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Secular Schools? Religious Practices in New York and Viginia Public Schools Since World War II

Published online by Cambridge University Press:  14 October 2011

Bruce J. Dierenfield
Bruce J. Dierenfield
Affiliation:
Canisius College
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Extract

Scholars examining the controversy over church-state relations in the modern era have concentrated almost exclusively on its constitutional aspects. This is to be expected since the U.S. Supreme Court has handed down epic decisions that have drawn an increasingly sharper picture of the First Amendment's guideline concerning the government's involvement in religion. The Court did, in fact, lead the way in establishing or reestablishing the doctrine called “separation of church and state.” But the Court touched off a furious debate within the states that has intermittently yet persistently influenced public policy since the early 1960s. It is time that scholars examine more closely the participants outside of the Court.

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Articles
Information
Journal of Policy History , Volume 4 , Issue 4 , October 1992 , pp. 361 - 388
Copyright
Copyright © The Pennsylvania State University, University Park, PA. 1992

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References

Notes

1. Sky, Theodore, “The Establishment Clause, The Congress and the Schools: An Historical Perspective,” Virginia Law Review 52 (December 1966): 1395–1466CrossRefGoogle Scholar; Blanshard, Paul, Religion and the Schools: The Great Controversy (Boston, 1963)Google Scholar; Costanzo, Joseph F., This Nation Under God: Church, State, and Schools in America (New York, 1964)Google Scholar; Boles, Donald E., The Bible, Religion, and the Public Schoob (Ames, Iowa, 1965)Google Scholar; Loder, James E., Religion and the Public Schools (New York, 1965)Google Scholar; Muir, William K., Prayer in the Public Schools: Law and Attitude Change (Chicago, 1967)Google Scholar; Swomley, John M., Religion, the State, and the Schools (New York, 1968)Google Scholar; Michaelsen, Robert, Piety in the Public School (New York, 1970)Google Scholar; Dolbeare, Kenneth M. and Hammond, Phillip E., The School Prayer Decision: From Court Policy to Local Practice (Chicago, 1971)Google Scholar; Byrnes, Lawrence, Religion and Public Education (New York, 1975)Google Scholar; McMillan, Richard M., Religion in the Public Schools: An Introduction (Macon, Ga., 1984)Google Scholar; Wood, James E. Jr, Religion and the State: Essays in Honor of Leo Pfeffer (Waco, Tex., 1985).Google Scholar

2. Rauch, Diane, The Great School Wars: A History of the New York City Public Schools (New York, 1988), 3–76Google Scholar; Marty, Martin E., Pilgrims in Their Own Land: 500 Years of Religion in America (Boston, 1984); 403–26Google Scholar; Hudson, Winthrop S., Religion in America (New York, 1981), 379–88.Google Scholar

3. Morgan, Richard E., The Law and Politics of Civil Rights and Liberties (New York, 1985), 171–78Google Scholar; Everson v. Board of Education, 330 U.S. 1 (1947); McCollum v. Board of Education, 333 U.S. 203 (1948).

4. National Council of Churches, Churches and Church Membership in the United States, 1952, Series B, nos. 7 and 8 (New York, 1956).Google Scholar

5. “Spiritual Values in Public Schools,” Richmond Times-Dispatch, Sunday Magazine, 21 October 1951, 1.

6. Ibid.; Luther Flynn, “A Study of Moral, Spiritual, and Religious Values in the Public Schools of Virginia,” Ph.D. dissertation, University of Virginia, 1956; “Religious Tones at Class Opening in Area Involved,” Alexandria Gazette, 26 June 1962, 1–2; “Waning of Christian Influence Seen Here,” Richmond News Leader, 22 June 1962, 1,3.

7. “Daily Prayer in All Schools is Urged by State's Regents,” New York Times, 1 December 1951, 1. For a history of religion in New York public schools at the turn of the century, see Hall, Arthur J., Religious Education in the Public Schools of the State and City of New York (Chicago, 1914).Google Scholar

8. Ibid.; “Pastors Endorse School Prayers,” New York Times, 3 December 1951, 21; “School Prayers Backed,” New York Times, 4 December 1951, 35.

