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Board of Education of Kiryas Joel Village School v. Grumet (1989)

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Background Information

In 1989, the New York created new boundaries for a school district in order to accomodate the wishes of the residents of the village of Kiryas Joel. This area was overwhelmingly occupied by people who practiced Satmar Hasidim, a particularly strict form of Orthodox Judaism. Although they wanted to continue sending their children to free public schools, the parents also wanted their children to be segregated away from the children of non-Hasidic families. The only way to ensure was to create a special school district that was dominated by Hasidic neighborhoods.

A group of taxpayers sued, arguing that the creation of this school district was a furtherance of religion. According to them, the government was not permitted to go to such lengths to accommodate the religious beliefs of one group, essentially using government funds to support and maintain their status.

Court Decision

In a 6-3 decision written by Justice Souter, the Supreme Court found that the boundary was indeed unconstitutional because it was drawn to include only those people who lived in the area occupied by the members of a particular religious sect; therefore, it was thus a deliberate attempt to aid a particular religious group.

The majority opinion argued that the boundaries drawn by the legislature violated the Establishment Clause because the boundaries created a "fusion" of government and religious objectives. Quoting from the earlier decision in Larkin v. Grendel's Den, Inc.:

That individuals who happen to be religious may hold public office does not mean that a state may deliberately delegate discretionary power to an individual, institution, or community on the ground of religious identity.

The area's deliberate religious make-up was the main, if not the only, criteria in how the boundaries were drawn - and that meant that te boundary was not drawn in a neutral manner. Thus, it was inexcapable that the State was using its resources to assist the practitioners of the Satmar faith.

Petitioners' proposed accommodation singles out a particular religious sect for special treatment, and whatever the limits of permissible legislative accommodations may be, ...it is clear that neutrality as among religions must be honored.

Significance

This decision prohibits state and local governments from using religion as a standard for reaching decisions or making laws because doing so would violate their requirement to remain neutral in religious matters. The government isn't permitted to give any one religion or religious group special considerations or authority in making decisions which fall under governmental control

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