Prayer in schools

Description: Prayers and Bible readings sanctioned by school officials were efforts to promote religious beliefs and values in students in public educational institutions.

Relevant amendment: First

Significance: The practice of reciting officially sanctioned prayers or reading from the Bible in US public schools was challenged as a violation of the doctrine of separation of church and state under the establishment clause of the First Amendment of the US Constitution. Supreme Court rulings resulted in strong public criticism and in continuing efforts by Congress to reverse the court’s decision.

In 1962, the US Supreme Court issued one of its most controversial decisions in Engel v. Vitale. At issue was a nondenominational prayer composed by the regents of the state of New York that was to be recited in public school classrooms by teachers on a voluntary basis. It read: “Almighty God we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers, and our Country.” Justice Hugo L. Black, writing the opinion for the court, noted that the apparatus of the public school system was employed in the promotion of religion and thus resulted in a violation of the establishment clause. A year later, the court struck down a state-mandated practice of reading passages from the Bible without commentary in Abington School District v. Schempp. In his opinion, Justice Tom C. Clark applied the same “strict separation” analysis.

In its decision in Lemon v. Kurtzman (1971), the court developed the establishment clause test that remained in use and has been applied in church-state cases. Chief Justice Warren E. Burger wrote, “First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion; finally, the statute must not foster ‘an excessive government entanglement with religion.’” The first element of this three-pronged test was invoked in Wallace v. Jaffree (1985), when the court ruled unconstitutional an Alabama law requiring a daily moment of silence for prayer or meditation in public schools. In 1990, the court ruled in Board of Education of Westside Community Schools v. Mergens that the 1984 law requiring schools to permit religious extracurricular clubs to meet in equality with all other extracurricular groups must be upheld. The Lemon test was then reaffirmed in Lee v. Weisman (1992), when the court struck down Providence, Rhode Island, public school principals’ use of members of the clergy to offer invocation and benediction prayers as part of the formal graduation ceremonies for middle and high schools. Eight years later, in Santa Fe Independent School District v. Doe, the court ruled that a Texas school's policy of student-led prayer conducted over the public address system before football games violated the First Amendment.

While school-sponsored or required prayer was still legally banned in the early 2020s, commentators noted that religion did still have a presence—perhaps even an increased presence—in the school environment, largely in the form of prayers conducted on personal time in between classes or during lunch or through extracurricular activities. Ministries continued helping students organize clubs in several public schools, students often discussed the Bible in informal groups, and religious instruction could take place as part of after-school programs. Additionally, some classes incorporated objective history lessons about various religions as part of their curriculum, as this type of study is not considered unconstitutional.

In its efforts to define and apply the establishment clause, the court developed several perspectives on how best to ensure that the government refrained from endorsing a particular faith while at the same time protected the religious freedom of liberty and conscience. The result was often a confusing line of precedents that offered no distinct or enduring first principles that work in all situations. Despite heavy criticism levied against the court, however, its separationist stance on government-supported religion in public schools remained firm.

In the early 2020s, however, the Supreme Court's view on maintaining the separation of church and state in public schools began to shift. In 2022, the court ruled in favor of a high school football coach in Washington State who had been fired in 2015 for praying on the field at the end of games, citing that his actions were protected by the First Amendment. The case highlighted the more conservative court's inclination to interpret government actions previously seen as neutral and essential for upholding the separation of church and state as being antagonistic toward religious expression.

Additionally, the first (2017–21) and second (starting in 2025) administrations of President Donald Trump sought to use executive power to ensure that students' constitutional rights to freedom of religion and prayer while at school were protected. Part of this effort entailed updating existing guidance from 2003 issued by the US Department of Education regarding religious expression in public elementary and secondary schools to reiterate that no one in the school setting can be discriminated against for private religious expression. The updated guidance additionally stipulated that local education agencies receiving funds through the Elementary and Secondary Education Act of 1965 must regularly certify that they do not have any policies in place that would prevent anyone from participating in constitutionally protected prayer. Under the guidance, any instances of complaints of such breaches of rights needed to be reported to the Department of Education.

At the state level, some legislatures continued to introduce or pass laws pertaining to school prayer. In 2025, Texas passed a bill allowing districts to optionally dedicate a period of time during the school day for those who wanted to engage in prayer.

Although the percentage of Americans in favor of religion in schools declined somewhat over the years, a Pew Research study revealed that, between 2023 and 2024, 52 percent of American adults favored allowing public school teachers to lead their classes in prayers that refer to Jesus.

Bibliography

"Attorney General Ken Paxton Encourages Texas Schools to Begin Legal Process of Putting Prayer Back in the Classroom and Recommends the Lord's Prayer for Students." Ken Paxton, 2 Sept. 2025, texasattorneygeneral.gov/news/releases/attorney-general-ken-paxton-encourages-texas-schools-begin-legal-process-putting-prayer-back. Accessed 23 Mar. 2026.

Kaleem, Jaweed. "School Prayer 50 Years Later: What Do Americans Believe?" The Huffington Post, 19 June 2013, www.huffingtonpost.com/2013/06/19/school-prayer_n_3461479.html. Accessed 23 Mar. 2026.

Klein, Rebecca. "Most Americans Support Allowing Students to Pray in Public Classrooms." The Huffington Post, 2 Oct. 2014, www.huffingtonpost.com/2014/10/02/pray-in-public-school_n_5917000.html. Accessed 23 Mar. 2026.

Lawrence, Lee. "School Prayer: 50 Years after Ban, God and Faith More Present Than Ever." The Christian Science Monitor, 16 June 2013, www.csmonitor.com/The-Culture/Family/2013/0616/School-prayer-50-years-after-the-ban-God-and-faith-more-present-than-ever. Accessed 23 Mar. 2026.

Reilly, Katie. "Donald Trump Is Promising 'Big Action' on School Prayer to Rally Evangelical Voters." Time, 16 Jan. 2020, time.com/5765829/trump-school-prayer-evangelicals/. Accessed 23 Mar. 2026.

Rotolo, Chip. "Support for Christian Prayer in U.S. Public Schools Varies Widely by State." Pew Research Center, 23 June 2025, www.pewresearch.org/short-reads/2025/06/23/support-for-christian-prayer-in-us-public-schools-varies-widely-by-state/. Accessed 23 Mar. 2026.

Sneed, Tierney. "School Prayer Fight Begins Anew." U.S. News and World Report, 27 Aug. 2014, www.usnews.com/news/articles/2014/08/27/school-prayer-fight-begins-anew. Accessed 23 Mar. 2026.

"U.S. Department of Education Issues Guidance on Prayer and Religious Expression in Public Schools." US Department of Education, 5 Feb. 2026, www.ed.gov/about/news/press-release/us-department-of-education-issues-guidance-prayer-and-religious-expression-public-schools. Accessed 23 Mar. 2026.

Williams, Pete. "Supreme Court Rules for Former Coach in Public School Prayer Case." NBC News, 27 June 2022, www.nbcnews.com/politics/supreme-court/supreme-court-rules-coach-public-school-prayer-case-rcna31662. Accessed 23 Mar. 2026.