Engel v. Vitale

by:

Following is the case brief for Engel v. Vitale, United States Supreme Court,(1962)

Case summary for Engel v. Vitale:

  • Vitale, in his official capacity, directed teachers to start off each day with a non-denominational prayer.
  • Engel brought suit claiming such a practice violated the First Amendment’s Establishment Clause and petitioned to the Supreme Court.
  • The Court held that the requirement violated the First Amendment’s Establishment despite the prayer being non-denominational and students having the option to leave during the time of prayer.

Engel v. Vitale Case Brief

Statement of the facts:

Vitale was the head of the Board of Education of Union Free School District No. 9 in New York. He directed each teacher to start off each school day with a prayer. As a response, Engel filed suit in state court claiming the prayer requirement violated the First Amendment’s Establishment Clause.

Procedural History:

The lower court upheld the prayer as constitutional. Engel petitioned to the Supreme Court of the United States and the Court granted certiorari.

Rule of Law or Legal Principle Applied:

State officials may not compel official state prayer, even when denominationally neutral and students have the option of remaining silent or being excused, under the First Amendment’s Establishment Clause.

Issue and Holding:

Can the state compel official prayer under the First Amendment’s Establishment Clause? No.

Judgment:

The Supreme Court reversed the lower court’s decision.

Reasoning:

The state has adopted a practice inconsistent with the First Amendment by using its school system to encourage recitation of prayer. Since the prayer is a religious activity, it is unconstitutional for Vitale in his capacity as a state official to compose and require prayer to be recited by students.

The practice of establishing governmentally composed prayer was one of the many reasons the early colonists left England to seek religious freedom. The Constitution is sensitive to preventing action which establishes a religion.  Whether or not the prayer is non-denominational and providing students the opportunity to leave the room does not matter as continuing such practice ignores constitutional defects.

The prayer is unconstitutional and the Establishment Clause of the First Amendment prevents the school’s actions.

Concurring or Dissenting opinion:

Concurring (Douglas):

The state’s prayer breaks tradition and cannot be imposed without violated the Constitution. In addition, the state should not permit financial aid to go to religious school even if for a non-religious purpose.

Dissenting (Stewart):

Since the prayer is voluntary, brief and non-denominational, allowing recitation has nothing to do with Establishing Religion.  The state’s prayer is an act which follows the deeply entrenched and highly cherished spiritual traditions of America and should be upheld.

Significance:

Engel v. Vitale as a landmark case prohibits a school from requiring prayer, even though non-denominational, as it violates the Establishment Clause of the First Amendment.

Student Resources:

http://www.pbs.org/jefferson/enlight/prayer.htm
https://www.law.cornell.edu/supremecourt/text/370/421