In Coles v. Cleveland Board of Education, the U.S. Court of Appeals for the Sixth Circuit held unconstitutional the practice of opening school board meetings with prayer. The school board argued that opening their meetings with an invocation was similar to the practice of opening legislative sessions with prayer that the Supreme Court held constitutional in Marsh v. Chambers. However, the court found that, since the board meetings were a crucial part of the public school system and provided a forum for students to raise concerns about their education, the prayers in this case were more like the school prayers the Court held unconstitutional in Engel v. Vitale. To determine whether the prayers violated the Establishment Clause, the court applied the test articulated by the Supreme Court in Lemon v. Kurtzman, which requires that suspect government activity has a secular purpose, and that it neither advances religion nor creates excessive entanglement of church and state. Based on the admissions of school board members, the court found that the purpose of the prayers was purely sectarian. Because the content of the prayers was overtly Christian, with repeated reference to Jesus and the Bible, the court found that the prayers advanced a particular religion. Finally, because the school board decided to include the prayers as part of the meeting and the president of the board often drafted the prayers himself, the practice of opening meetings with prayer created excessive entanglement between church and state. Thus, the practice violated the requirements of the Establishment Clause.
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