Global Freedom of Expression

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 Freedom

Content Attribution Policy

Global Freedom of Expression is an academic initiative and therefore, we encourage you to share and republish excerpts of our content so long as they are not used for commercial purposes and you respect the following policy:

  • Attribute Columbia Global Freedom of Expression as the source.
  • Link to the original URL of the specific case analysis, publication, update, blog or landing page of the down loadable content you are referencing.

Attribution, copyright, and license information for media used by Global Freedom of Expression is available on our Credits page.

Case Analysis

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.



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

Quick Info

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

Table of Authorities

National standards, law or jurisprudence

Case Significance

Quick Info

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.

The decision was cited in:

Official Case Documents

Official Case Documents:

Reports, Analysis, and News Articles:

Have comments?

Let us know if you notice errors or if the case analysis needs revision.

Send Feedback