Santa Fe V. Doe Case Summary

The Santa Fe v. Doe case delineated the constitutionality of prayer and Christianity in America. The famous case that transformed how prayer in a public sphere is understood took place on March 28, 2000 and was argued before the U.S. Supreme Court reaching a verdict on June 18, 2000. The case was brought forward by a Mormon and a Christian family who believed that the Santa Fe High School practice an act which was a clear endorsement of a religion by the government as the school was a public school. it was supported by the school faculty.

Jay Sekluw the Chief Counsel of the American Center for Law and Justice (ACLJ) and Professor of law at Regent University of Law argued for petitioner Santa Fe School District. Sekluw argued before the Court that the

practice committed by the students of Santa Fe school were independent of the school’s values and were private acts committed by students individually. He put forth before the Supreme Court that the practice though being enacted by students in a public sphere were not meant to endorse any religion nor pressurize observers to participate in this act.
The ruling for the Santa Fe v. Doe case was in favor of Jane Doe. The court felt that the prayer held by the students explicitly manifested a religious act which took place on Governmental grounds. The Supreme Court stated that it did not support any religious denomination or religious practice and justified its ruling by the Establishment Clause. Religion in America is considered a private matter decided individually, and not meant to be pressured upon any individual either by the ruling authority or law and clearly evident in the Santa Fe v. Doe ruling.
Supreme Court Justice John Paul Stevens Delivered the Court’s judgment regarding the case based on the majority vote. The actions of the students were judged not individually rather as actions indirectly taken by the school. Despite the great majority in the ruling a dissent created by discontent Supreme Court Justices.
A dissent delivered by Chief Justice Rehniquist along with the support of both Justices Thomas and Scalia issued their disregard for the majority opinion which Justices Sandra O’connor, John Stevens, Anthony Kennedy, David Souter, Ruth Ginsburg and Stephen Breyer supported. The damaged Justed stated in their dissent that America is closely tied to a religion and that the judgement which is based on the Establishment Clause is complete absurdity as it disregards America’s moral and values. Rehniquist understood America as a nation that practices religious act and behaviors and beliefs in a ‘God.’ He believed that the Founders of the Nation had established America with a religious foundation and disregarding the Bill of Rights and America’s customs is unrighteous.
America protects and provides religious freedom to all of its citizens. Religion in America is an ideology practiced by its participants freely, and protected under the First Amendment and the Establishment Clause and Free Exercise Clause. The First Amendment clearly delineates the freedom of religion while the Free Exercise Clause protects not only an individual's right to religion but also their religious behavior. It is the first right given to all citizens of America, to allow each individual to practice and incorporate religion yet, the Supreme Court considers prayer, an unconstitutional act when done publicly.
The Supreme Court believed the prayer at Santa Fe High School before the football games was unconstitutional stating it to be an endorsement of religion by the government. The school’s participation in administering a student election to choose a student chaplain to pray was a clear violation of the Establishment Clause. The school allowed students to elect a student to deliver the prayer before football games and to broadcast the prayer during the beginning of the football a clear manifestation of the school’s involvement to the worship that took place. Despite citing the Establishment Clause as testimony to explain the logic of the court’s ruling, the U.S. Supreme Court neglected to consider the Free Exercise Clause for its ruling.
The Free Exercise Clause protects an individual's right to practice religion according to their free will. The ruling in the Santa Fe v. Doe can regard the government as a ruling body that infringed upon a group’s right to a religious practice. The prayer before the football game encouraged people to participate in a public act similar to the prayer held before inaugural addresses and governmental meetings. The Court remained single-minded on its ruling, reiterating that the prayer was broadcasted on governmental grounds and contradicts the idea of a non-governmental religion. The Court believed that the school indirectly encouraged the practice of prayer based on the majority of the student body and undermined the religious beliefs of the minorities attending school. The Santa Fe v. Doe ruling was similar to Lee v. Weisman case which was decided in 1992.
The ruling of the Santa Fe v.

Doe case was a reiteration by the Supreme Court on many cases involving prayer in school as evident in the Lee V. Weisman case. At the Nathan Bishop Middle School in Providence, Rhode Island the principal Robert Lee invited a rabbi as the commencement speaker however, the parent of middle schooler Deborah, Daniel Weisman challenged the principal’s act. The issue decided in the Lee v. Weisman was concerned about the legality of praying before audience at a graduation. In a 5 to 4 ruling the Supreme court considered the appointment of a Rabbi to speak and pray at a graduation ceremony unconstitutional. The court used the Establishment Clause as justification for its ruling, stating that the Rabbi’s prayer forced students to listen to a religious message which was a clear endorsement of a governmental religion. In both cases Santa Fe v. Doe and Lee v. Weisman the Court distanced itself from any religious prayer especially in a public school setting believing it to be contrary to the Establishment Clause. Despite the Supreme Court’s intolerance of prayer in school, the ruling for the Town of Greece v. Galloway revealed the Court’s acceptance for prayer held at governmental

