Doe v. Elmbrook Sch. Dist., No. 10-2922 (7th Cir. 2012)
Annotate this Case
Plaintiffs alleged that the school district practice of holding high school graduation ceremonies and related events at a Christian church rented for the occasion violated the Establishment Clause of the First Amendment and sought preliminary and permanent injunctions, a declaratory judgment and damages. The district court entered summary judgment in favor of the district. The Seventh Circuit affirmed. On rehearing en banc, the court reversed in part. The public school graduation ceremonies in the sanctuary of a Christian church, violated the Constitution. The court noted that it was not making a broad statement about the propriety of governmental use of church-owned facilities, nor was it criticizing cases permitting governmental use, in the proper context, of certain church-owned facilities. When confronted with an Establishment Clause challenge of this nature, the Supreme Court requires examination of the context in which government interacts with a religious organization. Here, the involvement of minors, the significance of the graduation ceremony, and the conditions of extensive
proselytization prove too much for the district’s actions to withstand the strictures of the Establishment Clause.
This opinion or order relates to an opinion or order originally issued on September 9, 2011.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.