Lee (1992): Suppose that a school conducts an official ceremony or ritual outside the classroom, and prayer is part of that ceremony. At least where school officials can fairly be said to be sponsoring the religious message, a prayer will be found to be a violation of the Establishment Clause. But Lee also establishes that even a completely non-denominational school prayer will violate the Establishment Clause if it is state-sponsored. This case involved prayers at public middle-school and high-school graduation ceremonies. In one instance, a middle-school principal invited a rabbi to deliver prayer, told him the prayer should be non-sectarian, and gave him a pamphlet (prepared by the National Conference of Christians and Jews) detailing the kinds of prayers that would be appropriate at a public civic occasion. The prayers delivered by the rabbi were indeed non-denominational, and consisted mainly of thanks to God (e.g., “Oh, God, we are grateful to You for having endowed us with the capacity for learning which we have celebrated on this joyous commencement…. Send Your blessings upon the teachers and administrators who helped prepare [the students]”). P was a graduating student who argued that she shouldn’t be required to listen to a prayer as part of her graduation ceremony. Was this non-denominational school prayer a violation of the Establishment Clause of the First Am.?
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