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Wallace v. Jeffree, 472 US 38 (1985)
Ishmael Jeffree, a resident of Mobile County, Alabama, filed an action on behalf of his minor children against the governor, school board and other public officials (Appellants), seeking an injunction restraining appellants from maintaining or allowing regular prayer services in the public schools. The father alleged that his two children were subjected to various acts of religious indoctrination during the school year and that appellants refused to stop the services. The action was later certified as a class action. At trial, appellants relied on three statutes enacted to allow voluntary prayer in the schools. The district court dismissed the father's claim, concluding that the Establishment Clause of U.S. Const. amend. I did not bar the states from establishing a religion. The United States District Court found that the statute was intended to encourage religious activity, but held that it was constitutional because a state has the power to establish a state religion if it chooses to do so; accordingly the district court dismissed the complaint. The United States Court of Appeals reversed, holding that such statute, though permissive in form, was nevertheless state involvement respecting an establishment of religion and was thus unconstitutional. Subsequently, appellants challenged the decision of the appellate court.
Was the Alabama state statute unconstitutional.
Yes. On appeal, the Supreme Court of the United States held that Ala. Code § 16-1-20.1 is a law respecting the establishment of religion and thus violates the First Amendment. The Court noted that one of the well-established criteria for determining the constitutionality of a statute under the Establishment Clause is that the statute must have a secular legislative purpose. According to the Court, the First Amendment requires that a statute must be invalidated if it is entirely motivated by a purpose to advance religion. In the case at bar, it has been established that § 16-1-20.1's purpose was to endorse religion. Furthermore, the Court held that the enactment of the statute was not motivated by any clearly secular purpose. The Court concluded that the State's endorsement, by enactment of § 16-1-20.1, of prayer activities at the beginning of each school day, is not consistent with the established principle that the government must pursue a course of complete neutrality toward religion.