9. “Regents’ Prayer Adopted Slowly,” New York Times, 12 October 1952, 38; “Prayer in Schools Opposed,” New York Times, 7 December 1951, 26; “Atom Trip to Moon in Fifty Years is Seen,” New York Times, 8 December 1951, 13; “School Prayer Fought,” New York Times, 10 December 1951, 25; “Regents’ Prayer Is Opposed by Rabbis,” New York Times, 4 January 1952, 12.

10. “Regents’ Prayer Adopted Slowly,” New York Times, 12 October 1952, 38; “Singing ‘America’ in Schools Is Urged as the Opening Prayer,” New York Times, 22 October 1952, 29; “Prayer in School Still State Issue,” New York Times, 3 January 1954, 77; “Teaching Is Urged on Moral Values,” New York Times, 29 March 1955, 31.

11. “Time for Religion,” New York Times, 4 May 1952, IV, 2; “Religious Training, Free Speech,” U.S. News & World Report 32, 9 May 1952, 32; “Religious Ruling Settles Old Issue,” New York Times, 9 May 1952, IV, 9.

12. Morgan, Law and Politics of Civil Rights and Civil Liberties, 171–78; “High Court Weighs School ‘Time-Out,’ “New York Times, 1 February 1952, 15; “High Court Upholds Release of Pupils to Study Religion,” New York Times, 29 May 1952, 1; Sorauf, Frank J., “Zorach v. Clauson: The Impact of a Supreme Court Decision,” American Political Science Review 53 (September 1959): 777–91CrossRefGoogle Scholar; Zorach v. Clausen, 343 U.S. 306 (1952).

13. “High Nine Clarification of Prayer Rule Awaited,” Binghamton Press, 13 October 1962, 4; Richard B. Dierenfield, Religion in American Public Schools, Washington, D.C., 1962, 39–90.

14. “Prayer in School Fought in Court,” New York Times, 25 February 1959, 33; “School Prayers Upheld by Court,” New York Times, 25 August 1959, 33; “School Prayers in State Upheld,” New York Times, 8 July 1961, 1; “U.S. Court to Rule on School Prayer,” New York Times, 5 December 1961, 33; Engel v. Vitak, 370 U.S. 421 (1962); “Supreme Court Outlaws Official School Prayers in Regents Case Decision,” New York Times, 26 June 1962, 1, 16; “Prayer-Fighters Had Court Win,” Utica Observer-Dispatch, 26 June 1962, 2; “Plaintiff Parents ‘Happy,’ “Binghamton Press, 26 June 1962, 1. The Court was not at full strength when the Engel case was decided because Felix Frankfurter had suffered a stroke and retired and Byron White had not heard oral arguments.

15. “Toward the Godless State,” Richmond News Leader, 27 June 1962, 8; “The Supreme Inquisitor,” Richmond News Leader, 12 July 1962, 10; “The Supreme Court?” Alexandria Gazette, 28 June 1962, 4; “School Prayer Policy to Get Broad Restudy,” Charlottesville Daily Progress, 27 June 1962, 4; “No ‘Establishment of Religion,’ “Charlottesville Daily Progress, 30 June 1962, 4; “The Result Could Be Beneficial,” Richmond Afro-American, 21 July 1962, 4; “The End of Prayer in Public Schools,” Rochester Democrat and Chronicle, 26 June 1962, 18; “Reductio ad Absurdum,” Binghamton Press, 28 June 1962, 6; “School Prayer Outlawed by Supreme Court,” Buffalo Courier-Express, 28 June 1962, 18. An exception to New York's acceptance of the Court ruling can be found in “God and the Law,” a vitriolic front-page attack on it in William Randolph Hearst's Albany Times-Union, 27 June 1962.

16. “Cardinal Says Court Rule Frightening,” Buffalo Courier-Express, 28 June 1962, 7; Kenneth Margolis, New York state department of education, telephone interview, 18 November 1987; “Priest Says ‘Secularist’ War Is On,” Buffalo Courier-Express, 29 June 1962, 8; “Eight State School Districts to Defy Court on Prayer,” Binghamton Press, 27 June 1962, 16; “Bishop Scully Sees ‘Hostility to Religion’ in High Court Ruling,” Albany Times-Union, 27 June 1962, 27; “Black Monday,” Binghamton Press, 22 July 1962, 6.