meetings.
The Town of Greece v. Galloway case decided by the U.S. Supreme Court on May 4, 2014 clearly explained the Court’s contrast to school prayer and governmental prayer. In Greece, New York five members of the board that met monthly always began their town meetings with a prayer. The prayer was usually held by a Christian clergy, to which the respondent Susan Galloway felt was a clear discrimination of other religions based on the Establishment Clause. Galloway believed that the act committed before the board committee was a clear inclination made on the government’s behalf as it favored the Christian denomination over other religions. The Supreme Court handled this case differently than both the Santa Fe v. Doe case and the Lee v. Weisman case.
The Town of Greece v. Galloway case is a particularly recent case in which the Supreme Court clarifies the Establishment Clause as to justify its logic. The Court states that the prayer held before government meetings is permissible yet, when held at a public school setting it is unlawful and unacceptable. Legislative prayer is supposedly, written in the law and considered both valid and encourages participation with no disregard to other religions however, prayer at school disregards the religious behavior of other religions. The justification for the ruling of this case contrasts the ruling for the Santa Fe v. Doe case and Lee v. Weisman case. The same religious behavior exhibited at both the Greece meeting hall and Santa Fe High School differed only in their settings but the prayer before a governmental meeting was considered legitimate. The definition of religion, comprised of prayer and participation is better explained by scholars Clifford Geertz and Robert Bellah.
Clifford Geertz a famous anthropologist and scholar describes in his novel, “Religion as a Cultural System” the definition of religion. The symbol evident in all three cases is prayer, a symbol that leaves one with “long-lasting” emotions, and experience by which one can feel a spiritual connection with the divine. Considering Geertz definition, the “legislative prayer” exhibited by the Town of Greece v. Galloway is considered as much of a religious ritual as the “unconstitutional prayer” held before the football games at the Santa Fe High School. The Supreme Court manipulated the meaning of the Establishment Clause as to not directly favor a religious behavior at a public school setting but tolerate their religious behavior at a governmental meeting. The ruling for the Town of Greece v. Galloway case creates a civil-religion in America. Robert Bellah explains in his novel the civil-religion prevalent in America.
Robert Bellah, a well-renowned sociologist and educator at the University of California Berkeley explains the social religion in America. Bellah does not define a religion but rather draws attention to an existing religion in America. He describes the civil religion as not directly related to any denomination but rather a philosophy that establishes a civil society. This religion is a code of ethics, morals and nationalism that unites America.Bellah considers the American civil religion not only accepted by society but also practice by great majority of people. The orientation of individuals toward a higher allows prayer to be viewed as acceptable especially, if uniting a large group of people. According to Bellah’s civil religion, the ruling for the Town of Greece v. Galloway was fair as the act was a common form of behavior shared by a majority of Americans.
Bellah’s civil religion specifically established an order of ethics and moral standards based on the religion of a majority. He would consider the “legislative prayer” as defined by the Supreme Court in the Town of Greece case as ethical American behavior. Despite Bellah’s understanding of the American civil religion as an institution that governs the behavior of individuals, the prayer depicted in both the Santa Fe v. Doe case and the Lee v. Weisman case should not be dubbed as unlawful. The prayer at both Santa Fe High School and Nathan Bishop Middle School is as much of a religious act apart of the American civil religion by inasmuch, as the prayer held at the Town of Greece meeting hall.
Geertz and Bellah both consider religion to encompass rituals and symbols. Prayer is a ritual performed by participants of a religion. Both scholars, Geertz and Bellah indicate explicitly their understanding of religion but Bellah goes as far as to say that the American civil religion is normative, even despite it encompassing rituals and beliefs that are not shared by minority groups. All in all, prayer is by both Geerts and Bellah a ritual of religion. Bellah’s analysis of religion differs from Geertz, in that he considers America to manifest an American civil religion, that allows certain acts shared by a majority of Americans to be defined as legal, normative and acceptable. The majority of American citizens share a relationship of a monotheistic religion with a higher being and thus the rituals of Christianity are apparent and accepted in governmental settings.
Despite Bellah’s definition being a problematic one politically, favoring the beliefs and practices of a Christian religion, it is socially acceptable and seen normative as depicted in the court’s ruling for the Town of Greece v. Galloway case. In the ruling for the Town of Greece v. Galloway case the court indirectly favored and legalized Christian prayer in governmental settings as acceptable. The ruling in a way encourages governmental members to participate in such a ritual as to seek wisdom and act in humble ways just as one stands in the presence of a divine being. The prayer is a ritual that depicts one's humility from which the individual should execute his actions by for the nation. Prayer then as Geertz and Bellah describe it is a symbol but it is not only a religious behavior but also an outlet for governmental figures to seek wisdom. The use of such rituals which governs America’s civil society is to create a sense of nationalism in conjunction to good Christian morals yet, indirectly denouncing any governmental religious establishment.