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Zelman v. Simmons-Harris, 536 U.S. 639, 122 S.Ct. 2460, 153 L.Ed.2d 604, 70 USLW 4683, 166 Ed. Law Rep. 30, 02 Cal. Daily Op. Serv. 5788, 2002 Daily Journal D.A.R. 7295, 15 Fla. L. Weekly Fed. S 490

Facts

Ohio's Pilot Project Scholarship Program was enacted to provide educational choices to families in the Cleveland City School District, which was under state control due to poor performance. The program offered tuition aid for students to attend participating public or private schools, with a significant number of private schools being religiously affiliated. In the 1999-2000 school year, 82% of participating private schools had a religious affiliation, and 96% of scholarship recipients enrolled in religious schools. The program aimed to assist low-income families, with financial aid distributed based on need.

Ohio's Pilot Project Scholarship Program gives educational choices to families in any Ohio school district that is under state control pursuant to a federal-court order.

Issue

Does the Ohio Pilot Scholarship Program violate the Establishment Clause of the United States Constitution?

The question presented is whether this program offends the Establishment Clause of the United States Constitution.

Rule

The Establishment Clause prevents a state from enacting laws that have the purpose or effect of advancing or inhibiting religion. A government aid program is not readily subject to challenge under the Establishment Clause if it is neutral with respect to religion and provides assistance directly to a broad class of citizens who, in turn, direct government aid to religious schools as a result of their own genuine and independent private choice.

The Establishment Clause of the First Amendment, applied to the States through the Fourteenth Amendment, prevents a State from enacting laws that have the 'purpose' or 'effect' of advancing or inhibiting religion.

Analysis

The Court found that the Ohio program was neutral toward religion and provided educational assistance to a broad class of individuals without reference to religion. The program allowed parents to choose from various educational options, including religious and nonreligious schools, and did not create financial incentives favoring religious schools. The Court emphasized that the incidental advancement of a religious mission was attributable to individual choices, not government endorsement.

The program here in fact creates financial disincentives for religious schools, with private schools receiving only half the government assistance given to community schools and one-third the assistance given to magnet schools.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the Ohio Pilot Scholarship Program does not offend the Establishment Clause.

Held: The program does not offend the Establishment Clause.

Who won?

The prevailing party was the State of Ohio, as the Supreme Court ruled that the voucher program did not violate the Establishment Clause, emphasizing the program's neutrality and the principle of private choice.

The program is one of true private choice, consistent with the Mueller line of cases, and thus constitutional.

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