Wallace v. Jaffree – Case Brief Summary

Summary of Wallace v. Jaffree, 427 U.S. 38, 105 S. Ct. 2479, 86 L. Ed. 2d 29 (1985).

Facts

This case involved a dispute over Alabama statutes that by stages allowed voluntary prayer lead by public school teachers. The District Court found nothing wrong with the first statute that called for a one minute period of silence for meditation in all public schools. It then found the second and third statutes unconstitutional. These statutes sanctioned voluntary prayer and permitted teachers to lead willing students in a prescribed prayer to Almighty God…the Creator and Supreme Judge of the world. The Court of Appeals affirmed and the Supreme Court granted certiorari.

Issue

Does the First Amendment require that a statute be invalidated if it is entirely motivated by a purpose to advance religion?

Holding and Rule (Stevens)

Yes. The First Amendment requires that a statute be invalidated if it is entirely motivated by a purpose to advance religion.

From the legislative record it was clear that this was merely passed in an effort to return voluntary prayer to the public schools. The legislative intent to return prayer to public schools is quite different from merely protecting every student’s right to engage in voluntary prayer during an appropriate moment of silence.

Disposition

The judgment of the Court of Appeals is affirmed.

Dissent (Burger)

To suggest that a moment of silence in a statute that includes the word prayer unconstitutionally endorses religion, while one that simply provides for a moment of silence does not, manifests hostility toward religion which is as much forbidden as is an official establishment of religion.

Dissent (White)

If a student asks if he can pray during the moment of silence, it is difficult to believe that the teacher could not answer in the affirmative.

Dissent (Rehnquist)

The Establishment Clause has been expressly freighted with Jefferson’s misleading metaphor for nearly forty years. Jefferson was in France when the Bill of Rights was passed and his letter to the Danbury Baptist Association was a short note of courtesy. The intent as expressed by Madison was against the establishment of a ‘national’ religion and not the divorce and barrier actions that have been interpreted under modern constitutional law.

See Silkwood v. Kerr-McGee Corp. for a constitutional law case brief in which the Supreme Court addressed the legislative intent of Congress regarding the Price-Anderson Act. The Court concluded that the Act did not preclude the states from providing remedies to victims of radiation exposure in nuclear power plants.


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