Agostini v. Felton facts for kids
Quick facts for kids Agostini v. Felton |
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Argued April 15, 1997 Decided June 23, 1997 |
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Full case name | Rachel Agostini et al. v. Betty Louise Felton et al. |
Citations | 521 U.S. 203 (more)
117 S. Ct. 1997; 138 L. Ed. 2d 391
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Prior history | Felton v. Sec'y, U.S. Dep't of Educ., 101 F.3d 1394 (2d Cir. 1996); cert. granted, 519 U.S. 1086 (1997). |
Holding | |
Reverses Aguilar v. Felton in allowing public school teachers to instruct at religious schools, so long as the material was secular and neutral in nature and no "excessive entanglement" between government and religion was apparent. | |
Court membership | |
Case opinions | |
Majority | O'Connor, joined by Rehnquist, Scalia, Kennedy, Thomas |
Dissent | Souter, joined by Stevens, Ginsburg; Breyer (Part II) |
Dissent | Ginsburg, joined by Stevens, Souter, Breyer |
Laws applied | |
Establishment Clause of the U.S. Const. amend. I | |
This case overturned a previous ruling or rulings
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School Dist. of Grand Rapids v. Ball (1985) (in part) Aguilar v. Felton (1985) |
Agostini v. Felton, 521 U.S. 203 (1997), was a very important case decided by the Supreme Court of the United States. In this case, the Court changed its mind from an earlier decision called Aguilar v. Felton (1985). The new ruling said it was okay for public school teachers to teach at religious schools. This was allowed as long as the lessons were not about religion and the government wasn't too involved with the religious school. This case shows how the Supreme Court's ideas about the First Amendment can change over time.
Contents
Helping Students: The Story Behind the Case
What is Title I?
In 1965, the U.S. Congress created a program called Title I. Its main goal was to help all children in the United States get a good education. This was especially true for students from families with lower incomes.
- Title I sends money from the federal government to states.
- States then give this money to local schools.
- The money is used to offer extra help, like tutoring, for students who are struggling.
- These services are for students who might not meet state learning goals.
- It's important that these services are available to all eligible students, whether they go to public or private schools.
- The lessons must be about regular school subjects, not religion.
New York City's Challenge
The Board of Education in New York City wanted to use Title I funds. In some parts of the city, many students went to private schools, and most of these were religious schools.
- To avoid problems with the First Amendment, the Board first tried busing private school students to public schools for extra lessons. This didn't work well.
- Then, they tried letting public school teachers teach inside the private school buildings.
- They set up rules to make sure no religious teaching happened during these lessons. For example, supervisors would make surprise visits. Also, religious items had to be removed from the classroom during Title I lessons.
The Aguilar v. Felton Decision
This plan was reviewed by the Supreme Court in a case called Aguilar v. Felton.
- The Court decided that this plan created too much "entanglement" between the government and religion.
- This meant the plan was not allowed under the First Amendment.
- A lower court then ordered New York City to stop using this plan.
Finding a New Way to Help Students
After the Aguilar decision, New York City had to find a new way to provide Title I services.
- They started spending over $100 million each year to rent buildings and vehicles.
- This money was used to create separate places where public school teachers could teach private school students.
- This huge cost meant less money was left for the actual teaching services.
In 1995, the Board of Education and some parents asked the court to change the Aguilar decision. They argued that other Supreme Court cases since 1985 had weakened the reasons for the Aguilar ruling. They felt it was no longer fair to make them follow that old decision.
- The lower court agreed that the Board was trying the right thing.
- However, the court said it couldn't change the Aguilar decision because it was still the law.
- The case then went up to the Supreme Court. The Supreme Court agreed to hear the case on April 15, 1997.
What Were the Main Arguments?
The people asking for the change (the petitioners) had three main reasons why the Aguilar decision should no longer apply.
- High Costs: They argued that the huge amount of money spent on renting buildings was a big, unexpected problem. They said it was not smart to force them to keep spending so much. The other side (the respondents) argued that these costs were known when Aguilar was first decided.
