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View Full Version : 8th Circuit Drops the Ball in Prayer Case


Stephen Maturin
August 22, 2003, 11:51 AM
Seems the good folks in Madison County, Nebraska, or at least their elected representatives, are rather fond of state-sanctioned prayer at public school graduation ceremonies. The parent of a graduation high school senior found out that the school district scheduled formal invocation and benediction prayers for her son's graduation ceremony. Mom contacted the ACLU, which in turn contacted the district. Two days before the ceremony, and apparently after much wailing and gnashing of teeth, the school board agreed to drop the prayers.

So far, so good.

Graduation day rolled around and the school board president opened the ceremony with an announcement. He basically told those assembled that we're all kinds of sorry about this, but there won't be any prayers at the ceremony thanks to the ACLU. Later in the ceremony, the president introduced another member of the school board who announced that he had "a few words to share." The board member stepped to the podium and gibbered as follows:

I promise to make this uh fairly short for me. There is a saying that when the door closes another one opens. We have been prohibited from doing some things at today’s ceremony and it’s brought me to a lot of reflections over the last couple of days. And when I have to reflect, I usually turn and ask for guidance. And one of the things that I usually do is to recite. So I am going to recite something, and I would ask and more so, encourage, any of you that this sounds familiar [sic] to please join in. Our Father, who art in heaven, hallowed be thy name. Thy kingdom come, thy will be done, on earth as it is in heaven. Give us our daily bread, and forgive us our trespasses as we forgive those who trespass against us and lead us not into temptation but deliver us from evil, for thine is the kingdom and the power and the glory forever. May God be with you always.

Please, please take a seat. Back to my original discussion. You need to think about in [sic] the rest of your life in setting goals. And the real challenge is twofold. If you meet that goal, to reset an even higher goal. The bigger challenge, however, is when you set the goal and you’re unable to obtain the goal, not to lower the goal. We will all have failures – physically, mentally and spiritually. Your charge is not to lower the bar, to keep the bar high. I’ll leave you with this. From what we learned Wednesday, we learned the meaning behind in [sic] how to say good-bye. May God be with you always. Congratulations.

An Establishment Clause violation? A state actor abusing his authority in a singularly flagrant manner?

Nope. The board member's recitation of the Lord's Prayer was constitutionally protected "private speech," or so says the U.S. Court of Appeals for the Eighth Circuit.

One judge on the panel had enough testicular fortitude to tell it like it is in a brief but spot-on dissenting opinion:

I dissent from the part of the court's judgment that upholds Mr. Scheer's quite transparent effort to use his public office to thwart the efforts of the anonymous plaintiffs to ensure that the Constitution is observed. The court refers to all the apposite authorities, but, with respect, I believe that it applies them incorrectly. In my view, in the context in which Mr. Scheer was operating, it is apparent that an objective observer could see his actions as state-sponsored. He was acting as a member of the school board in an environment in which the recent school prayer controversy had already been alluded to; indeed, the school board president, instead of merely passing the matter by, had intentionally expressed his displeasure that the first amendment had been invoked and the plans for an invocation abandoned. It is at the very least a jury question whether an objective observer would regard Mr. Scheer's "speech" as state sponsored.

It needs saying directly, though the court does not say so, that Mr. Scheer was not merely speaking, he was praying. He invoked the deity. He "spoke" in the vocative case and he invited others to join in. He recited a prayer that must have been familiar to everyone who was present. This was a religious act, pure and simple, at a state-sponsored event by a state actor who, or so at least a reasonable person could conclude, was determined that the ceremony would be outfitted with a benediction despite the school board's decision that it would not be. This was the manifest purport of Mr. Scheer's statement that "there is a saying that when the door closes another one opens." For that action, Mr. Scheer should be required to respond in damages. (Citation omitted.)

Anyone who's interested can find the entire decision in PDF here (http://www.ca8.uscourts.gov/opndir/03/08/024135P.pdf).

RufusAtticus
August 22, 2003, 12:10 PM
I thought it was decided law that the only people able to have "free, private speech" at a graduation ceremony were the students graduating. Everyone else was an actor of the state.

What ever happened to schools requiring that any benediction be unamiously approved by the graduates?

RufusAtticus
August 22, 2003, 12:28 PM
The School District's informal policy required that Scheer meet two separate criteria prior to speaking at the graduation ceremony; (1) a parent of a graduating senior; and (2) a member of the School Board. Both requirements, parental and School Board membership, were of equal importance and therefore the informal policy criteria neither favor nor oppose a private speech determination. The parental criterion indicates that Scheer was not acting solely in a representative capacity as a member of the School Board, and the membership requirement indicates that Scheer was not acting solely as a parent. However, the existence of the parental requirement is extremely significant and therefore we reject the argument that Scheer spoke only in his official capacity as a member of the School Board. We do not believe that Scheer's membership on the School Board requires a finding of state-sponsorship, rather, we view it merely as one of the factors which supports the involvement of the state in the recitation of the prayer.

This is just plain sloppy reasoning. The fact is that if Sheer wasn't a school board member, he wouldn't be allowed on stage. Ergo, his speech rests on his official capacity.

In fact, there is no evidence that any representative of the School District had any knowledge of Scheer’s intentions.

Except Scheer himself. I'm surprised that they made such a sloppy mistake.

The complete absence of any involvement by the School District in determining whether Scheer would deliver a speech as well as he complete autonomy afforded to Scheer in determining the content of his remarks indicates a lack of statesponsorship of his recitation.

Except, unlike students, Scheer is an member of the School District. Therefore, it is impossible to claim that there was an absence of any involvement by the School District.

Stephen Maturin
August 23, 2003, 03:55 PM
Originally posted by RufusAtticus
Except Scheer himself. I'm surprised that they made such a sloppy mistake.

It's plenty sloppy, all right, but I doubt it was a "mistake" from the majority's standpoint. This was as result-oriented a ruling as you'll ever see.

Jewel
August 23, 2003, 04:06 PM
Originally posted by RufusAtticus
I thought it was decided law that the only people able to have "free, private speech" at a graduation ceremony were the students graduating. Everyone else was an actor of the state.


That's exactly what I thought. I wouldn't think that a member of a school board acting in an official capacity could recite the lords prayer at a graduation.

I doubt the majority ruling was a mistake -- I'm sure they knew full well what they were doing.

StrictSeparationist
August 24, 2003, 09:57 AM
So, what do we think will be the eventual result? Reversal by the full Circuit? A vacate and remand order by the Supreme Court? A loss at the Supreme Court? This whole private speaker thing reeks of disregard of Lee, and I would hope that the Supreme Court won't ignore that.

Stephen Maturin
August 25, 2003, 07:53 AM
Originally posted by StrictSeparationist
So, what do we think will be the eventual result?

Given the dissent and the issue involved, this one looks like an excellent candidate for en banc rehearing. I know jack about the 8th Circuit, though, and thus can't say whether such a rehearing would be a good thing.