Lamb’s Chapel v. Center Moriches Union Free School District
In disputes over the question of separation of church and state, the use of school facilities by religious groups has been an issue numerous times. The landmark case of Lamb’s Chapel v. Center Moriches Union Free School District (1993) set a broad precedent for the use of public school facilities by outside groups, including religious organizations. In a rare unanimous decision, the U.S. Supreme Court ruled that a school board’s denial of school facility use to a religious group violated the group’s First Amendment guarantee to free speech.
Facts of the Case
Lamb’s Chapel arose where a New York state law allowed school boards to permit a wide variety of groups to use their facilities and property for a wide array of outside purposes, including social, civic, and recreational meetings and entertainment. However, the law did not include the use of meetings for religious purposes.
A local church twice requested to use school facilities at Center Moriches Union Free School District, outside of school hours, to show a 6-hour video series dealing with parenting issues that centered on Christian family values. Board officials denied the church’s request on both occasions, claiming that the film was “church related.”
When the church and its pastor sued the board for violating the Free Speech Clause of the First Amendment of the U.S. Constitution, a federal trial court granted its motion for summary judgment. The court maintained that since the school’s facilities were only a limited public forum, the board’s denials of the group’s request to use them for religious activities were, in fact, viewpoint neutral. The Second Circuit affirmed in favor of the board.
The Court’s Ruling
On further review, the U.S. Supreme Court reversed in favor of the religious organization, on the basis that the board’s denial of its request to use school facilities solely because the group planned to show a film with a religious basis did, indeed, violate the church’s free speech rights as protected by the First Amendment. The Court explained that since the facilities were used by other non-school-related groups for functions during nonschool hours, the board had in effect established a “limited public forum.”
The Court added that since there was no apparent threat of violence or disruption for allowing the group to use school facilities, the request to use district facilities should likely have been granted. The Court thus found that insofar as the only reason the board rejected the organization’s request was solely that the group was of a religious nature, denying it access for this reason was a violation of the “viewpoint neutrality” standard that requires state agencies to exhibit neither a positive nor negative attitude toward religion.
By allowing school facilities to be used by civic and social groups, such as the Boy Scouts or Girl Scouts, the Supreme Court was of the opinion that school boards such as the one in Center Moriches establish a “limited public forum” and cannot then deny similar access or facility use to religious groups or organizations. The Court reasoned that opening school doors for some groups but not specifically for religious groups violates both the notion of viewpoint neutrality and their rights to free speech as protected by the First Amendment, even if this speech has its basis in religion or is made for religious purposes.
Likewise, the Court observed that allowing a group to use school facilities for religious purposes does not imply that school or board officials promote or establish religion. In fact, the Court pointed out that the use of facilities does not imply that a meeting (or movie, as in the case at bar) is a school-sponsored or schoolendorsed event, because while such a gathering is not necessarily closed to the public, there is nothing to suggest that the board has established an open forum for the use of its facilities.
As the Supreme Court noted in Lamb’s Chapel, and reiterated almost a decade later in Good News Club v. Milford Central School (2001), if the message being delivered by the use of school facilities is appropriate (which the movie on child rearing and family values was), then a government-sponsored agency such as a school board cannot discriminate solely on the basis of the religious nature of the messenger.
Stacey L. Edmonson
- Good News Club v. Milford Central School, 21 F. Supp. 2d 147 (N.D.N.Y. 1998); aff'd, 202 F.3d 502 (2d Cir. 2000, rev’d); 533 U.S. 98 (2001). Lamb’s Chapel v. Center Moriches School District, 508 U.S. 384 (1993).