Ahlquist v. City of Cranston

840 F. Supp. 2d 507 (D.R.I. 2012)



To determine whether or not a plaintiff has standing, courts employ a three-part test, derived directly from the U.S. Supreme Court's jurisprudence. A plaintiff must have suffered 1) an injury in fact; 2) which is caused by the offending conduct; and 3) which is capable of being redressed by a favorable court decision.


Plaintiff, an avowed Atheist, is an eleventh grader at Cranston High School West, a public high school. At the said school, a large Christian prayer mural decorated the walls of the auditorium. According to the plaintiff, the prayer mural made her feel “excluded, ostracized and devalued.” Plaintiff parent, on behalf of his minor child, instituted a Motion for a Permanent Injunction, demanding that Defendants remove or alter the Christian prayer, and in effect, asking for the removal of religious references from government. Defendants, who have refused to alter or remove the prayer, argue that Plaintiff does not have the requisite standing to bring her complaint. 


Does the plaintiff have standing to bring her complaint before the Court, and if she does, can the action prayed for be granted?




According to the Supreme Court, the status as a student enrolled at Cranston West is sufficient to confer standing to the Plaintiff in a dispute about a prayer displayed at her school. Furthermore, Plaintiff has stated that the presence of a Christian prayer on the wall of her school has made her feel ostracized and out of place. The Court opined that while the plaintiff’s injuries might be characterized as abstract, those injuries are consistent with the injuries complained of by other plaintiffs in Establishment Clause litigation. Establishing the plaintiff’s standing to bring the suit, the Court ruled that the plaintiff is entitled to the immediate removal of a prayer mural from the auditorium. The Court posited that the mural violated the First Amendment Establishment Clause since it did not have a clearly secular purpose, and it advanced a particular religion.

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