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bullet "[The] Constitution forbids the State to exact religious conformity from a student as the price of attending her own high school graduation." U.S. Supreme Court justice Anthony Kennedy (1992), Lee v. Weisman
bullet "This is nothing but the devil working against Christ. I am a red-blooded American. The Constitution gives me the right to pray anywhere and I shall do it." Citizen of Rocky Grove, PA, at a public meeting about graduation prayers.
bullet "I'm not interested in hearing a prayer said because I believe that it infringes on my right not to pray," Brian Kitchen, graduating student at Penn State Erie, 1997-OCT 1
bullet "People who don't believe in prayer at graduation should keep their opinion to themselves and not bother people who believe in it." Ryan Bowers, sophomore student at Penn State Erie, 1997-OCT 1 

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Graduation prayer and individual beliefs:

Prayer during graduation is a "hot button" subject. People's emotions tend to run high:

bullet Many conservative Christians are furious that the school boards and courts will not allow them to have a prayer freely included in graduation ceremonies. This is a time when a young adult goes through a major life transition. They feel that their God should be acknowledged in public at this important occasion. They strongly object to what they feel are restrictions on their religious freedom.
bullet Many adherents of non-Christian religions are outraged if the Christian majority wants to impose their own religious practices on a religiously diverse public. They object to Christian invocations and benedictions. Prayers may sound blasphemous to them, since the prayers discount even the existence of their own deities.
bullet Some Humanists, Atheists, Agnostics, and other individuals with no affiliation to an organized faith group object to any public religious prayer. They find any prayer at graduation to be offensive. 

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Background material: Students right to pray in public schools:

Student-initiated prayer is allowed in various situations and locations in the public school system. For example:

bullet In school busses. 
bullet At the flag-pole.
bullet In after-hours student religious clubs, if there are any other student-run clubs in the school.
bullet In the school hallways.
bullet In the cafeteria. 
bullet In the classroom before or after scheduled classes.
bullet etc. 

Not only are these permitted, they are actually protected forms of speech under the U.S. Constitution. Students are guaranteed the right to pray, as long as it is not disruptive, and as long as it is not during classroom hours.

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Background material: Prayer in the classroom: 

Prayer is not normally permitted as a scheduled part of classroom activities. That would violate the principle of church-state separation which is has been defined by court interpretations of the 1st Amendment to the U.S. Constitution. The separation principle is extended to public schools as an arm of the government. (An exception may be permitted if, during the school year, a mixture of prayers, statements, etc are delivered, using material derived from a number of different religions and secular sources. To our knowledge, this has never been tried in a school or ruled upon by a court) .

As interpreted by the courts, the First Amendment of the U.S. Constitution requires that public school teachers, principals, and boards be religiously neutral:

bullet They may not promote a particular religion as being superior to any other.
bullet They may not promote religion in general as superior to a secular approach to life.
bullet They may not promote secularism in general as superior to a religious approach to life.
bullet They may not be antagonistic to religion in general or a particular religious belief in particular.
bullet They may not be antagonistic to secularism.
bullet They must neither advance nor inhibit religion.

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Prayer at graduation ceremonies:

With these rules in place with respect to classroom prayer, one would expect that prayer during graduation ceremonies would also be prohibited. However, case law is mixed on this point. Some courts have ruled that prayer at graduation ceremonies deserves special treatment, because they are one-shot events -- a student only experiences it once. Thus, the linkage of church and state would not be repeated as it would be if prayers were given at the beginning of each school day in a classroom. 

More information on court decisions and public reactions.

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Searching for a solution, acceptable to all:

It is possible to compromise on the matter of school prayer. However, it is not an easy task. Passions run very high on these matters. It is difficult to arrange a meeting of religious and secular folk for the purpose of dialog and resolution. Even if such a meeting is held, many attendees probably will not want to budge from their position.

