Board of Education of Kiryas Joel Village School District v. Grumet
512 U.S. 687 (1994)
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Rule of Law:
A state statute that carves out a political subdivision and delegates governmental power on the basis of religious affiliation violates the Establishment Clause of the First Amendment. Such a law is not a permissible accommodation of religion but an impermissible fusion of governmental and religious functions.
Facts:
- The Satmar Hasidim, practitioners of a strict form of Judaism, established the village of Kiryas Joel in New York.
- The village boundaries were intentionally drawn during its incorporation to include only Satmar residents.
- Children in the village attended private religious schools, but handicapped children were entitled to publicly funded special education.
- Initially, the local Monroe-Woodbury Central School District provided these services at an annex inside the village.
- Following Supreme Court decisions in 1985 (Aguilar v. Felton), the district stopped on-site services, requiring the handicapped children to attend public schools outside the village.
- Satmar parents found that sending their children to secular schools outside their community was psychologically traumatic due to vast cultural and linguistic differences, and most withdrew their children from the public programs.
- In 1989, the New York Legislature passed a special statute, Chapter 748, creating a new public school district with boundaries identical to the village of Kiryas Joel, exclusively to serve these children.
Procedural Posture:
- Louis Grumet and others sued the New York State Education Department in the New York Supreme Court, a state trial court, arguing the statute creating the school district was unconstitutional.
- The Kiryas Joel Village School District was permitted to intervene as a defendant.
- The trial court granted summary judgment for the plaintiffs, finding the statute violated all three prongs of the Lemon test.
- The defendants (the School District) appealed to the New York Supreme Court, Appellate Division, an intermediate appellate court.
- The Appellate Division affirmed the trial court's decision, holding that the statute's primary effect was to advance religion.
- The School District appealed to the New York Court of Appeals, the state's highest court.
- The Court of Appeals affirmed on federal constitutional grounds, finding the statute created a 'symbolic union of church and State.'
- The Board of Education of the Kiryas Joel Village School District (petitioner) was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a state statute that creates a separate public school district with boundaries drawn deliberately to coincide with a village composed exclusively of members of a single religious sect violate the Establishment Clause of the First Amendment?
Opinions:
Majority - Justice Souter
Yes, the statute violates the Establishment Clause. A state may not delegate its civic authority to a group chosen according to a religious criterion. The statute effectively defines a political subdivision by a religious test, creating a forbidden fusion of governmental and religious functions. The law is not a neutral, generally applicable law but a special act that runs counter to the state's customary districting practices, thereby creating a preference for one religious group over others. This legislative favoritism fails the constitutional requirement of neutrality toward and among religions.
Concurring - Justice O'Connor
Yes, the statute violates the Establishment Clause because it singles out a particular religious group for favorable treatment. While the government may accommodate religious needs, it should do so through generally applicable legislation, not through a special act benefiting only one sect. This law appears to be a clear religious preference, as there is no guarantee that another similarly situated group would receive the same accommodation from the legislature. She also noted that the problem stemmed from the Court's earlier decision in Aguilar v. Felton, which should be reconsidered.
Concurring - Justice Kennedy
Yes, the statute is unconstitutional, but for the narrower reason that the government may not draw political or electoral lines on the basis of religion. The real vice of the school district is that New York created it through explicit religious gerrymandering. However, the majority's reasoning is flawed because a legislative accommodation for a particular religious group is not automatically invalid simply due to the risk that the legislature might not grant a similar accommodation to another group in the future.
Concurring - Justice Stevens
Yes, the statute violates the Establishment Clause. By creating a school district specifically intended to shield children from contact with those of 'different ways,' the state provided official support to cement the attachment of young adherents to a particular faith. This state action affirmatively supports a religious sect's interest in segregation, which is fairly characterized as establishing, rather than merely accommodating, religion.
Dissenting - Justice Scalia
No, the statute does not violate the Establishment Clause. The law had a legitimate secular purpose: to provide public, secular education to handicapped children in a culturally sensitive environment, solving a unique educational and emotional problem. The school district is a civil authority held by citizens who happen to share a religion, not by a church itself. The majority's holding misinterprets the Establishment Clause to prohibit a characteristically American accommodation of the cultural peculiarities of a tiny minority sect, turning religious toleration into an establishment of religion.
Analysis:
This decision reinforces the principle of government neutrality and clarifies the line between permissible religious accommodation and unconstitutional establishment. The Court established that while accommodations are allowed, they cannot take the form of delegating core governmental powers, like education, to a group defined by its religion. The ruling signals a strong judicial skepticism toward special, single-group legislation, suggesting that accommodations are safer from constitutional challenge when enacted through neutral, generally applicable laws. The various concurrences also highlight the Court's ongoing internal debate over the proper analytical framework for Establishment Clause cases, with several justices expressing dissatisfaction with the existing Lemon test.
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