17. “Decision on Prayer Held Misconstrued,” Richmond News Leader, 28 June 1962, 17; “Pastor Analyzes ‘Reverse Ruling,’ “Richmond News Leader, 2 July 1962, 3.

18. “Harrison Scores Decision,” Richmond News Leader, 28 June 1962, 20; “Harrison Deplores Prayer Decision,” Charlottesville Daily Progress, 28 June 1962, 3; “President, Harrison Differ on Prayer Rule,” Alexandria Gazette, 28 June 1962, 1; Public Papers of Nelson A. Rockefeller, Fifty-Third Governor of the State of New York, 1962, 181; “Eight State School Districts to Defy Court on Prayer,” Binghamton Press, 27 June 1962, 16; “Debate Decisions, Rocky Asks,” Binghamton Press, 2 July 1962, 1, 9; “Prayers Possible, Rocky Contends,” Binghamton Press, 20 July 1962, 12; “Rockefeller Likes Idea of Meditation in School,” Albany Times-Union, 31 August 1962, 5.

19. “State to Halt Use of Prayer Immediately,” Buffalo Courier-Express, 26 June 1962, 1, 3; “Obey Ban on Prayer: Regents,” Binghamton Press, 29 June 1962, 1; “Regents Order Compliance, Says ‘Amen’ to Its Prayer,” Albany Times-Union, 30 June 1962, 2; “State Holds No Prayer at All Should Be Recited in Schools,” Binghamton Press, 22 August 1962, 5; “Court Ruling Held Binding as School Prayer Bar,” Albany Times-Union, 23 August 1962, 27; “Court Ban Covers All School Prayers, State Attorney Says,” Binghamton Press, 26 September 1962, 3; “School Disputes Find Him in the Middle,” Binghamton Press, 23 October 1962, 6; Briand, Charles A., “Question Box,” Journal of the New York State School Boards Association 26 (December 1962): 72–77Google Scholar; “Religion and Public Education,” New York Parent-Teacher 42 (September 1963): 34.Google Scholar

20. “Court Forbids Pupil Prayer,” Albany Times-Union, 26 June 1962, 1; “Allen Tells School Officials to Respect Prayer Decision,” Albany Times-Union, 29 June 1962, 2; “Words from Star-Spangled Banner Held Illegal,” Albany Times-Union, 30 August 1962, 1; “A New ‘Prayer Ruling,’“New York State Education 50 (October 1962): 12.Google Scholar

21. “Ban Brings Mixed Reaction in Buffalo,” Buffalo Courier-Express, 26 June 1962, 1,3; “Allen Tells School Officials to Respect Prayer Decision,” Albany Times-Union, 29 June 1962, 2; “Area Schoolmen Still Favor Prayers, But Some May End Them This Fall,” Binghamton Press, 26 June 1962, 21; “Eight State School Districts to Defy Court on Prayer” and “Some TC Schools Use Banned Lord's Prayer,” Binghamton Press, 27 June 1962, 16, 35; “Stop Using Lord's Prayer, State Tells Forks Schools,” Binghamton Press, 21 August 1962, 21; “Forks Prayer Always Illegal, Couper Says,” Binghamton Press, 24 August, 1962, 27; “Four Area School Districts to Halt Prayer,” Binghamton Press, 30 August 1962, 30; “Forks School Officials to Stop Reading Lord's Prayer, Binghamton Press, 4 September 1962, 3; “City Schools Drop School Prayer” and “Forks to Obey Prayer Ruling,” Binghamton Press, 5 September 1962, 5, 28.

22. “Prayers Mark First School Day,” Albany Times-Union, 6 September 1962, 2; “LI Board Backs Bible Readings,” Binghamton Press, 24 October 1962, 62.

