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Case Summary for Lamb's Chapel v. Center Moriches School District
Date Decided: June 7, 1993
Issue: Freedom of Religion/Freedom of Speech -- Whether a local school district that allows its facilities to be used for social and civic purposes may prevent a religious organization from using the facilities to show a movie that presents family issues from a religious perspective.
Vote: No, 9-0
Facts: The school district of Center Moriches, New York, adopted rules that permitted its facilities to be used for social, civic, and recreational purposes, but that prohibited any group from using the facilities for religious purposes. Lamb's Chapel, an evangelical church, applied for permission to show a six-part film series in one of the buildings. The series presented a religious perspective on family issues and child rearing. The school district denied the application, relying on the prohibition against using the facilities for religious purposes. Lamb's Chapel sued in federal court, but both the trial court and the Second Circuit Court of Appeals found in favor of the school district.
Legal Principles at Issue: A government is not obligated to make its non-public facilities available for use by the general public. Even when it does so, it may limit the purposes for which the facilities may be used. The government may not, however, deny access to the facilities based upon the viewpoint of the person who seeks access to them. Cornelius v. NAACP Legal Defense and Ed. Fund, 473 U.S. 788 (1985). A government may deny access to a religious group if allowing access would violate the First Amendment's prohibition against establishing a religion. One test for evaluating whether the Establishment Clause is being violated is set forth in Lemon v. Kurtzman, 403 U.S. 602 (1971) -- whether the challenged governmental action has a secular purpose, whether the action has the principal effect of advancing or inhibiting religion, and whether it fosters an excessive entanglement with religion. While never quite repudiated, this test has proven unpopular with many members of the Court.
Legal Basis for Decision: The Court rather easily concluded that the school district's denial of Lamb's Chapel's application was contrary to the holding in Cornelius. The Court found that the school district allowed its facilities to be used for discussions of family and child-rearing issues and that its denial of the application was based solely upon the religious perspective of the series. The Court held that the denial was based on the viewpoint of the speech and therefore violated the First Amendment. The Court, relying upon Lemon, also concluded that the district would not be endorsing religion by allowing the series to be shown.
This Case is Important Because: The Court again drew a careful line between neutrality towards religion and establishment of religion. The members of the Court, however, were divided as to the propriety of applying the Lemon test.
Quotable: "Like some ghoul in a late-night horror movie that repeatedly sits up in its grave and shuffles abroad, after being repeatedly killed and buried, Lemon stalks our Establishment Clause jurisprudence once again, frightening the little children and school attorneys of Center Moriches Union Free School District." -- Justice Scalia, concurring in judgment
Writing for the Majority: Justice White
Voting with the Majority: Chief Justice Rehnquist, Justices Blackmun, Stevens, O'Connor, and Souter (Justice Kennedy, concurring in part and concurring in judgment) (Justices Scalia and Thomas, concurring in judgment)
Writing for the Dissent: N/A
Voting with the Dissent: N/A
Not Voting: N/A
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