Engel v. Vitale Abolished Public School Prayer

The ruling cited the Establishment Clause of the Constitution

Students holding hands and praying at their desks

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What authority, if any, does the U.S. government have when it comes to religious rituals such as prayers? The Engel v. Vitale Supreme Court decision of 1962 dealt with this very question.

The Supreme Court ruled 6 to 1 that it was unconstitutional for a government agency such as a school or government agents such as public school employees to require students to recite prayers.

Here's how this ultimately important church vs. state decision evolved and how it reached the Supreme Court.

Fast Facts: Engel v. Vitale

  • Case Argued: April 3, 1962
  • Decision Issued: June 25, 1962
  • Petitioner: Steven I. Engel, et al.
  • Respondent:  William J. Vitale Jr., et al.
  • Key Question: Does the recitation of a nondenominational prayer at the beginning of the school day violate the Establishment Clause of the First Amendment?
  • Majority Decision: Justices Earl Warren, Hugo Black, William O. Douglas, John Marshall Harlan, Tom Clark, and William Brennan
  • Dissenting: Justice Potter Stewart
  • Ruling: Even if the prayer is not nondenominational nor is participation mandatory, the state cannot sponsor prayer in public schools.

Origin of the Case

The New York State Board of Regents, which had supervisory power over New York public schools, began a program of “moral and spiritual training” in the schools that included a daily prayer. The regents themselves composed the prayer in what was intended to be a nondenominational format. Labeled the “To whom it may concern” prayer by one commentator, it stated:

"Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers and our Country."

But some parents objected, and the American Civil Liberties Union joined 10 of the parents in a suit against the Board of Education of New Hyde Park, New York. Amicus curiae (friend of the court) briefs supporting the lawsuit were filed by the American Ethical Union, the American Jewish Committee, and the Synagogue Council of America.

Both the state court and the New York Court of Appeals rejected the parents' efforts to block the prayer.

Who Were Engel and Vitale?

Richard Engel was one of the parents who objected to the prayer and filed the initial lawsuit. Engel said his name became part of the decision only because it came ahead of the other plaintiffs' names alphabetically.

He and the other parents said their children endured taunting at school because of the lawsuit and that he and other plaintiffs received threatening phone calls and letters while the suit made its way through the courts.

William J. Vitale Jr. was president of the board of education.

Supreme Court's Decision

In his majority opinion, Justice Hugo Black sided substantially with the arguments of the "separationists," who quoted heavily from Thomas Jefferson and made extensive use of his “wall of separation” metaphor. Particular emphasis was placed upon James Madison’s “Memorial and Remonstrance against Religious Assessments.”

The decision was 6-1 because Justices Felix Frankfurter and Byron White did not take part (Frankfurter had suffered a stroke). Justice Stewart Potter was the sole dissenting vote. 

According to Black's majority opinion, any prayer created by the government was akin to the English creation of the Book of Common Prayer. The Pilgrims came to America to avoid this type of relationship between government and organized religion. In Black's words, the prayer was “a practice wholly inconsistent with the Establishment Clause.”

Although the regents argued that there was no compulsion on students to recite the prayer, Black observed that:

"Neither the fact that the prayer may be denominationally neutral nor the fact that its observances on the part of students is voluntary can serve to free it from the limitations of the Establishment Clause."

Establishment Clause

The clause is the portion of the First Amendment to the U.S. Constitution that prohibits the establishment of religion by Congress.

In the Engel v. Vitale case, Black wrote that the Establishment Clause is violated regardless of whether there is any “showing of direct government compulsion ... whether those laws operate directly to coerce non-observing individuals or not.”

Black said the decision showed great respect for religion, not hostility:

"It is neither sacrilegious nor antireligious to say that each separate government in this country should stay out of the business of writing or sanctioning official prayers and leave that purely religious function to the people themselves and to those the people choose to look to for religious guidance."

Significance

This case was one of the first in a series of cases in the latter half of the 20th century in which a variety of religious activities sponsored by the government were found to violate the Establishment Clause. This was the first case that effectively prohibited the government from sponsoring or endorsing official prayer in schools.

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Cline, Austin. "Engel v. Vitale Abolished Public School Prayer." ThoughtCo, Dec. 6, 2021, thoughtco.com/engel-v-vitale-1962-249649. Cline, Austin. (2021, December 6). Engel v. Vitale Abolished Public School Prayer. Retrieved from https://www.thoughtco.com/engel-v-vitale-1962-249649 Cline, Austin. "Engel v. Vitale Abolished Public School Prayer." ThoughtCo. https://www.thoughtco.com/engel-v-vitale-1962-249649 (accessed March 19, 2024).