23. State Board of Education, Minutes, 16–18 August 1962, 28 June 1963, Richmond, Virginia, 53–62 and 56–64; Williams, Robert F., “Hands More Than Full—Part I,” Virginia Journal of Education 56 (September 1962): 13–14Google Scholar; “The Supreme Court Decisions,” Virginia PTA Bulletin 46 (November 1963): 11Google Scholar; “Devotions,” Virginia PTA Bulletin 48 (March 1965): 4.Google Scholar

24. Richmond School Board, Minutes, 18 June 1962–20 December 1965, 212–400, 1–265; Charlottesville School Board, Minutes, 12 July 1962, 1–7, 11 July 1963, 1–10; Alexandria School Board, Minutes, 18 July 1962, 1–7, 17 July 1963, 1–7, 15 April 1964, 1–12; “Sanger Says City School Will Not Alter Devotionals,” Alexandria Gazette, 27 August 1962, 1; “Fairfax Schools Plan No Changes in Prayers,” Alexandria Gazette, 28 August 1962, 2; “Prayer in Our Schools,” Alexandria Gazette, 31 August 1962, 4; “School Prayer Ruling Effect Here Is Nil,” Richmond News Leader, 26 June 1962, 14; “School Board Reorganized at Orange,” Charlottesville Daily Progress, 10 July 1962, 3; “Bible Reading, Prayers to Follow Old Pattern,” Richmond News Leader, 30 July 1962, 1,3; “Opening Prayer to Be Retained in County Schools,” Alexandria Gazette, 8 August 1962, 2; “Prayer, Scriptures Common in Schools,” Richmond Times-Dispatch, 28 October 1962, 1; “Prayer Ruling to Have Little Effect on State Schools,” Charlottesville Daily Progress, 30 July 1963, 3.

25. Wood, James E., ed., Religion: The State and Education (Waco, Tex., 1984), 31–32Google Scholar; Abington School District v. Schempp, 374 U.S. 203 (1963). Justice Clark borrowed these words from Justice Wiley Rutledge's dissent in the Everson case.

26. “The Lord's Prayer and the Bible,” Alexandria Gazette, 20 June 1963, 4; “The Public's Slow Burn,” Alexandria Gazette, 6 July 1963, 4; “Fastest Growing Religion,” Alexandria Gazette, 10 September 1963, 4.

27. “Schools Plan to Keep Religion Despite Supreme Court Ruling,” Alexandria Gazette, 8 August 1963, 14; “Bootleg School Prayers,” Alexandria Gazette, 25 September 1963, 4; “Dr. Albohm Seeks Attorney's Advice on School Prayer,” Alexandria Gazette, 30 July 1963, 1; “Prayer Exercises in City's Schools Are Discontinued,” Alexandria Gazette, 23 August 1963, 1.

28. “Congress Has Slim Chance to Override Court Decision,” Buffalo News, 18 June 1963, 20; “Local Clerics Split on Court Ruling,” Buffalo Courier-Express, 18 June 1963, 11; “They Say,” Buffalo Courier-Express, 23 June 1963, 28; “Supreme Court, 8 to 1, Prohibits Lord's Prayer and Bible Reading as Public School Requirements,” 19 June 1963, 1; “Freedom of Religion,” New York Times, 19 June 1963, 36; “Stanza of ‘America’ Barred in Schools,” New York Times, 8 August 1963, 17; “Allen Sees Meditation, Hymns Open to School,” Utica Observer-Dispatch, 9 August 1963, 11; “Educator Hits Bible Ritual in Schools,” Buffalo Courier-Express, 19 August 1962, 2; “City Schools End Reading of Bible,” New York Times, 22 August 1963, 29.

29. New York Legislative Record and Index (1964–71), (Albany: Legislative Index Co., 1964–71), 8 January and 18 February 1964, 435, 1289–90; 6 January, 24 February, and 18 March 1965, 509, 731,928; 1, 15, 17, 21–22 Feburary and 21 March 1966, 298, 315, 369, 419, 751, 896; 4 January and 1 February 1967, A26, A106, A141, S80, S202; 3–4, 22–23 January and 5, 14, 20 February 1968, A156, A238, A55O, S82, S103, S185, S246, S324; 8, 13, 22–23, 27 January, 3, 13 February, 20 March, and 15 April 1969, A69, A172, A257, A308, A660, S99, S156, S164, S177, S390, S532; 3, 16 February 1970, A427, A465; 6–7, 12, 26–27 January 1971, A48, A257, A298, S112, S140.

30. “Federal Court Ponders Ouster of an Unconventional Librarian,” New York Times, 28 December 1969, 35; “City Employs New Librarian,” Martinsville Bulletin, 19 May 1970, 1; “Religious Education Class Unconstitutional in Present Form,” Martinsville Bulletin, 24 May 1970, 7; “ACLU, Staunton Clash over Religion in School,” Richmond Times-Dispatch, 3 February 1974, 1, 3; “Localities Giving Up Religion Class Bids,” Richmond Times-Dispatch, 3 September 1974, 1, 3.

