The proper role of prayer in public schools is a divisive issue that continually challenges our courts to rethink the meaning of the First Amendment. The Supreme Court has offered some guidance to school officials and lower courts, but many open questions still remain. This note analyzes whether student-led, student-initiated prayer at public school graduation ceremonies is constitutional. Drawing on the Supreme Court\'s various Establishment Clause Tests and Santa Fe Independent School District v. Doe, the recent Supreme Court decision evaluating student-led prayer at a public school football game, the author concludes that two representative school policies addressing student-led, student-initiated prayer at graduation are unconstitutional. The author makes two suggestions to schools and students about how a student may deliver a religious message at a graduation ceremony without offending the Constitution.
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