Professor William Allan Kritsonis, PhD - Distinguished Alumnus, Central Washington University, College of Education and Professional Studies, Ellensburg, Washington.Dr. Kritsonis has traveled and lectured extensively throughout the United States and world-wide. Some international travels include Australia, New Zealand, Tasmania, Turkey, Italy, Greece, Monte Carlo, England, Holland, Denmark, Sweden, Finland, Russia, Estonia, Poland, Germany, Mexico, the Caribbean Islands, Mexico, Switzerland, Grand Cayman, Haiti, St. Maarten, St. John, St. Thomas, St. Croix, St. Lucia, Puerto Rico, Nassau, Freeport, Jamaica, Barbados, Martinique, Canada, Curacao, Costa Rico, Aruba, Venezuela, Panama, Bora Bora, Tahiti, Latvia, Spain, Honduras, and many more. He has been invited to lecture and serve as a guest professor at many universities across the nation and abroad.

1. Prayer in SchoolsPrayer in Schools
William Allan Kritsonis, PhDWilliam Allan Kritsonis, PhD

2. Prayer and the PublicPrayer and the Public
SchoolsSchools
Most people of faith understandMost people of faith understand
that personal issues of prayerthat personal issues of prayer
when manipulated bywhen manipulated by
government can lead togovernment can lead to
dangerous consequences,dangerous consequences,
including exclusion, octracizationincluding exclusion, octracization
and even violence. For thisand even violence. For this
reason the faith groupsreason the faith groups
represented in this workrepresented in this work
diligently to make sure thatdiligently to make sure that
individual conscience is respectedindividual conscience is respected
by rejecting calls for laws toby rejecting calls for laws to
mandate prayer in the publicmandate prayer in the public
schools.schools.

3. Recent Court Decisions aboutRecent Court Decisions about
Prayer in SchoolsPrayer in Schools
• By the 1990s the courts beganBy the 1990s the courts began
addressing prayer at schooladdressing prayer at school
extracurricularextracurricular eventsevents with lesswith less
clarity. While some courtsclarity. While some courts
allowed student prayers fromallowed student prayers from
the podium at graduationthe podium at graduation
exercises, a federalexercises, a federal appellate
court inin HoustonHouston ruled in 1999ruled in 1999
that the recent controversy hasthat the recent controversy has
revolved around prayer atrevolved around prayer at
school athletics events.school athletics events.
Guidance was provided by theGuidance was provided by the
Supreme Court inSupreme Court in
Santa Fe Independent School Dist. v. DoeSanta Fe Independent School Dist. v. Doe
[2000] when it upheld a lower[2000] when it upheld a lower
court ruling invalidating prayerscourt ruling invalidating prayers
conducted over the publicconducted over the public
address system prior to highaddress system prior to high
school games at state schoolschool games at state school
facilities before a school-facilities before a school-
gathered audience.gathered audience.

4. Continued from Slide 2Continued from Slide 2
• Those in favor of sponsored prayerThose in favor of sponsored prayer
in state schools publicly often sayin state schools publicly often say
that "prayer" is forbidden in statethat "prayer" is forbidden in state
schools.schools. [1][1] Prayer is not and neverPrayer is not and never
has been forbidden. Regarding thehas been forbidden. Regarding the
Free Exercise Clause of the First AmendmentFree Exercise Clause of the First Amendment
, the courts have consistently ruled, the courts have consistently ruled
that students' expressions ofthat students' expressions of
religious views through prayer orreligious views through prayer or
otherwise cannot be abridged unlessotherwise cannot be abridged unless
they can be shown to causethey can be shown to cause
substantial disruption in the school.substantial disruption in the school.
• Reinstatement of state-sponsoredReinstatement of state-sponsored
prayer has been attempted inprayer has been attempted in
different forms in a number of areasdifferent forms in a number of areas
of the U.S. Some introduced aof the U.S. Some introduced a
"moment of silence" or "moment of"moment of silence" or "moment of
reflection" when areflection" when a studentstudent may, ifmay, if
he or she wishes to, offer a silenthe or she wishes to, offer a silent
prayer.prayer.

5. ACLU on Constitutional AmendmentACLU on Constitutional Amendment
on School Prayer Or Moment ofon School Prayer Or Moment of
Silence (2002)Silence (2002)
Some, like former Secretary ofSome, like former Secretary of
Education William Bennett blameEducation William Bennett blame
the 1962 decision, Engel v. Vitale,the 1962 decision, Engel v. Vitale,
banning official prayer from publicbanning official prayer from public
schools, for everything from lowschools, for everything from low
SAT scores to high teenageSAT scores to high teenage
pregnancy rates. But manypregnancy rates. But many
educators and other experts tell useducators and other experts tell us
that these problems flow from thethat these problems flow from the
enormous and increasing gulf inenormous and increasing gulf in
wealth and opportunity andwealth and opportunity and
education, between the richest andeducation, between the richest and
poorest people in our society. A one-poorest people in our society. A one-
minute prayer or moment of silenceminute prayer or moment of silence
in school everyday will do nothing toin school everyday will do nothing to
change that.change that.