31. New York Legislative Record and Index, 17 February 1970, A508, S6O7, 3 February 1971; “Assembly Votes to Allow Silent Prayer in School,” New York Times, 4 February 1971, 70; “State Senate Votes Silent-Prayer Period in Schools,” New York Times, 24 March 1971, 55; “Building Aid Plan Advances in Albany,” New York Times, 4 May 1971, 51. In 1969 James E. Allen, Jr., was appointed by President Richard M. Nixon as the first U.S. Commissioner of Education.

32. Lyn Simon, attorney for the Utica City School District, to author, 13 August 1987.

33. Journal of the House of Delegates, 15 January and 8, 15, 20–21, 23 February 1973, 82, 89, 529, 819, 885, 949, 1066–67; Journal of the Senate, 24 February 1973, 749–50, 785.

34. “Ruling Believed Violated,” Richmond Times-Dispatch, 12 June 1974, 1; “Religious Instruction Said Illegal,” Richmond News Leader, 12 June 1974, 1; “Religion Classes ‘Unconstitutional,’” Richmond Times-Dispatch, 22 August 1974, 1, 3; “Miller Rules Out Religion Classes in Leased Space,” Richmond News Leader, 30 August 1974, 1; “Localities Giving Up Religion Class Bids,” Richmond Times-Dispatch, 3 September 1974, 1; “Albemarle Board Revokes Religious Instruction Permits,” Richmond News Leader, 17 September 1974, 1; “ACLU, Staunton Clash over Religion in School,” Richmond Times-Dispatch, 3 February 1974, 1, 3; “Court Bans City Bible Classes,” Harrisonburg News-Record, 18 March 1975, 2; “Religious Classes Are Banned,” Richmond Times-Dispatch, 18 March 1975, 1; “Schools—Religion Plan Said ‘Finished,’” Richmond News Leader, 18 March 1975, 1; “The WRE Decision” and “Board to Appeal Bible Class Ruling,” Harrisonburg News-Record, 19 March 1975, 6, 17; “High Court Refuses Religious Ed Case,” Harrisonburg News-Record, 20 January 1976, 9; “High Court Skips Harrisonburg Issue,” Richmond Times-Dispatch, 20 January 1976, 1; “Va. Religion Rule Upheld by High Court,” Richmond News Leader, 20 January 1976, 1. Not all of Miller's opinions were upheld by the federal courts. Indeed, the Fourth U.S. Circuit Court and the U.S. Supreme Court affirmed the validity of Harrisonburg's released-time program in 1975 and early 1976. It remains in effect to this day.

35. “Religion Ban Is Termed Rights Issue,” Richmond Times-Dispatch, 31 October 1977, B4; Hammond, Guy B. et al. , “Moral Education—How Far Should We Go?” Virginia Journal of Education 71 (February 1978): 12.Google Scholar

36. Ibid.

37. “Yule Pageant Ban Said Mistake,” Richmond News Leader, 1; Hammond, “Moral Education,” 12.

38. Anti-Defamation League of B'nai B'rith, “Church-State Separation: Recent Trends and Developments,” LAW 6 (Winter 1980): 6–7; “Steins Drop Battle to Shift Ceremony,” Richmond Times-Dispatch, 3 June 1980, 1, 4; “Graduation Plea Heard,” Richmond News Leader, 28 May 1980, 21.

