Board of Education of Kiryas Joel Village School District v. Grumet

Closed Mixed Outcome

Key Details

  • Mode of Expression
    Non-verbal Expression
  • Date of Decision
    June 27, 1994
  • Outcome
    Decision - Procedural Outcome, Affirmed Lower Court, Decision Outcome (Disposition/Ruling), Law or Action Overturned or Deemed Unconstitutional
  • Case Number
    No. 93–517
  • Region & Country
    United States, North America
  • Judicial Body
    Supreme (court of final appeal)
  • Type of Law
    Constitutional Law
  • Themes
    Religious Expression
  • Tags
    Establishment Clause, Religion

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Case Analysis

Case Summary and Outcome

The U.S. Supreme Court upheld state appellate court rulings that a New York law that drew lines around a school zone to enclose a Satmar Hasidic Jewish neighborhood, Kiryas Joel, was an unconstitutional violation of the Establishment Clause because the law impermissibly ‘advanced’ religion, and therefore, failed the second prong of the Establishment test set out in Lemon v. Kurtzman.

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. The New York Supreme Court invalidated the law and Kiryas Joel appealed through the federal courts reaching the U.S. Supreme Court.

The Court reasoned that the relevant law, Chapter 748 of the New York Laws of 1989, violated the Establishment Clause for two main reasons. Firstly, this was a case-specific creation of a district for a religious community and there was no assurance that the next religious community seeking a school district of its own would receive one so the Court had no means of reviewing whether the government was preferring one religion to another, or religion to irreligion and the law therefore had the effect of advancing religion. Secondly, the Court found that although the Constitution allows states to accommodate religious needs by alleviating special burdens, Chapter 748 crossed the line from permissible accommodation to impermissible establishment because there were several alternatives for providing bilingual and bicultural special education to Satmar children that did not implicate the Establishment Clause.

 


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.

The Court found that New York’s Chapter 748 violated the Establishment Clause of the First Amendment for two primary reasons. First, there was no assurance that the next religious community seeking a school district of its own would receive one. The case-specific creation of this district for a religious community left the Court without any way to review whether the government was preferring one religion to another, or religion to irreligion, and the historical context did not warrant special treatment. Thus, Chapter 748 had the effect of advancing religion.

Second, the Court found that although the Constitution allows states to accommodate religious needs by alleviating special burdens, Chapter 748 crossed the line from permissible accommodation to impermissible establishment because there were several alternatives for providing bilingual and bicultural special education to Satmar children that did not implicate the Establishment Clause.

Accordingly, because New York’s Chapter 748 advanced the Satmar religion, and because the advancement reached beyond the realm of “permissible accommodation” due to the availability of ready alternatives, the Court found that Chapter 748 violated the Establishment Clause of the First Amendment to the U.S. Constitution.


Decision Direction

Quick Info

Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.

Mixed Outcome

This case has a mixed outcome concerning religious expression. On the one hand, this case could be understood as enhancing religious expression by disentangling government from religious establishment. On the other hand, this case could be understood as suppressing the Satmar community’s ability to express its faith by sending children of the community to schools of the parents’ choosing.

Global Perspective

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Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.

National standards, law or jurisprudence

  • U.S., Const. amend. I
  • U.S., Const. amend. XIV
  • U.S., Larkin v. Grendel's Den, Inc. 459 U.S. 116 (1982)
  • U.S., Shaw v. Reno, 509 U. S. 630 (1993)
  • U.S., Lemon v. Kurtzman, 403 U.S. 602, 619 (1971)
  • U.S., Committee for Public Education v. Nyquist 413 U.S. 756 (1973)
  • U.S. Epperson v. Arkansas 393 U.S. 97 (1968)
  • U.S., Dist. of Abington Twp., Pa. v. Schempp, 374 U.S. 203 (1963)
  • U.S., Wolman v. Walter, 433 U. S. 229 (1977)
  • U.S., Cnty. of Allegheny v. Am. Civil Liberties Union Greater Pittsburgh Chapter, 492 U.S. 573 (1989)
  • U.S., Everson v Board of Education, 330 U.S. 1 (1947)
  • U.S., McDaniel v. Paty, 435 U. S. 618 (1978)
  • U.S., Church of Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993)
  • U.S., Gomillion v. Lightfoot, 364 U.S. 339 (1960)
  • U.S., Wallace v. Jaffree 472 U.S. 38 (1985)
  • U.S., Bowen v. Kendrick 487 U.S. 589 (1988)
  • U.S., Corp. of Presiding Bishop v. Amos 483 U.S. 327 (1987)
  • U.S., Hobbie v. Unemployment Appeals Comm 'n, 480 U.S. 136 (1987)
  • U.S., Zorach v. Clauson 343 U.S. 306 (1952)
  • U.S., Grand Rapids Sch. Dist. v. Ball 473 U.S. 373 (1985)
  • U.S., Aguilar v. Felton 473 U.S. 402 (1985)
  • U.S., Torcaso v. Watkins, 367 U.S. 488 (1961).
  • U.S., Olsen v. Drug Enforcement Admin., 878 F. 2d 1458, 1461 (CADC 1989)
  • U.S., Walz v. Tax Comm'n of City of New York 397 U.S. 664 (1970)
  • U.S., Texas Monthly, Inc. v. Bullock 489 U.S. 1 (1989)
  • U.S., Estate of Thornton v. Caldor, Inc., 472 U. S. 703, 711 (1985)
  • U.S., Witters v. Washington Dept. of Servs. for Blind, 474 U. S. 481 (1986)
  • U.S., Larson v. Valente, 456 U.S. 228 (1982)
  • U.S., Lee v. Weisman, 505 U.S. 577, (1992)
  • U.S., Wolman v. Walter, 433 U. S. 229 (1977)
  • U.S., Welsh v. United States 398 U.S. 333 (1970)
  • U.S., Employment Div. v. Smith 494 U.S. 872 (1990)
  • U.S., Gillette v. United States, 401 U. S. 437, 401 U. S. 453 (1971)
  • U.S., United States v. Seeger 380 U.S. 163 (1965)
  • U.S., Lamb's Chapel v. Center Moriches Union Free School District, 508 U.S. 384 (1993)
  • U.S., Zobrest v. Catalina Foothills School Dist. 509 U.S. 1 (1993)
  • U.S., Lynch v. Donnelly, 465 U.S. 668, 693-94 (1984)
  • U.S., Stone v. Graham 449 U.S. 39 (1980)
  • U.S., Serbian Orthodox Diocese v. Milivojevich 426 U.S. 696 (1976)
  • U.S., Clark v. Cmty. for Creative Non-Violence, 468 U.S. 288 (1984)
  • U.S., Mueller v. Allen 463 U.S. 388 (1983)
  • U.S., Olsen v. State of Iowa, 649 F. Supp. 14 (S.D. Iowa 1986)
  • U.S., Califano v. Westcott 443 U.S. 76 (1979)
  • U.S., Widmar v. Vincent, 454 U.S. 263 (1981)
  • U.S., Village of Arlington Heights v. Metro. Hous. Dev. Corp., 429 U.S. 252 (1977)
  • U.S., Kennedy v. Bureau of Narcotics and Dangerous Drugs, 459 F. 2d 415 (CA9 1972)
  • U.S., Edwards v. Aguillard 482 U.S. 578 (1987)

Case Significance

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Case significance refers to how influential the case is and how its significance changes over time.

The decision establishes a binding or persuasive precedent within its jurisdiction.

The U.S. is a common law country; this decision is binding on other cases with similar facts and similar legal issues. Because this is a Supreme Court decision, it is binding on all lower Courts across the U.S.

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