The landmark Supreme Court case Lemon v Kurtzman established crucial precedent for interpreting the First Amendment's Establishment Clause and separation of church and state. The 1971 case challenged Pennsylvania and Rhode Island state laws that provided financial support to private religious schools.
Chief Justice Warren Burger delivered the majority opinion in Lemon v Kurtzman, creating the influential three-part "Lemon test" for determining if government actions violate the Establishment Clause. This test requires that laws must: 1) Have a secular legislative purpose, 2) Neither advance nor inhibit religion as their primary effect, and 3) Not foster excessive government entanglement with religion. The Court ruled that both states' programs violated the third prong by creating too much entanglement between government and religious institutions through monitoring requirements and direct funding. This case remains foundational for civil liberties jurisprudence regarding religious freedom and church-state separation.
The background of the case centered on Pennsylvania's Nonpublic Elementary and Secondary Education Act, which reimbursed private schools for teacher salaries and materials in secular subjects, and Rhode Island's similar program providing salary supplements to private school teachers. Alton Lemon and other taxpayers challenged these laws as unconstitutional government support of religion, since most participating schools were Catholic. While the states argued these programs served valid secular educational purposes, the Supreme Court's ruling established that even indirect aid to religious schools could violate the First Amendment if it required extensive government oversight. Though parts of the Lemon test have faced criticism and refinement in subsequent cases, its core principles continue to influence how courts evaluate civil liberties questions involving government interaction with religious institutions in areas like education funding, religious displays, and faith-based programs.
