Cambridge Christian School v. Florida High School Athletic Association
Back in December of 2015, Cambridge Christian High School made it to the Florida Class 2A championship football game, in which they were set to play their rival, University Christian High School. The two Christian schools shared religious ideologies, general academics, moral bases, educational community goals, and prayer tradition. On game day, students took matters into their own hands and wished to pray amongst their team and with everyone in the stadium. The prayer was restricted from being broadcasted over the loudspeaker, which meant the prayer was only audible to the student athletes, not anyone else in attendance of the football game. Cambridge Christian was extremely discontent and insisted that denial to operate the loudspeaker system inhibited both teams' students, parents, and fans' right to religious worship, gather in prayer, and exhibit the free speech to do such. Many members in this unified Christian community were displeased with the Florida High School Athletic Association for prohibiting the religious speech of its student athletics, while permitting the projection of announcements, team introductions, advertisements, and music with the Camping World Stadium Public Address System. While student speech was granted to further the sporting event objectives, speech in the form of prayer was strictly banned across the stadium.
Uprising and resistance to the Florida High School Athletic Association (FHSAA) guidelines surfaced, as both schools and their fans collectively believed prayer was essential before the championship game, the most important one of the session. The student athletes argued this form of prayer is a fundamental part of their worship and a way for both teams and their fans to religiously connect. The prayer was also heavily valued for God to guide them in strength, stay safe from injury, rejoice, and be spiritually guided towards victory. The FHSAA showed little regard for the two schools' unified request, as the attorney contended that allowing a pregame prayer would directly violate the Constitution in regard to establishment. Both schools collectively challenged this statue, leading Cambridge Christian to file suit.
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The FHSAA was quick to reject the Christian school’s request for broadcasted prayer, as it was religious in nature and would appear to be establishing religion to any reasonable observer, which would intrude a separation of the Church and state. The association further argued that regardless of both schools aligned faith and morals, it would be unconstitutional to place people in a situation where they had to choose between leaving the game or sitting in agony if their views clashed with the projected prayer. Additionally, the championship game was not conducted on school grounds, rather a state-owned stadium with its respective equipment. Nonetheless, Cambridge Christian refuted these presumptions and asserted that the FHSAA is wrongfully executing viewpoint discrimination. This means the association is restricting the content of the private speech of student prayer, on the premise that it contradicts the viewpoints of the state.
In culminating the background of the case, we must evaluate the question at hand, “Does the Cambridge Christian High School student-led religious prayer during a school football game, violate the Establishment Clause of the First Amendment? In order to properly grasp the extent of this case and how the Supreme Court has ruled in the past over a similar matter regarding student-led prayer, we must turn our attention to the precedent case of Santa Fe Independent School District v. Doe.
In 1995 a student that was elected to Santa Fe High School’s student-led student council, delivered a public prayer before each home varsity football game. The students unanimously voted who would give the prayer with knowledge of the religious perspective it would be from. Shortly following, the students, alumni, and parents of the Catholic and Mormon faiths brought this action to court, on the grounds of its endorsing nature and unconstitutionality. The Court resisted this notion, even after the school modified a new district policy in regard to this matter; and strictly required that all speeches be nonsectarian and non-proselytizing. The court reasoned that the authorization and carrying out of prayer would create an excessive entanglement between the church and the state; as the delivery of the speech used government funded equipment and was on government property. The court implemented the coercion test and concluded that religion was being endorsed, as no individual should be placed in an environment where the only options are not attending the game or attending the game and possibly being offended by the religious messages carried over the speakers.
It is interesting to note that these cases are quite similar in nature, but diverge in one category. In Santa Fe Independent School District v. Doe, the school requesting prayer is public, while both schools in the Cambridge Christian School case against the FHSAA are private and share the same denomination. While this may appear to be a key differentiating factor, the football games in both cases were on public, government funded property. I feel as though it would be hard for the Supreme Court to rule that prayer in this case is constitutional, considering it was ultimately prohibited and deemed unconstitutional in the other case. If this were to occur, then the court would have to overturn the ruling of Santa Fe Independent School District v. Doe which does not seem likely. In analyzing the details, the students of the Santa Fe School District took a rather democratic tactic by voting amongst the students to carry out the majority opinion of performing prayer, while the Christian school students felt there was no need for a vote because both schools were religiously uniform. Regardless of the majority, I believe in both situations, desiring a prayer to be carried out in this particular manner would be an unconstitutional establishment of religion. Student-led voting and assumptions can not be the basis or justification for integrating a religious matter, one that not everyone may hold, into a secular setting. This places students, families, and fans of Cambridge Christian and University Christian who may hold a different religious belief or are agnostic, in an inferior, minority position. Many different people are coming to this government funded championship stadium setting to view a sporting game, not be directly or indirectly, depending on your perspective, coerced into the Christian faith. I bestow a point highlighted by the majority opinion in Santa Fe Independent School District v. Doe, which is with all of this in mind, any reasonable observer would view this as an unconstitutional religious endorsement.
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https://www.mtsu.edu/first-amendment/article/672/santa-fe-independent-school-district-v-doe
http://religionclause.blogspot.com/2022/04/ban-on-prayer-over-pa-system-at-high.html
https://www.britannica.com/event/Santa-Fe-Independent-School-District-v-Doe
When looking at this case, you successfully acknowledged the key difference between it and prior precedent: the two schools involved are private religious schools. While on their own grounds they can likely conduct prayer when wanted, the FHSAA is a public organization for sports in the state of Florida. It encompasses both private and public schools, as the different divisions are based on size of the school. Additionally, the teams are not always the same, meaning it would not be possible to create a rule for religious schools to pray before state games, even if it was constitutional. However, that is beside the point since given the precedent and the nature of the organization as a public establishment, it is not constitutional to allow prayer before games, as a common spectator may see it as coercion of those involved.
ReplyDeleteIn this case, I think it is most important to note the distinction between public and private schools. I do not believe it can be considered a state establishment of religion if a private institution decides to lead prayers. These schools are both Christian private schools who would like to conduct a prayer that is in line with their values. Just because it is not a neutral prayer, or citizens who disagree with these beliefs will have to hear it does not make it an establishment. The grounds where the game is held are public, which can be considered an establishment, but because the message is coming from private, religious institutions, I do not see government endorsement of religion. The government may be allowing religion, but that falls more in line with free exercise.
ReplyDeleteThis is a great breakdown of the case, Lena. I agree with Molly's comment above that it does not matter if it was public or private since the FSHAA is a state program with state equipment. It would most definitely be a slippery slope if the Court said this was Constitutional as any private school using state grounds and equipment would feel affirmed to broadcast a prayer. If the game was between the two teams on one's home field, it would be Constitutional due to the power realm of private schools. But since the field and game was regulated by the FSHAA, the state circumstance makes it a breach of establishment.
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ReplyDeleteThis is a very interesting case, especially considering some of the class discussions we've had this semester. The private vs public school scenario is a very difficult one to analyze. It is my opinion that private schools should be able to practice prayer before a game. However, it becomes tricky when a public school that relies heavily on state funding tries to do the same. I wonder if in a situation like a private vs public school there could be an alternative solution to allow for prayer to continue. For instance, ensuring that the prayer happens in a private space like the locker room instead of in a public area.