Engel v Vitale

US President Thomas Jefferson once remarked that when the American public adopted the Establishment Clause, they erected "a wall of separation between the church and the state." Today it's somewhat of a known fact that saying prayers at school is not allowed. Have you ever wondered why that is? It all comes down to the First Amendment and the ruling established in Engel v Vitale which found that state-sponsored prayer was unconstitutional. This article aims to give you more information regarding the details surrounding Engel v. Vitale and its impact on American society today.

Figure 1. Establishment Clause vs State-Sponsored Prayer, StudySmarter Originals

Engel v Vitale Amendment

Before diving into the Engel v Vitale case, let's first talk about the Amendment the case centered around: The First Amendment.

The First Amendment States:

Establishment Clause

In Engel v Vitale, parties argued whether or not the Establishment Clause in the First Amendment was violated. The Establishment Clause refers to the part of the first Amendment that says the following:

This clause ensures that Congress doesn't establish a national religion. In other words, it banned state-sponsored religion. So, was the establishment clause violated or not? Let's find out!

Engel v Vitale Summary

In 1951, the New York Board of Regents decided to write a prayer and have students recite it as part of their "moral and spiritual training." The 22-word non-denominational prayer was voluntarily recited every morning. However, the children could opt out with parental permission or could simply refuse to partake by remaining silent or leaving the room.

In the creation of the prayer, the New York Board of Regents did not want to have issues with the First Amendment and the religious freedom clause, so they composed the following prayer:

While many schools in New York declined to have their students recite this prayer, the Hyde Park School Board went ahead with the prayer. As a result, a group of parents, including Steven Engel, represented by William Butler, appointed by the American Civil Liberties Union (ACLU), submitted a lawsuit against the School Board President William Vitale and the New York State Board of Regents, arguing that they were violating the Establishment Clause in the First Amendment by having the students recite the prayer and referring to God in the prayer.

Vitale and the School board argued that they had not infringed upon the First Amendment or the Establishment Clause. They argued that the students weren't forced to say the prayer and were free to leave the room, and therefore, the prayer did not infringe on their rights under the Establishment Clause. They also argued that while the First Amendment did ban a state religion, it did not restrict the growth of a religious state. They even claimed that since the prayer was nondenominational, they weren't infringing upon the free exercise clause in the First Amendment.

The lower courts sided with Vitale and the School Board of Regents. Engel and the rest of the parents continued their fight and appealed the verdict to the United States Supreme Court. The Supreme Court accepted the case and heard Engel v Vitale in 1962.

Engel v Vitale Ruling

The Supreme Court ruled in favor of Engel and the other parents in a 6-to-1 decision. The only dissenter on the court was Justice Stewart The justice that wrote the majority opinion was Justice Black. He stated that any religious activities sponsored by a public school were unconstitutional, especially since the Regents wrote the prayer themselves. Justice Black noted that praying for God's blessing was a religious activity. Therefore the state was imposing religion upon the students, going against the establishment clause. Justice Black also stated that although students could decline to say the prayer if the state backs it, they might feel pressured and feel compelled to pray anyway.

Justice Stewart, in his dissenting opinion, argued that there was no evidence showing that the state was establishing a religion when it was giving the children an option of not saying it.

Engel v Vitale 1962

The ruling of Engel v. Vitale in 1962 caused public outrage. The Supreme Court's decision turned out to be a counter-majoritarian decision.

There seemed to be a misunderstanding as to what the judges had decided. Many, due to media outlets, were led to believe that the Judges outlawed prayer in school. However, that was untrue. The judges agreed that schools couldn't say prayers created by the state.

Due to Engel v. Vitale, the court received the most mail it had ever received regarding a case. In total, the court received over 5,000 letters that mainly opposed the decision. After the decision was made public, a Gallup poll was taken, and around 79 percent of Americans were unhappy with the court's decision.

The public reacted to this case due to a media frenzy. Still, many factors may have made the outcry worse, such as the Cold War and juvenile delinquency during the 50s. This led to many choosing to accept religious values, which just fueled the flame for the objection to the Engel v. Vitale ruling.

Twenty-two states submitted amicus curiae in favor of prayer in public schools. There were even multiple attempts by the legislative branch to create amendments to make prayer in public schools legal. However, none were successful.

Figure 3. No School-Sponsored Prayer, StudySmarter Originals

Engel v Vitale Significance

Engel v. Vitale was the first court case that dealt with reciting prayers at school. It was the first time that the Supreme Court prohibited public schools from sponsoring religious activities. It helped limit the scope of religion within public schools, helping create a separation between religion and state.

Engel v Vitale Impact

Engel v Vitale had a lasting impact on religion vs. state matters. It became a precedent for finding state-led prayer at public school events unconstitutional, as in the case of Abington School District v. Schempp and Santa Fe Independent School District v. Doe.