Freedom From Religion v. Chino Valley Uni. Sch. Dist.
896 F.3d 1132 (2018)
Rule of Law:
A public school board's policy of opening its meetings with religious prayer violates the Establishment Clause of the First Amendment when students are present and involved, as this practice falls outside the historical legislative prayer exception and fails to serve a secular purpose under the Lemon test.
Facts:
- The Chino Valley Unified School District Board of Education (the Board) holds regular public meetings to govern the school district.
- Since at least 2010, the Board has included a prayer as part of its meetings.
- Board meetings frequently feature student performances, presentations, and award ceremonies (called a 'student showcase' and 'student recognition'), involving students from elementary through high school.
- A student representative serves as a member of the Board, participates in open sessions, and represents student interests.
- In October 2013, the Board adopted a formal policy permitting a religious invocation at the start of the open session of each meeting, typically delivered by clergy from a pre-approved list.
- During meetings, several Board members, including James Na and Andrew Cruz, frequently made explicitly Christian statements, read Bible verses, and proselytized to the audience.
- For example, Board member Andrew Cruz stated the Board's goal was 'under God, Jesus Christ,' and then-Board President James Na 'urged everyone who does not know Jesus Christ to go and find Him.'
- These prayers and religious statements occurred in the presence of students who were there to receive awards or participate in the meeting.
Procedural Posture:
- The Freedom From Religion Foundation, along with parents and students (Plaintiffs), sued the Chino Valley Unified School District Board of Education and its members (Defendants) in the U.S. District Court for the Central District of California.
- Plaintiffs alleged the Board's policies and customs of prayer and proselytizing at meetings violated the U.S. Constitution's Establishment Clause and other laws.
- The district court granted partial summary judgment in favor of the Plaintiffs on the Establishment Clause claim.
- The district court issued a declaratory judgment stating the prayer policy violated the Establishment Clause and issued an injunction prohibiting Board members from conducting or endorsing school-sponsored prayer at meetings.
- The Board of Education and its members (Defendants-Appellants) appealed the district court's decision to the United States Court of Appeals for the Ninth Circuit.
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Issue:
Does a public school board's policy and practice of opening its meetings with religious invocations, where students are often present and participate, violate the Establishment Clause of the First Amendment?
Opinions:
Majority - Per Curiam
Yes, the school board’s prayer policy and practice violate the Establishment Clause. The practice does not fall within the legislative prayer exception established in Marsh v. Chambers and Town of Greece v. Galloway because the context is fundamentally different from a legislature. School board meetings function as an extension of the school environment, where students are a key part of the audience; these students are impressionable, their attendance is not truly voluntary, and they are in an unequal power relationship with the Board members, creating a coercive atmosphere. Because the legislative prayer exception is inapplicable, the court applied the three-pronged Lemon v. Kurtzman test and found the policy unconstitutional. The policy fails the first prong because it lacks a secular legislative purpose; the stated purposes of 'solemnization' and 'respect for religious diversity' were a sham, undermined by the Board members’ overt proselytizing and the choice to use an 'invocation' when secular means of solemnization were available. The policy’s purpose was predominantly to advance religion, specifically Christianity.
Analysis:
This decision significantly limits the application of the legislative prayer exception from Town of Greece, clarifying that it does not extend to the unique environment of public school board meetings where students are present. It reinforces the principle that religious exercises in school-related settings are subject to heightened scrutiny due to the coercive pressures on impressionable students. The case establishes a strong precedent within the Ninth Circuit, distinguishing school boards from other deliberative bodies like city councils and affirming that the presence of students transforms the constitutional analysis. The ruling also confirms the continued viability of the Lemon test for evaluating Establishment Clause challenges in the public school context.
