In Wallace v. Jaffree, the Supreme Court held unconstitutional an Alabama statute authorizing a one-minute period of silence in all public schools for meditation or voluntary prayer. The Court applied its test articulated in Lemon v. Kurtzman, which outlines three conditions for the constitutionality of statues related to religion; the first is that the statute must have a secular legislative purpose. After reviewing the legislative history of the Alabama law, the Court concluded that statute was designed to endorse religion and lacked any secular purpose. The legislative record indicated that the purpose of the statute was to return voluntary prayer to public schools. In the face of such clear and unrebutted evidence of a religious purpose, the Court held that the statute violated the Establishment Clause principle that the government must remain neutral toward religion.
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