Wynne v. Town of Great Falls
376 F.3d 292 (2004)
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Rule of Law:
A legislative body's practice of opening its meetings with sectarian prayers that invoke a specific deity, such as Jesus Christ, violates the Establishment Clause of the First Amendment by advancing one religion over others.
Facts:
- The Town Council of Great Falls, South Carolina, comprised entirely of Christians, always began its public meetings with a prayer.
- The prayers frequently referred to 'Jesus,' 'Jesus Christ,' 'Christ,' or 'Savior,' and citizens in attendance customarily stood, bowed their heads, and said 'amen.'
- Darla Kaye Wynne, a resident and follower of the Wiccan faith, regularly attended these meetings to participate in town business.
- Wynne became uncomfortable with the exclusively Christian nature of the prayers and objected to the Town Council, proposing they use nonsectarian prayers or invite other faiths to pray.
- The Mayor, Henry Clayton Starnes, rejected her request, stating, 'This is the way we’ve always done things and we’re not going to change.'
- After Wynne's objection, community backlash included petitions supporting 'Christian' prayer and opposition to allowing a 'witch' to pray.
- Wynne felt ostracized and threatened by fellow citizens, who told her she wasn't wanted and accused her of being a 'Satanist.'
- Wynne's ability to participate in council business was adversely affected; she was denied speaking time and felt treated differently by the council.
Procedural Posture:
- Darla Kaye Wynne sued the Town of Great Falls, its Mayor, and council members in U.S. District Court.
- The complaint alleged that the Council's practice of holding Christian prayers at its meetings violated the Establishment Clause of the First Amendment and sought an injunction.
- The district court denied the Town Council's motion for summary judgment.
- After a bench trial, the district court entered judgment for Wynne, finding the prayer practice unconstitutional.
- The district court issued a permanent injunction ordering the Town Council to cease invoking the name of a specific deity associated with any one faith.
- The Town Council (appellant) appealed the district court's judgment to the U.S. Court of Appeals for the Fourth Circuit.
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Issue:
Does a town council's practice of opening its public meetings with prayers that specifically and frequently invoke 'Jesus Christ' violate the Establishment Clause of the First Amendment?
Opinions:
Majority - Judge Motz
Yes, the Town Council's practice violates the Establishment Clause. While the Supreme Court in Marsh v. Chambers permitted nonsectarian legislative prayer based on a unique historical tradition, it explicitly warned against exploiting the prayer opportunity to 'proselytize or advance any one, or to disparage any other, faith or belief.' By consistently invoking 'Jesus Christ,' a deity specific to Christianity, the Town Council's prayers are sectarian, not nonsectarian. This practice affiliates the government with a particular creed and officially prefers one religion over others, which, as clarified in County of Allegheny v. ACLU, violates the 'clearest command of the Establishment Clause.' The argument that such prayers fall within the 'Judeo-Christian tradition' is incorrect, as that tradition encompasses beliefs held in common, not doctrines specific to one faith. Therefore, the Council's prayers are not the type of permissible legislative prayer upheld in Marsh, but rather an unconstitutional advancement of a particular religion.
Analysis:
This decision significantly clarifies the scope of the legislative prayer exception established in Marsh v. Chambers. It solidifies the principle that the historical allowance for legislative prayer does not extend to sectarian endorsements that affiliate the government with a specific faith. The ruling establishes a clear boundary: nonsectarian, non-denominational invocations are permissible, while prayers that name deities exclusive to one religion constitute an unconstitutional preference. This precedent serves as a critical guide for local governments, reinforcing that they must remain neutral in matters of religion, even within historically accepted practices like legislative prayer.
