ABSTRACT
In Board of Education v. Grumet, 512 US 687 (1994), the US Supreme Court enunciated the neutrality principle the government must apply when dealing with religious groups: It cannot prefer one religion to another. The government violates the Establishment Clause of the First Amendment to the US Constitution when it discriminates among religious groups. The village of Kiryas Joel was created by a group of Satmar Hasidic Jews (Satmars), practitioners of a particularly strict form of Orthodox Judaism, who drew the village lines carefully to exclude all but Satmars. In 1989, in what Governor Mario Cuomo described as a "good faith effort to solve this unique problem," the New York Assembly passed a law constituting Kiryas Joel as a separate school district and created a local board to preside over the new district. The Kiryas Joel district ran only a special education program for the village's handicapped children, as the other Satmar children continued to attend their parochial schools.
