Case Summary and Outcome

The U.S. Supreme Court found that a New York state law violated the Establishment Clause of the First Amendment by creating a school district for a religious community. The law in question created a school district for Kiryas Joel, a Satmar Hasidic Jewish neighborhood in Monroe, New York, in order to enable students with special needs to access government services without leaving their community. The Court found the law unconstitutional because its case-specific nature did not assure other religious or irreligious communities that they would receive their own districts, and because the law surpassed existing permissible accommodations for religious communities.

Facts

In the 1960s, a small community of orthodox Satmar Hasidic Jews purchased and established a village on 320 acres of undeveloped land near Monroe, New York, which eventually became the village known as Kiryas Joel. The Satmar residents of Kiryas Joel are extremely religious. The Satmars require special dress, have rules regarding the behavior of different genders, admonish television and radio, ground youth education in the Torah, and reject much of modern society, including many modern technologies.

To resolve a zoning dispute that emerged as the town of Monroe grew to encompass Kiryas Joel, and in order to comply with a state law requirement that services be provided by the government for students with special needs (e.g. developmentally disabled students), the state of New York passed a law (Chapter 748) which established that the village of Kiryas Joel “constituted a separate school district…and shall have and enjoy all the powers and duties of a union free school district.” Accordingly, rather than requiring Satmar children to leave their community allegedly to traumatic effect, public funds could be used to provide services to students with special needs within the village of Kiryas Joel.

Several months before Chapter 748 went into effect, the New York State School Boards Association and two of its officers, Grumet and Hawk, brought this action against the State Education Department and various state officials alleging that the New York law violated the Establishment Clause of the First Amendment to the U.S. Constitution. After the New York Supreme Court invalidated the Chapter 748, Kiryas Joel appealed through the federal courts until reaching the current decision issued by the U.S. Supreme Court.

Decision Overview

Justice Souter wrote the Opinion for the U.S. Supreme Court’s 6-3 majority.