6. Prayer at Graduation CeremoniesPrayer at Graduation Ceremonies
Recently, some high schoolsRecently, some high schools
havehave
banned prayer from graduationbanned prayer from graduation
ceremonies. In May 2006, theceremonies. In May 2006, the
ACLUACLU of Tennessee convincedof Tennessee convinced
Munford High SchoolMunford High School's principal to's principal to
ban official prayer atban official prayer at
graduation.graduation.[2][2] In response,In response,
students pulled out cards with thestudents pulled out cards with the
Lord's PrayerLord's Prayer written on them andwritten on them and
began to read. Also, some havebegan to read. Also, some have
concluded that the school's ACLUconcluded that the school's ACLU
club faculty adviser has lost herclub faculty adviser has lost her
job over the incident.job over the incident.[3][3]

7. In Different Regions of theIn Different Regions of the
WorldWorld
United KingdomUnited Kingdom
• InIn England and WalesEngland and Wales,, the School Standardsthe School Standards
and Framework Act 1998and Framework Act 1998 states that all pupilsstates that all pupils
inin state schoolsstate schools must take part in a daily actmust take part in a daily act
of collective worship, unless their parentsof collective worship, unless their parents
request that they be excused from attending.request that they be excused from attending.
[1][1] The majority of these acts of collectiveThe majority of these acts of collective
worship are required to be "wholly or mainlyworship are required to be "wholly or mainly
of a broadlyof a broadly ChristianChristian character", with twocharacter", with two
exceptions:exceptions:
• Religious schools, which should provideReligious schools, which should provide
worship appropriate to the school's religionworship appropriate to the school's religion
(although most religious schools in the UK(although most religious schools in the UK
are Christian.)are Christian.)
• Schools where the Local EducationSchools where the Local Education
Authority's Standing Advisory Council onAuthority's Standing Advisory Council on
Religious Education has determined thatReligious Education has determined that
Christian worship would not be appropriateChristian worship would not be appropriate
for part or all of the school.for part or all of the school.
• Despite there being a statutory requirementDespite there being a statutory requirement
for schools to hold a daily act of collectivefor schools to hold a daily act of collective
worship, many do not. OFSTED's 2002-03worship, many do not. OFSTED's 2002-03
annual report [2], for example, states thatannual report [2], for example, states that
80% of secondary schools are failing to80% of secondary schools are failing to
provide daily worship for all pupilsprovide daily worship for all pupils

8. The History of Prayer in SchoolsThe History of Prayer in Schools
• School Sponsored or Employee- LedSchool Sponsored or Employee- Led
Prayer.Prayer. More than40 years ago, the U.S.More than40 years ago, the U.S.
Supreme Court handed down two majorSupreme Court handed down two major
school prayer decisions. The first,school prayer decisions. The first, EngelEngel
v. Vitale(1962),v. Vitale(1962), involved ainvolved a
denominationally neutral prayerdenominationally neutral prayer
composed by the New York State Boardcomposed by the New York State Board
of Regents: “Almighty God, weof Regents: “Almighty God, we
acknowledge our dependence uponacknowledge our dependence upon
Thee, and we beg Thy blessings uponThee, and we beg Thy blessings upon
us, our parents, our teachers, and ourus, our parents, our teachers, and our
Country.” The second case,Country.” The second case, SchoolSchool
District of Abington v. Schempp (1963),District of Abington v. Schempp (1963),
involved state laws requiring selectioninvolved state laws requiring selection
and reading of passages from the Bibleand reading of passages from the Bible
and recitation of the Lord’s Prayer. Theand recitation of the Lord’s Prayer. The
Court ruled against the state- endorsedCourt ruled against the state- endorsed
prayers in both cases. Since the stateprayers in both cases. Since the state
had in effect made a law respecting anhad in effect made a law respecting an
establishment of religion in these cases,establishment of religion in these cases,
the Court ruled that the Constitutionthe Court ruled that the Constitution
was violated.was violated.

