Mitchell v. Helms

530 U.S. 793 (2000)

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Nature of the Case

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Facts

Chapter 2 is a federal program that channels federal funds to local educational agencies (LEA's), which are usually public school districts, via state educational agencies (SEA's), to implement programs to assist children in elementary and secondary schools. The program provides for the acquisition and use of instructional and educational materials, including library services and materials (including media materials), assessments, reference materials, computer software and hardware for instructional use, and other curricular materials.' LEA's and SEA's must offer assistance to both public and private schools (although any private school must be nonprofit). Several restrictions apply to aid to private schools. Most significantly, the 'services, materials, and equipment' provided to private schools must be 'secular, neutral, and nonideological.' Private schools may not acquire control of Chapter 2 funds or title to Chapter 2 materials, equipment, or property. Respondents filed suit in December 1985, alleging that Chapter 2, as applied in Jefferson Parish, violated the Establishment Clause of the First Amendment of the Federal Constitution. The District Court for the Eastern District of Louisiana granted summary judgment in favor of respondents. Under the second part of the three-part test in Lemon v. Kurtzman, the program had the primary effect of advancing religion: The materials and equipment loaned to the Catholic schools were direct aid to those schools and because the Catholic schools were 'pervasively sectarian.' A new judge reversed the decision of the former and upheld Chapter 2. The Court of Appeals for the Fifth Circuit faced a dilemma between the Ninth Circuit's holding and analysis in Walker and the subsequent decisions in Rosenberger and Agostini, and, on the other hand, holdings in Meek and Wolman. The Fifth Circuit abandoned any effort to find coherence in the case law or to divine the future course of decisions and instead focused on particular holdings. The Fifth Circuit concluded that Meek and Wolman controlled, and thus it held Chapter 2 unconstitutional.