- Changing Opinions: They said that many Supreme Court Justices had changed their minds about Aguilar. They felt a majority of the Justices now thought Aguilar should be reversed.
- New Court Rulings: They argued that other Supreme Court decisions made after Aguilar had made the legal reasons for Aguilar weaker. They believed Aguilar was no longer based on current law and should be overturned.
The Supreme Court's Decision
On June 23, 1997, Justice Sandra Day O'Connor announced the Supreme Court's decision. Most of the Justices agreed with her.
- Chief Justice William Rehnquist and Justices Antonin Scalia, Clarence Thomas, and Anthony Kennedy agreed with the main decision.
- Justices John Paul Stevens, David Souter, Ruth Bader Ginsburg, and Stephen Breyer disagreed.
The Court's Response to the Arguments
- Costs: The Court agreed with the respondents. They said that the high costs were expected when Aguilar was decided. So, the costs were not a new reason to change the decision.
- Changing Opinions: The Court said that even if some Justices had expressed doubts about Aguilar in other cases, it didn't mean the law itself had changed. A Justice's personal view outside of a formal ruling doesn't change the law.
- New Court Rulings: This was the most important argument for the Court. The Court looked closely at how its ideas about the Establishment Clause had changed since 1985.
Changes in Thinking
The Court noted several important changes in its thinking:
- Public Teachers in Religious Schools: The Court no longer believed that a public teacher teaching in a religious school would automatically teach religious ideas.
- For example, in Zobrest v. Catalina Foothills School Dist., the Court allowed a government-paid interpreter to help a deaf student at a Catholic high school.
- The Court said it was focusing too much on where the teaching happened, rather than what was being taught.
- Government Money and Religious Schools: The Court also changed its view on government money directly helping religious schools.
- As long as the money was given fairly to all students, without the government telling schools how to spend it, it was okay.
- The Court mentioned Witters v. Washington Dept. of Servs. for Blind. In that case, it was okay for the government to give money for job training, even if the person used it for a religious job later. This was because the student made their own choice.
- Symbolic Union: The Court no longer thought that a public teacher in a religious school created a "symbolic union" between church and state.
- The Court argued that if moving students off campus didn't remove this "union," then Title I itself might be impossible.
- The Court also pointed out that Title I is meant to add to a school's lessons, not replace them. This means it's not supposed to fund religious teaching.
The Final Ruling
The Court decided that New York City's program, which was previously found unconstitutional in Aguilar, was now acceptable.
- The help was given based on fair rules, not on religion.
- It was offered to all eligible students, no matter what school they chose.
- The program didn't encourage anyone to change their religious beliefs.
The Supreme Court officially overturned Aguilar. They said that while it's important to stick to past decisions (this is called stare decisis), the Court can change its mind when the law or understanding of the law has changed significantly.
The Court summarized its decision:
New York City's Title I program does not run afoul of any of three primary criteria we currently use to evaluate whether government aid has the effect of advancing religion: it does not result in governmental indoctrination; define its recipients by reference to religion; or create an excessive entanglement. We therefore hold that a federally funded program providing supplemental, remedial instruction to disadvantaged children on a neutral basis is not invalid under the Establishment Clause when such instruction is given on the premises of sectarian schools by government employees pursuant to a program containing safeguards such as those present here. The same considerations that justify this holding require us to conclude that this carefully constrained program also cannot reasonably be viewed as an endorsement of religion.
In the end, the Court sent the case back to the lower court. They told the lower court to cancel its order that stopped the program. Because Aguilar was no longer valid, New York City could now use its original plan to help students.
The Dissenting Opinion
Justice David Souter wrote a dissenting opinion, meaning he disagreed with the majority. Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen Breyer joined him.
- The dissenting Justices felt that the Court should not have overturned a previous decision so easily.
- They believed the case felt more like a re-hearing of Aguilar rather than a new legal process.
- They argued that changing past decisions too often could make the Court seem less stable and fair.
- They felt the ruling went against the idea that the Court should not be influenced by politics.