9. Doe vs. Duncanville ISDDoe vs. Duncanville ISD
• In 1995 the Fifth Circuit ruled in a longIn 1995 the Fifth Circuit ruled in a long
running case involving the Duncanville I.S.D.running case involving the Duncanville I.S.D.
that school districts and their employees maythat school districts and their employees may
not lead, encourage, promote, or participatenot lead, encourage, promote, or participate
in prayers with or among students duringin prayers with or among students during
curricular or extracurricular activities,curricular or extracurricular activities,
including before, during, or after- schoolincluding before, during, or after- school
related sporting events (Doe v. Duncanvillerelated sporting events (Doe v. Duncanville
I.S.D., known as Duncanville II). The appealsI.S.D., known as Duncanville II). The appeals
court rejected the contention that such acourt rejected the contention that such a
restriction denies school employees arestriction denies school employees a
constitutional right to join students in prayerconstitutional right to join students in prayer
activities. Participation by coaches and otheractivities. Participation by coaches and other
school employees would “signal anschool employees would “signal an
unconstitutional endorsement of religion,”unconstitutional endorsement of religion,”
the court noted, since they are representativesthe court noted, since they are representatives
of the school. However, employees are notof the school. However, employees are not
required to leave the room when studentsrequired to leave the room when students
pray on their own, or otherwise treat studentpray on their own, or otherwise treat student
religious beliefs with disrespect. In short thereligious beliefs with disrespect. In short the
law is clear that neither the public school norlaw is clear that neither the public school nor
its employees may sponsor prayer at schoolits employees may sponsor prayer at school
or at extracurricular activities and athleticor at extracurricular activities and athletic
events.events.

10. The Lee Case: Clear Creek ISDThe Lee Case: Clear Creek ISD
• When it decided theWhen it decided the Lee caseLee case, the Supreme, the Supreme
Court returned a somewhat similar case toCourt returned a somewhat similar case to
the Fifth Circuit. In that case the Fifththe Fifth Circuit. In that case the Fifth
Circuit had upheld the Clear Creek I.S.D.Circuit had upheld the Clear Creek I.S.D.
school board’s resolution leaving theschool board’s resolution leaving the
inclusion of invocation and benediction atinclusion of invocation and benediction at
graduation exercises to the discretion ofgraduation exercises to the discretion of
the senior class. Under the resolution, ifthe senior class. Under the resolution, if
the senior class votes in the affirmative,the senior class votes in the affirmative,
then an invocation and benediction can bethen an invocation and benediction can be
given by a student volunteer. T Hegiven by a student volunteer. T He
message must be nonsectarian andmessage must be nonsectarian and
nonproselytizing. The Fifth Circuit pointednonproselytizing. The Fifth Circuit pointed
out that, unlike the disfavoredout that, unlike the disfavored LeeLee
practice, the Clear Creek prayer programpractice, the Clear Creek prayer program
did not implicate school officials in prayerdid not implicate school officials in prayer
decision-making and did not have the samedecision-making and did not have the same
psychologically coercive effect onpsychologically coercive effect on
objecting students. The ruling wasobjecting students. The ruling was
appealed to the U.S. Supreme Court,appealed to the U.S. Supreme Court,
which refused to hear it in June of 1993,which refused to hear it in June of 1993,
thus leaving the Fifth Circuit decisionthus leaving the Fifth Circuit decision
standing.standing.

11. Overall ConclusionOverall Conclusion
• Both the federal courts and the TexasBoth the federal courts and the Texas
Education Code recognize thatEducation Code recognize that
students can engage in personalstudents can engage in personal
prayer at school and at school-prayer at school and at school-
sponsored extracurricular and athleticsponsored extracurricular and athletic
events separate and apart from schoolevents separate and apart from school
involvement. Ininvolvement. In Doe v. DuncanvilleDoe v. Duncanville
I.S.D. I,I.S.D. I, the trial court pointed out thatthe trial court pointed out that
“Students may voluntarily pray“Students may voluntarily pray
together, provided such prayer is nottogether, provided such prayer is not
done with school participation.” Thedone with school participation.” The
judge added, “Athletes may prayjudge added, “Athletes may pray
before or after the games, but again ,before or after the games, but again ,
the activity must not suggest thatthe activity must not suggest that
school officials are sponsoring orschool officials are sponsoring or
participating in the prayer in anyparticipating in the prayer in any
manner.” The Fifth Circuit affirmedmanner.” The Fifth Circuit affirmed
the decision. TEC 25.901 declaresthe decision. TEC 25.901 declares
that a public school student has anthat a public school student has an
“absolute right” to pray or meditate in“absolute right” to pray or meditate in
school in a nondisruptive manner.school in a nondisruptive manner.

12. CreditsCredits
““Prayer in Schools”Prayer in Schools”
• Course ADMIN: 5023/ Prairie View A&M UniversityCourse ADMIN: 5023/ Prairie View A&M University
• Professor: Dr. PetterwayProfessor: Dr. Petterway
• By: Lelia JonesBy: Lelia Jones
SourcesSources
http://www.cleffpublishing.com/articles/jj122902.htmhttp://www.cleffpublishing.com/articles/jj122902.htm
http://www.infidels.org/library/modern/church-http://www.infidels.org/library/modern/church-
state/prayer.htmlstate/prayer.html