39. “Militant Television Preachers,” New York Times, 21 January 1980, 21; “Religious Fundamentalism and the New Right,” Journal of Church and State 22 (Autumn 1980): 409–21CrossRefGoogle Scholar; “The‘New Christian Right’ in American Politics,” Political Quarterly 53 (April/June 1982): 181–99Google Scholar; Viguerie, Richard A., The New Right: We're Ready to Lead (Falls Church, Va., 1980)Google Scholar; Falwell, Jerry, Listen America! (Garden City, N.Y., 1980)Google Scholar; Webber, Robert, The Moral Majority—Right or Wrong (Westchester, Ill., 1981)Google Scholar; Liebman, Robert C. and Wuthnow, Robert, eds., The New Christian Right: Mobilization and Legitimation (New York, 1983)Google Scholar; Chandler, Ralph Clark, “The New Religious Right: Worshipping a Past That Never Was,” Christianity and Crisis 42 (15 February 1982): 201–29Google Scholar; D'Souza, Dinesh, “Jerry Falwell's Renaissance,” Policy Review (Winter 1984): 34–43Google Scholar; “Prayer: Too Controversial for Election Year Action?” Christianity Today 24 (5 September 1980): 74Google Scholar; Marty, Martin E., “Things Fall Apart,” Christian Century 97 (10–17 September 1980): 863Google Scholar; Howard, M. William, “National Council of the Churches of Christ in the U.S.A.,” Congressional Digest 59 (December 1980): 299–313Google Scholar; “Religion and Politics 1980,” Church and State 33 (October 1980): 9–11Google Scholar; Lipset, S. M. and Raab, Earl, “The Election and the Evangelicals,” Commentary 71 (March 1981): 25–31Google Scholar; Brudney, Jeffrey L. and Copeland, Gary W., “Evangelicals as a Political Force: Reagan and the 1980 Religious Vote,” Social Science Quarterly 65 (December 1984): 1072–79Google Scholar; “Constitutional Amendment on Prayer in School,” Weekly Compilation of Presidential Documents 18 (24 May 1982): 664–65Google Scholar; Menendez, Albert J., “School Prayer Can Hurt,” Church and State 35 (September 1982): 17Google Scholar; New York Times, 7 May 1982; “Message to the Congress Transmitting a Proposed Constitutional Amendment on Prayer in School,” “Remarks at Kansas State University at the Alfred M. Landon Lecture Series on Public Issues,” “Radio Address to the Nation on Prayer,” “Remarks at a Candle-Lighting Ceremony for Prayer in Schools,” “Remarks at a North Carolina Republican Party Rally in Raleigh,” Public Papers of the Presidents: Ronald Reagan, 17 May, 9, 18, 25 September, and 26 October 1982, 647–48, 1122, 1182–83, 1218–19, 1386.

40. “Battle Rages over Religion in the Schools,” Richmond Times-Dispatch, 5 September 1982, 1, 18–19.

41. Ibid., 1; “Hearing to Open on Bible Class Fight,” Richmond Times-Dispatch, 27 June 1983, B1, B3; “Teacher Sees Classes as Coercive,” Richmond Times-Dispatch, 30 June 1983, Al, A5; “Judge in Bible Class Trial Once Argued Similar Case,” Richmond Times-Dispatch, 1 July 1983, B1, B8; “Couple Is Typical, But Not in Bristol,” Richmond Times-Dispatch, 1 July 1983, B1, B4; “Bible Case: Bristol Classes Voided, But Guides Given,” Richmond Times-Dispatch, 31 July 1983, B1, B2; “ACLU Warns Against New Bible Classes,” Richmond Times-Dispatch, 3 August 1983, B1; “Bristol School to Continue Bible Classes,” Virginia Journal of Education (October 1983): 8; “Opponent of Bristol Bible Classes Says Battle Still Not Over,” Richmond News Leader, 11 November 1983, 7; “Board to Decide Fate of Bristol's Bible Classes Today,” Richmond Times-Dispatch, 27 February 1984, B1; “Risk of Suit Kills Bible Classes,” Richmond News Leader, 28 February 1984, B1; “Bristol Schools Shelve Bible Classes,” Virginia Journal of Education (May 1984): 7.

42. “Moments of Silence Legal in Va. Classes,” Richmond News Leader, 23 February 1984, 3.

43. Ibid.; Ben Howerton, interview, Richmond, 2 May 1987.

44. “Moments of Silence: Part of Daily School Routine,” New York Times, 5 November 1983, 30; “High Court Upsets Moment's Silence for Pupil Prayer,” New York Times, 5 June 1984, A1, B5; Margolis interview; Lisa Kowal and Michelle Terragnoli, interviews, Buffalo, New York, 5 October 1987.

45. Zorach v. Clausen, 343 U.S. 306 (1952). For a good journalistic overview of the current controversy over church-state issues, see Nancy Gibbs, “America's Holy War,” Time 9 December 1991, 60–68. A national public opinion poll in 1991 has again reported that more than three-fourths of Americans still favor spoken prayers in the public schools.