Some alternatives that have been successfully explored are:

bullet Moment of silence: Substitute a moment of silence instead of the prayer. The graduating students and audience can then spend the time in any way that they wish: make a silent prayer, recollect moments from the past, meditate on the possibilities of the future, etc.
bullet Separate religious service: Organize a separate baccalaureate religious service which is separate from the graduation ceremony for those students who wish to have a strong religious content to their graduation process. This could be an inter-denominational service, including students and their friends and family from all Christian faith groups. Alternatively, it could even be an inter-faith ceremony involving prayers and statements from a variety of religions. 2
bullet Multiple prayers and secular statements: Have an time set aside in the program to allow students of all religions to recite a prayer from their faith tradition, and allow students with no religious affiliation to read a statement for the occasion. The audience might hear Christian, Jewish, Muslim, Wiccan and Church of Scientology prayers. They may hear an Atheist, Humanist and Agnostic read a inspirational, secular statements. All of the religions and moral/ethical beliefs of all of the students would be presented. Students and attendees would come away from the service with an appreciation of the diversity of religious and moral beliefs in the community. It could be an educational experience for all. 

St. Columba’s Middle School in New Delhi, India partly followed this path. Their middle school graduation service on 1999-DEC-17 began with a Prayer Service. Verses recited from The Bible, The Bhagwad Geeta, the Koran, and the Guru Granth Sahib. 3 

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Possible ways of circumventing the law:

Mathew D. Staver has proposed a number of ways that might narrowly meet the requirements of court decisions, yet still allow sectarian prayer at a graduation ceremony. 4 First, there would be no mention of an invocation, benediction or other prayer in the printed program. Then one of the following techniques might work:

bullet The organizer could choose a speaker, perhaps a clergyperson, on a secular basis. This could be on the basis of some past contribution to the community (e.g. he was elected volunteer of the year). The speaker would be asked to give an introduction and finale at the ceremony. She/he could decide unilaterally to give an invocation and benediction. 
bullet Proceed as above, except that a valedictorian, salutatorian or any other student participant would be chosen on some secular criteria - e.g. academic accomplishments.
bullet The students could elect a student chaplain, just as they also elect other class officers. The chaplain could be asked to deliver a speech. The chaplain could decide on his own initiative to include a prayer.
bullet The school officials could decide to cancel the regular graduation ceremony. A church, ministerial association, community group or group of parents could then decide to organize a replacement ceremony. They could then design the program with as much religious content as they wished. The parents could then request to use school facilities for what had become a purely community function.

There are a couple of serious problems with all of these methods of circumventing the law:

bullet To inject Christian prayers into a graduation ceremony will cause distress to many non-Christians, and secularists. The ceremony itself will be disrupted, even if it is only due to the students, parents and friends knowing that some people are upset. This violates the Ethic of Reciprocity that forms a part of essentially every religion. In Christianity, this is the Golden Rule: 

Matthew 7:12:  "Therefore all things whatsoever ye would that men should do to you, do ye even so to them." 

bullet Of concern to Christians who want to include prayers in graduation services, "Jesus warned us about practicing our piety before others and told us not to pray on the street corner where we can be seen, but go into our closet and shut the door and pray in secret (Matthew 6:1-6)." 5 More details on public prayer.

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The information above is intended for general educational use only. It is not intended to dispense legal advice. If you are involved in the organization of a public school or college graduation ceremony which is to include a prayer, we strongly recommend that you consult an attorney with some expertise in constitutional law.

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Related essays on this web site:

bullet What the Bible says about public prayer
bullet Separation of church and state issues

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  1. Jodi Hanauer, "Penn State Erie debates prayer at graduation," at:
  2. Charles Haynes, "Finding common ground: Prayer issue mars graduations," First Amendment Center, at: 
  3. "AJCongress says federal appeals court shouldnot have overturned ruling that Florida graduation ceremonies imposed prayers on religious minorities." American Jewish Congress, at:  
  4. M.D. Staver, "Graduation prayers in public schools," at: 
  5. "Shall we pray at graduation." Baptist Joint Committee on Public Affairs, at:

Copyright © 2001 by Ontario Consultants on Religious Tolerance
Originally written: 2001-MAR-6
Latest update: 2001-DEC-2
Author: B.A. Robinson

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