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Engel v Vitale Amendment
Before diving into the Engel v Vitale case, let's first talk about the Amendment the case centered around: The First Amendment.
The First Amendment States:
"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof, or abridging the freedom of speech, or of the press, or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances."
Establishment Clause
In Engel v Vitale, parties argued whether or not the Establishment Clause in the First Amendment was violated. The Establishment Clause refers to the part of the first Amendment that says the following:
"Congress shall make no law respecting an establishment of religion..."
This clause ensures that Congress doesn't establish a national religion. In other words, it banned state-sponsored religion. So, was the establishment clause violated or not? Let's find out!
Engel v Vitale Summary
In 1951, the New York Board of Regents decided to write a prayer and have students recite it as part of their "moral and spiritual training." The 22-word non-denominational prayer was voluntarily recited every morning. However, the children could opt out with parental permission or could simply refuse to partake by remaining silent or leaving the room.
In the creation of the prayer, the New York Board of Regents did not want to have issues with the First Amendment and the religious freedom clause, so they composed the following prayer:
"Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers, and our country,"
The regents' prayer was drafted by an interdenominational committee tasked with creating a nondenominational prayer.
While many schools in New York declined to have their students recite this prayer, the Hyde Park School Board went ahead with the prayer. As a result, a group of parents, including Steven Engel, represented by William Butler, appointed by the American Civil Liberties Union (ACLU), submitted a lawsuit against the School Board President William Vitale and the New York State Board of Regents, arguing that they were violating the Establishment Clause in the First Amendment by having the students recite the prayer and referring to God in the prayer.
The parents who took part in the lawsuit were of different religions. including Jewish, Unitarian, Agnostic, and Atheist.
Vitale and the School board argued that they had not infringed upon the First Amendment or the Establishment Clause. They argued that the students weren't forced to say the prayer and were free to leave the room, and therefore, the prayer did not infringe on their rights under the Establishment Clause. They also argued that while the First Amendment did ban a state religion, it did not restrict the growth of a religious state. They even claimed that since the prayer was nondenominational, they weren't infringing upon the free exercise clause in the First Amendment.
The free exercise clause protects a US citizen's right to practice their religion as they see fit so long as it does not run counter to public morals or compelling government interests.
The lower courts sided with Vitale and the School Board of Regents. Engel and the rest of the parents continued their fight and appealed the verdict to the United States Supreme Court. The Supreme Court accepted the case and heard Engel v Vitale in 1962.
FUN FACTThe case was called Engel v. Vitale, not because Engel was the leader but because his last name was the first alphabetically from the list of parents.
Figure 2. Supreme Court in 1962, Warren K. Leffler, CC-PD-Mark Wikimedia Commons
Engel v Vitale Ruling
The Supreme Court ruled in favor of Engel and the other parents in a 6-to-1 decision. The only dissenter on the court was Justice Stewart The justice that wrote the majority opinion was Justice Black. He stated that any religious activities sponsored by a public school were unconstitutional, especially since the Regents wrote the prayer themselves. Justice Black noted that praying for God's blessing was a religious activity. Therefore the state was imposing religion upon the students, going against the establishment clause. Justice Black also stated that although students could decline to say the prayer if the state backs it, they might feel pressured and feel compelled to pray anyway.
Justice Stewart, in his dissenting opinion, argued that there was no evidence showing that the state was establishing a religion when it was giving the children an option of not saying it.
FUN FACT
Justice Black did not use any cases as a precedent in his majority opinion in Engel v Vitale.
Engel v Vitale 1962
The ruling of Engel v. Vitale in 1962 caused public outrage. The Supreme Court's decision turned out to be a counter-majoritarian decision.
Counter-majoritarian Decision- A decision that goes against public opinion.
There seemed to be a misunderstanding as to what the judges had decided. Many, due to media outlets, were led to believe that the Judges outlawed prayer in school. However, that was untrue. The judges agreed that schools couldn't say prayers created by the state.
Due to Engel v. Vitale, the court received the most mail it had ever received regarding a case. In total, the court received over 5,000 letters that mainly opposed the decision. After the decision was made public, a Gallup poll was taken, and around 79 percent of Americans were unhappy with the court's decision.
The public reacted to this case due to a media frenzy. Still, many factors may have made the outcry worse, such as the Cold War and juvenile delinquency during the 50s. This led to many choosing to accept religious values, which just fueled the flame for the objection to the Engel v. Vitale ruling.
Twenty-two states submitted amicus curiae in favor of prayer in public schools. There were even multiple attempts by the legislative branch to create amendments to make prayer in public schools legal. However, none were successful.
Amicus Curiae - A Latin word that literally means "friend of the court." A brief from someone interested in an issue but not directly involved in the matter.
Engel v Vitale Significance
Engel v. Vitale was the first court case that dealt with reciting prayers at school. It was the first time that the Supreme Court prohibited public schools from sponsoring religious activities. It helped limit the scope of religion within public schools, helping create a separation between religion and state.
Engel v Vitale Impact
Engel v Vitale had a lasting impact on religion vs. state matters. It became a precedent for finding state-led prayer at public school events unconstitutional, as in the case of Abington School District v. Schempp and Santa Fe Independent School District v. Doe.
Abington School District v. Schempp
The Abington School District required that a verse of the bible be read every day before the pledge of allegiance. The Supreme Court ruled that it was unconstitutional because the government was endorsing a type of religion, going against the establishment clause.
Santa Fe Independent School District v. Doe
Students sued the Santa Fe Independent School district because, at football games, students would say a prayer over the loudspeakers. The court ruled that the recited prayer was school-sponsored because it was being played over the school's loudspeakers.
Engel v. Vitale - Key takeaways
- Engel v Vitale questioned whether reciting a prayer at school that was developed by the New York Board of Regents was constitutional based on the Establishment Clause of the First Amendment.
- Engel v Vitale ruled in favor of Vitale in the lower courts before reaching the Supreme Court in 1962.
- In a 6-1 ruling, the Supreme Court ruled in favor of Engel and the other parents, stating that in the New York Board of Regents, formulating a prayer for students to pray at school was infringing against the Establishment clause in the First Amendment.
- The Supreme court ruling caused a public outcry because the media made it seem that the verdict was abolishing prayer entirely from schools, which was not the case; it just couldn't be state-sponsored.
- The Engel v Vitale case set a precedent in cases such as Abington School District v. Schempp and Santa Fe Independent School District v. Doe.
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Frequently Asked Questions about Engel v Vitale
What is Engel v Vitale?
Engel v Vitale questioned whether a government-formulated prayer being recited at school was unconstitutional or not, according to the First Amendment.
What happened in Engel v Vitale?
- In a 6-1 ruling, the Supreme Court ruled in favor of Engel and the other parents, stating that in the New York Board of Reagents, formulating a prayer for students to pray at school was infringing against the Establishment clause in the First Amendment.
Who won Engel v Vitale?
The Supreme Court ruled in favor of Engel and the other parents.
Why is Engel v Vitale important?
Engel v Vitale is important because it was the first time that the Supreme Court prohibited public schools from sponsoring religious activities.
How did Engel v Vitale impact society?
Engel and Vitale impacted society by becoming a precedent for finding state-led prayer at public school events unconstitutional.
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