In an earlier decision, Lamb’s Chapel v. Center Moriches Union Free School District[c]Lamb’s Chapel v. Center Moriches Union Free School District[Lambs Chapel v. Center Moriches Union Free School District] (1993), the Supreme Court had held that public high school property must be open to groups with religious messages so long as they could be used by other groups. Since the Lamb’s Chapel case had involved an adult activity during evening hours, the Court had not addressed whether the same analysis would apply to activities involving young children as soon as the regular school day ends. When a school district of upstate New York followed a policy of not allowing “quintessentially religious” subjects to be taught in elementary school buildings, an evangelical Christian organization for young boys and girls, the Good News Club, sued the district in federal court. The appeals court in Manhattan ruled in favor of the district, emphasizing the special susceptibility of young children to indoctrination.

Reversing the lower court’s ruling by a 6-3 vote, the Supreme Court reaffirmed that the expression of religious viewpoints is protected by the First Amendment against discrimination on school property. Writing for the majority, Justice Clarence ThomasThomas, Clarence;Good News Club v. Milford Central School relied on the Court’s well-established neutrality principle, and he argued that the danger that young children might misperceive an open-door policy as an endorsement of religion was no greater “that they might perceive a hostility toward the religious viewpoint if the club were excluded from the public forum.” With Justice Stephen BreyerBreyer, Stephen G.;Good News Club v. Milford Central School writing an equivocal concurring opinion, five members of the Court appeared not to make any distinctions among religious speech, worship services, and recruitment activities.

Breyer, Stephen G.

Religion, establishment of

Religion, freedom of

Thomas, Clarence