465 U.S. 668, 104 S. Ct. 1355 (1984)
The United States Constitution does not require complete separation of church and state; it affirmatively mandates accommodation, not merely tolerance, of all religions, and forbids hostility toward any. The Establishment Clause of the First Amendment does not prohibit a municipality from including a creche, or Nativity scene, in its annual Christmas display.
The city of Pawtucket, Rhole Island would annually erect a Christmas display in a park owned by a nonprofit organization and located in the heart of the city's shopping district. The display would include a Santa Claus house, a Christmas tree, and a banner that reads "SEASONS GREETINGS," a crèche or Nativity scene, which has been part of this annual display for 40 years or more. Respondents, city residents, the American Civil Liberties Union (ACLU), and ACLU members, brought an action in Federal District Court, challenging the inclusion of the crèche in the display on the ground that it violated the Establishment Clause of the First Amendment, as made applicable to the states by the Fourteenth Amendment. The District Court upheld the challenge and permanently enjoined the city from including the crèche in the display. The Court of Appeals affirmed.
In including a crèche or Nativity scene in its annual Christmas display, did the city of Pawtucket violate the Establishment Clause of the First Amendment?
On a writ of certiorari, the Supreme Court of the United States held that notwithstanding the religious significance of the crèche, Pawtucket has not violated the Establishment Clause. According to the Court, the display of the crèche was no more an advancement or endorsement of religion than the congressional and executive recognition of the origins of Christmas itself as "Christ's Mass," or the exhibition of literally hundreds of religious paintings in governmentally supported museums. The Court ruled that the city had a secular purpose (i.e., the celebration of Christmas) for including the crèche, and concluded that the city had not impermissibly advanced religion, and including the crèche had not created excessive entanglement between religion and government. The Court reversed the permanent injunction against displaying the crèche.
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