ABSTRACT
Release-time programs are popular in many parts of the country. A release-time program is one in which public schools permit their students to use a certain period of the day to leave campus to receive religious instruction. According to surveys cited in Gordon v. Board of Education of the City of Los Angeles, 178 P.2d 488 (1947), by 1947 forty states had authorized some form of release-time program for public school students, and no appellate court in any state had held such programs unconstitutional. The Court found that "the use of tax-supported property for religious instruction and the close cooperation between the school authorities and the religious council in promoting religious education" violated the Establishment Clause. Students may claim that going off campus for religious instruction is necessary in order for them to exercise their religion freely.
