• Last updated on November 11, 2022

The Supreme Court held that a Christmas display focusing predominantly on religious symbols violated the establishment clause of the First Amendment.

In Lynch v. Donnelly (1984),[case]Lynch v. Donnelly[Lynch v. Donnelly] the Supreme Court voted five to four to approve a governmentsponsored nativity scene that also included a reindeer, a clown, and a Santa Claus house. The majority found that the display was in conformity with the demands of the three-part Lemon testLemon test[Lemon test] established in Lemon v. Kurtzman[case]Lemon v. Kurtzman[Lemon v. Kurtzman] (1971). Justice Sandra Day O’Connor’Connor, Sandra Day[OConnor, Sandra Day;Lynch v. Donnelly[Lynch v. Donnelly] joined the majority because she concluded that the effect of the display was not to convey a message of either endorsing or disapproving a religion.Religion, establishment ofChurch and state, separation of;Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter[Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter]Religion, establishment of

The Allegheny County case involved two holiday displays located on public property in Pittsburgh. The first was a pious nativity scene without any secular symbols. The judges voted five to four that this display was unconstitutional. Justice Harry A. Blackmun’sBlackmun, Harry A.;Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter[Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter] opinion, which O’Connor joined, was based on the “no endorsement of religion” standard. The same 5-4 majority approved of the second display, a menorah placed next to a Christmas tree. Blackmun asserted that the second display did not promote any religious message. The requirement for including some secular symbols in a seasonal display is sometimes called the “Christmas tree rule.” Justice Anthony M. Kennedy, a dissenter, wanted to rule on the basis of whether there was any “coercion.” The case illustrated the deep divisions of the justices when interpreting the establishment clause.[case]Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter[Allegheny County v. American Civil Liberties Union Greater Pittsburgh Chapter]

Agostini v. Felton

Lemon v. Kurtzman

Lynch v. Donnelly

Religion, establishment of

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