ABSTRACT

In Lamb's Chapel v. Center Moriches Union Free School District, 508 US 384, the US Supreme Court was presented with a case involving a New York state law that banned the use of public school facilities for any religious purpose, even during after-school hours. The Court avoided directly addressing the question of whether school districts must allow religious worship on school property. Justice Byron R. White's opinion reviewed the Court's precedents on the separation of church and state. Joined by five justices, White determined that Lamb's Chapel's use of school facilities to show the films did not violate the three-prong test developed in Lemon v. Kurtzman, the Court's pronouncement on when government action was prohibited under the Establishment Clause because it constituted "establishment of religion." Justice White wrote that the district could not deny Lamb's Chapel a public forum solely because the church addressed the topics from a religious viewpoint.