Ishmael Jaffree, an Alabama resident with three children in public schools, filed a complaint against the Mobile school board and his children's teachers for using a law which authorized a period of silence "for meditation or voluntary prayer" to engage in school prayer. Alabama already had a statute that established a period of silence "for meditation," but the state legislature had recently passed a law with the only change being the addition of the voluntary prayer language.
Is the new statute that authorizes a period of silence "for meditation or voluntary prayer" a law respecting the establishment of religion within the meaning of the First Amendment?
Yes. The state law was found to be unconstitutional by the First Amendment via the Fourteenth Amendment.
The majority found that the statute did not pass the first prong of the Lemon test, namely that the law was not passed for a secular purpose. The statute was clearly an attempt on behalf of the Alabama state legislature to endorse school prayer as made evident by the minor adjustment to the statute from the previous version as well as numerous public pronouncements by state legislators.
V. Concurring Opinion
Justice O'Connor wrote to make special note that most moment of silent statutes are constitutional and that this ruling was based solely on the obvious attempt of the Alabama legislature to push school prayer. She also rejects Justice Rehnquist's dissent that there is a historical precendent in the passing of the First Amendment that nullifies that secular purpose requirement of the Lemon test.
VI. Dissenting Opinion
Justice Rehnquist argued that James Madison did not intend for the First Amendment to require the government to be neutral in religious affairs and that the objective of the amendment was merely to prevent against the establishment of a national religion or prejudice against any religion.
This decision continued the strong precedent of the court to see school prayer as in violation of the First Amendment.