A Brief History of School Prayer

          In the United States today, the separation of Church and state is looked upon as normal and, in the eyes of many, unchangeable. However, the issues associated with allowing religious expression in schools are still very controversial. Indeed, the issues have not been stagnant ones throughout this nation’s history. The question of what and how much religious expression should be allowed in schools and what, if any, religious or moral values should be taught to students has been debated vigorously since before the 1950s.
          Although many people may not realize this, there is no actual clause in the Constitution specifically stating the doctrine of “separation of church and state.” Instead, there are two related clauses, one forbidding “any law respecting an establishment of religion” and the other protecting against any infringements on the “free exercise of religion” [1]. The current controversy has issued forth from the attempts of the Supreme Court to allow students and teachers their right to religious expression without promoting a specific religion over all others or making anyone uncomfortable.
          Before 1949, public schools were actually allowed to have religious education teachers, who would instruct the students in the Christian faith and moral values. In that year, the Court stated that public schools could no longer do this because it “breached the historical separation of church and state.” However, the Court did allow a “released time” program, which permitted students to leave school early in order to attend religious instruction given at their churches  [2]. By having the students leave school grounds to receive religious instruction, the Court believed that it had reached an acceptable compromise by preventing the violation of the establishment of religion in public schools but still allowing everyone’s religious freedom.
          Even though religious teaching was now banned from schools, religion itself was not. One of the more infamous occurrences of this was in New York State, where the board of regents allowed a bland, undenominational prayer appealing to an “Almighty God” to be read at the start of each school day [3]. A group of parents found this prayer to be offensive and brought a lawsuit against the board of regents, but the prayer continued, as the lower courts all ruled that, since the students were not compelled to join in, the recitation was constitutional. The parents still felt the prayer to be offensive, partly because of its discrimination against atheists and those who believed in more than one God. Eventually the lawsuit came before the Supreme Court in the form of the case Engel v. Vitale. On June 25, 1962 the Supreme Court declared the prayer to be unconstitutional, saying “by using its public address system to encourage recitation of the Regents’ prayer, the State of New York has adopted a practice wholly inconsistent with the Establishment Clause” [4].
          Other similar decisions followed this. On June 17, 1963, the Supreme Court decided the case of Abington School District v. Shemp. Mr. Shemp had challenged the Pennsylvania practice of starting each school day with readings from the Bible. Although parents were allowed to excuse their children from this reading, Mr. Shemp felt that this would also be detrimental to his children. He believed that it would expose his children to the ridicule and distrust of their teachers and fellow students and, during the height of the Cold War, be labeled as un-American. Another case which was incorporated into Abington v. Shemp was that of Murry v. Curlett. In this case, atheist Madalyn Murry challenged the Maryland practice of in school Bible readings on the basis that they were a threat to religious liberty by “placing a premium on belief as against non-belief” [5]. The Supreme Court struck down the laws in both states which allowed the Bible readings, stating that “It seems from a recognition of the teachings of history that powerful sects or groups might bring about a fusion of governmental and religious functions…this the Establishment Clause prohibits. And further reason for neutrality is found in the Free Exercise Clause” [6]. The Free Exercise Clause states that every individual is free to observe religion how he or she best sees fit, without compulsion of any kind from the government.
          These decisions did not mean that the debate was over. Nor did they even mean that schools across the country stopped mandatory Bible readings. While some religious agreed with the ruling in Abington School District v. Shemp, others did not. Some of its most vocal opponents were the Roman Catholic Church and many Southern Protestant denominations. In response to the decision, six states, Alabama, Arkansas, Delaware, Florida, Georgia, and Idaho, passed laws requiring religious services to be preformed in public schools. Governor William of Alabama even specifically instructed the State Board of Education to ignore the decision of the Supreme Court (Fenwick, pg 140). In many other states, Bible reading continued as a matter of tradition. However, the case did lead to a significant, and eventually complete, decline in Bible readings in public schools.
          The supporters of school prayer organized and called for a constitutional amendment to legalize it. The most successful resolution was the one introduced in Congress in 1963 by Representative Frank J. Becker of New York. In part, it read:

Nothing in this Constitution shall be deemed to prohibit the offering, reading from, or listening to prayers or biblical Scriptures, if participation therein is on a voluntary basis, in any governmental or public school, institution, or place [7].

Although there were many people who testified on behalf of the proposal, it never got out of the House Judiciary Committee. The debate ended in the government for approximately twenty years, even though it continued to be hotly contested on local and personal levels.
          Then, in 1980 Ronald Regan was elected President of the United States. He brought the school prayer debate back to national attention when he called for a full Senate debate of the issue in 1984. The debate was over the President’s proposed amendment to the Constitution, which would allow for group prayer in American schools. On March 20, 1984, the amendment was voted on. Although the many senators voted for it, the final vote was fifty-six to forty-four in favor, the two-thirds majority required for the passage of the amendment was not reached [8].
          Although the media attention on the school prayer debate has died down, the debate still continues. There is still controversy over issues as diverse as whether or not singing Christmas carols with religious themes in schools constitutes a violation of the separation of church and state and whether teaching the theory of evolution constitutes discrimination against those who believe that God created humanity specifically. Other issues grouped in with the school prayer debate even include the question of whether or not the phrase “One nation under God” should be taken out of the Pledge of Allegiance and whether, by taking all religious expression out of schools, the government is actually supporting secular humanism above other religious ideas. The question “Is it even possible to remove all religious allusions from schools?” has also risen. A more important one may be, even if it is possible, is that something the government should do?

Continue on to "The Dark Side of the Classroom"

1 O'Neil, Robert M. Classrooms in the Crossfire: The Rights and Interests of Students, Parents, Teachers, Administrators, Librarians, and the Community. Bloomington: Indiana University Press, 1981, pg. 73.

2 O'Neil, Robert M. Classrooms in the Crossfire: The Rights and Interests of Students, Parents, Teachers, Administrators, Librarians, and the Community. Bloomington: Indiana University Press, 1981, pg. 74.

3 Fenwick, Linda Beck. Should the Children Pray?. Waco, Texas: Baylor University Press, 1989, pg 130.

4 Engel v. Vitale. No. 370 U.S. 421. Supreme Court of the U.S. 25 June 1962. FindLaw.  19 Oct. 2004. < http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=370&invol=421 >

5 American Atheists. 2004. American Atheists Inc. 20 Oct. 2004. < http://www.atheists.org/ >

6 Abington School District v. Schempp.  No. 374 U.S. 203.  Supreme Court of the U.S.  17 June 1963.  FindLaw.  19 Oct. 2004. < http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=374&invol=203 >

7 Fenwick, Linda Beck. Should the Children Pray?. Waco, Texas: Baylor University Press, 1989, pg 130.

8 Fenwick, Linda Beck. Should the Children Pray?. Waco, Texas: Baylor University Press, 1989, pg 130.