Board of Trustees of Scarsdale v. McCreary facts for kids
Quick facts for kids Board of Trustees of Scarsdale v. McCreary |
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| Argued February 20, 1985 Decided March 27, 1985 |
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| Full case name | Board of Trustees of the Village of Scarsdale, et al. v. Kathleen S. McCreary, et al. |
| Docket nos. | 84-277 |
| Citations | 471 U.S. 83 (more)
105 S. Ct. 1859; 85 L. Ed. 2d 63; 1985 U.S. LEXIS 194
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| Prior history | McCreary v. Stone, 575 F. Supp. 1112 (S.D.N.Y. 1983); 739 F.2d 716 (2d Cir. 1984) |
| Argument | Oral argument |
| Opinion Announcement | Opinion announcement |
| Holding | |
| Judgement of the Court of Appeals for the Second Circuit is affirmed as per an evenly split Court. Due to ambiguity in the lower court's decision, it is unclear whether the Village is obliged to display a privately-sponsored nativity scene on public land or if it may adopt neutral rules permitting the exclusion of the nativity scene. | |
| Court membership | |
| Case opinions | |
| Per curiam. | |
| Powell took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. amend. I | |
Board of Trustees of Scarsdale v. McCreary was an important case decided by the Supreme Court of the United States in 1985. The case was about whether a private group could display a nativity scene (a scene showing the birth of Jesus) on public land during Christmas. The Court had to decide if this display went against the First Amendment of the U.S. Constitution, which talks about the separation of church and state.
Contents
What Happened Before
The Village of Scarsdale in New York had allowed a private group called the Scarsdale Creche Committee to display a creche in a public park since 1957. This happened every year for about two weeks during the Christmas season.
However, in 1981, the Village Board of Trustees stopped allowing the nativity scene. Many residents, especially those who were Jewish, felt it was "unneighborly" and "insensitive" to have a religious display on public land.
The First Lawsuit
In 1983, the Creche Committee and some residents, including Kathleen McCreary, sued the Scarsdale Board of Trustees. They argued that stopping the display went against their free speech and free exercise of religion rights under the First Amendment.
A judge in the U.S. District Court for the Southern District of New York ruled on December 8, 1983. The judge said that displaying the nativity scene on public land was like the government supporting a religion. This is not allowed by the Establishment Clause of the First Amendment, which means the government cannot establish or favor any religion. The judge explained that when a religious symbol is on public land, the land itself seems to be sending a religious message.
The Appeal
The decision was then appealed to a higher court, the United States Court of Appeals for the Second Circuit, in June 1984. This court agreed that the Village stopped the display because of its religious content.
However, the appeals court disagreed with the first judge's conclusion. They said that if the Village had rules that allowed all kinds of displays equally, then allowing the nativity scene might not go against the Establishment Clause. So, the appeals court sent the case back to the lower court to be looked at again.
The Scarsdale Board of Trustees thought this meant they had to allow the nativity scene on public land. Because of this, they decided to appeal the decision to the highest court, the Supreme Court.
The Main Question for the Supreme Court
The big question for the Supreme Court was whether a privately sponsored nativity scene, which is a religious symbol, could be displayed on public land. This involved balancing two important parts of the First Amendment:
- The Establishment Clause: This part says the government cannot establish or favor a religion. It helps create the separation of church and state.
- Free speech and free exercise of religion: These parts protect people's right to express their beliefs and practice their religion.
The Supreme Court's Decision
The Supreme Court heard the case on February 20, 1985, and announced its decision on March 27, 1985.
Justice Powell did not take part in the case because he was recovering from surgery. This meant there were only eight justices, and they were evenly split, meaning four voted one way and four voted the other.
When the Supreme Court is evenly split, the decision of the lower court (in this case, the Court of Appeals) is upheld. This is called a per curiam decision, which means "by the court" and usually indicates a short, unsigned opinion. The Supreme Court decided not to hear the case again later.
Because the Court was split, it was not completely clear from the lower court's decision whether the Village had to allow the nativity scene, or if it could make fair rules that might allow or prevent such displays on public land.
Some justices, like Justice O'Connor, Justice Rehnquist, and Justice White, thought the Village misunderstood the appeals court's decision. They believed the appeals court meant the Village could stop the nativity scene, but only if it did so based on neutral rules that applied to everyone, not just because it was a religious display.
See also
- List of United States Supreme Court cases, volume 471
- Lynch v. Donnelly (1984)
