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Lamb's Chapel v. Center Moriches Union Free School District

Supreme Court of the United States · 1993 · Constitutional Law

Constitutional LawFirst AmendmentFree SpeechReligious SpeechPublic ForumFree Speech Clauseviewpoint discriminationnonpublic forum

Facts

New York Education Law § 414 authorized certain after-hours uses of school property, and the Center Moriches school district adopted rules permitting social, civic, and recreational uses but barring use by any group for religious purposes. Lamb's Chapel twice applied to use school facilities to show a six-part film series featuring Dr. James Dobson on family and child-rearing issues, described as presenting traditional Christian family values and as a family-oriented movie from a Christian perspective. The district denied both applications because the film appeared to be church related. The church challenged the denial under the First Amendment and the Fourteenth Amendment.

Issue

Whether a school district violates the Free Speech Clause by denying a church access to school premises to show a film series on family and child-rearing issues solely because the presentation addresses that otherwise permitted subject from a religious standpoint. The case also required the Court to consider whether allowing the use would create an Establishment Clause problem sufficient to justify the exclusion.

Rule

Even in a nonpublic forum, the government may control access based on subject matter and speaker identity only if the distinctions are reasonable in light of the forum's purpose and are viewpoint neutral. The government violates the First Amendment when it denies access to a speaker solely to suppress the point of view the speaker espouses on an otherwise includible subject, and excluding religious perspectives on a permitted topic is viewpoint discrimination.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A public middle school in Columbus, Ohio, allows community groups to rent classrooms after hours for programs on financial literacy, neighborhood safety, and parenting. Grace Harbor Fellowship applies to show a seminar on parenting teenagers from a Christian perspective, but the school denies the request because its facilities may not be used for presentations with a religious viewpoint.

If the school otherwise permits programs on parenting, is the denial most likely constitutional?

Explanation. Even assuming the school has created only a nonpublic or limited forum, restrictions must be reasonable and viewpoint neutral. When the forum is open to discussion of parenting, the government may not exclude a speaker solely because the speaker addresses that permitted subject from a religious standpoint. The defect is viewpoint discrimination, not the mere fact that the speaker is religious.