erican people to recite as a part of a religious program carried on by government" and Wallace v. Jaffree, 472 U.S. 38 (1985), in which the Court struck down state statutes under which time was set aside in the public schools for meditation or silent prayer. This followed Abington School District v. Schnepp, 374 U.S. 203 (1963) which struck down a state statute and public school policies requiring the reading of the Bible or the reciting of the Lord's Prayer in classrooms. In Stone v. Graham, 449 U.S. 39 (1980), the Court ruled that the compulsory posting on bulletin boards in the public schools of the Ten Commandments violated the establishment clause. Tribe says that the net result of these cases is that "prayer as an established part of the official school day is always forbidden" (1988, p. 1169). In a recent decision, Lee v. Weisman, 505 U.S. 577 (1992), struck down a non-sectarian prayer offered at a public school graduation ceremony given by a Jewish rabbi.
Outer Limits of the Establishment Clause.
The strict view taken by the Supreme Court in the school prayer cases is based on the belief that there should be "a wall of separation between Church and State," a view attributed originally to Thomas Jefferson (Everson v. Board of Education, 370 U.S. 1, 16 (1947). The school prayer decisions have been controversial and have been opposed by significant elements of the population, especially the religious right. Pat Robertson, for example, quoted John Adams for the proposition that "our Constitution [is made] only for a moral and a religious people" and decried "the judicial distortions which have forbidden little children to pray or read the Bible in the public schools" (1991, pp. 597-598). Various polls by Gallup and others have showed that there is widespread non-compliance with the Court's school prayer decisions, especially in the South (Cochran, Mayer, Carr & Cayer, 1996, p. 412 and 423).
The Court has tread more wari...