Engel v. Vitale: Drawing the Line Between State and Religion

By Vincent Rhys DaRin — November 25, 2025

Introduction

In the 1960s, the State of New York passed a law that required public schools to recite the Pledge of Allegiance and a nondenominational prayer at the start of each school day. Students were not required to be a part of the prayer, as they were allowed to excuse themselves if they did not want to participate in it. Steven Engel, a Long Island parent, sued the state in challenge of the law, arguing that it was unconstitutional. He was joined in his case by other parents who also believed the prayer violated their civil liberties.

Timeline of the Case

The Supreme Court heard oral arguments in Engel v. Vitale, 370 U.S. 421 (1962) on April 3, 1962. Engel’s lawyers argued that children are inherently impressionable, and the reading of prayers could impact their beliefs. They claimed that this constituted government influence of the religious beliefs of students, which would go against the Establishment Clause. Additionally, his lawyers argued that excusing nonparticipants is still an Establishment Clause violation. In opposition, Vitale’s lawyers, who represented the state, argued that New York’s actions complied with the Constitution. They emphasized that the prayer is nondenominational and brief. They asserted that the prayer only recognizes the existence of God and was not accompanied by religious discussion afterward. They maintained that any student unwilling to participate is allowed to leave the room, or students can choose to remain quiet if they fear being ridiculed for leaving. Vitale’s lawyers also argued that most citizens in New York approved of prayer within schools, and imposing the minority’s objection on the majority would be unfair.

Decision and Reasoning

The Supreme Court ruled in favor of Engel in a 6–1 decision. Only seven Justices participated in the case, as Justice White and Justice Frankfurter did not take part. Justice Stewart was the sole dissenter. He argued that since the prayer was nondenominational and did not denote a specific religion, it did not violate the Establishment Clause. The remaining six Justices sided against the State of New York, holding that prayer, even voluntary, did violate the Establishment Clause. In the majority opinion, written by Justice Hugo Black, the Court stated that the Establishment Clause prohibited the government from composing prayers for its citizens to read, as religion is not an area for government control. Additionally, the Court felt that since Americans have diverse religious beliefs, any sort of prayer, denominational or not, would be seen as an endorsement of religion by the government. As stated in the majority opinion, “It is no part of the business of government to compose official prayers for any group of the American people to recite as a part of a religious program carried on by government.”

Aftermath of the Decision

Following the decision, school-sponsored prayer was no longer permitted by law. This meant that the school days now began only with the recitation of the Pledge of Allegiance. Many citizens were outraged with the Supreme Court’s ruling, feeling that the Court wanted to remove religious values from their children’s schools. They called for the Supreme Court to reverse its decision, wanting these prayers to return. The Supreme Court maintained its ruling and went on to issue similar decisions in comparable cases. For example, in Abington School District v. Schempp, 374 U.S. 203 (1963), the Court considered the constitutionality of reading the Christian Bible during class in a public school. In the 1960s, Pennsylvania law required classrooms to recite the Pledge of Allegiance followed by a Bible reading. Any student who did not wish to participate could choose not to, similar to the provision challenged in Engel v. Vitale. The Supreme Court ruled this Pennsylvania law unconstitutional, citing the Establishment Clause and relying on precedent from Engel v. Vitale to reach its decision. Today, Engel v. Vitale remains one of the most significant Establishment Clause cases in history, as it was the first case to address religion in public schools and helped to limit government overreach.

Bibliography

  • Engel v. Vitale, 370 U.S. 421 (1962).
  • U.S. Const. amend. I.
  • Oyez, “Engel v. Vitale.”
  • U.S. Courts, “Engel v. Vitale (1962).”
  • New York Civil Liberties Union, “Obituary: Steven Engel.”
  • Constitutional Center, “Engel v. Vitale.”
  • Legal Information Institute, “Engel v. Vitale (1962).”
  • Abington School District v. Schempp, 374 U.S. 203 (1963).