Wednesday, November 6, 2013

Locke v. Davey case brief

Locke v. Davey case brief summary
540 U.S. 714 (2004)

CASE SYNOPSIS
Respondent student sued petitioner officials of the State of Washington under 42 U.S.C.S. § 1983, alleging that the State's prohibition of educational assistance for the pursuit of a theology degree violated the student's right to free exercise of religion. Upon the grant of a writ of certiorari, the officials appealed the judgment of the United States Court of Appeals for the Ninth Circuit which held that the prohibition was unconstitutional.

CASE FACTS
The prohibition against using State scholarship funds to pursue a theology degree codified the Washington Constitution's express prohibition against appropriating State funds for religious instruction. The student, who otherwise qualified for State educational assistance, argued that the scholarship program unconstitutionally singled out religion for unfavorable treatment without being narrowly tailored to achieve a compelling state interest.


DISCUSSION

  • The United States Supreme Court held that, while the federal constitution did not preclude the election of religious instruction using government assistance, the State's broader prohibition reflected its substantial interest against the establishment of religion by funding devotional degrees, and the prohibition was not violative of the federal constitution since the exclusion of such funding placed a relatively minor burden on the student. 
  • That the State dealt differently with education for the ministry than with education for other callings was not evidence of hostility toward religion, especially since the scholarship program did not prohibit attendance at religious institutions or a curriculum which included devotional theology courses.
CONCLUSION
The judgment, that the prohibition against the use of State funds to pursue a theology degree was unconstitutional, was reversed.

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