The First Amendment of the U.S. Constitution prohibits the government from establishing religion (the Establishment Clause), which the U.S. Supreme Court has interpreted to include a prohibition on official support or endorsement of religion. It also prohibits the government from interfering with individuals' exercise of religion (the Free Exercise Clause). The balancing of these constitutional provisions often leads to questions regarding the extent to which religious activities may occur at public events or within public institutions. On one hand, it may be argued that permitting prayer as a part of publicly sponsored events or activities suggests official support for religion. On the other hand, restricting religious expressions at events or activities may appear to interfere with individuals' ability to exercise their religious beliefs. The Court has addressed these questions in a variety of contexts and drawn important distinctions regarding the constitutionality of such prayers. In particular, the Court's major decisions have focused on two categories of public prayers: prayer in schools and legislative prayers. Lower courts have considered the constitutionality of publicly sponsored prayers in other contexts, including the military chaplaincy as well as invocations and other religious commemorations at public events. This report will analyze the Court's approach to each of these categories and examine the relevant distinctions used to determine whether a public official or entity may engage in prayer activity or other religious commemorations. The Court's interpretation of the Establishment Clause's prohibition on publicly sponsored prayer arises from the historical roots of the founding of the United States. The Court has noted that the "practice of establishing governmentally composed prayers for religious services was one of the reasons which caused many of our early colonists to leave England and seek religious freedom in America." Accordingly, the Court has held that "the constitutional prohibition against laws respecting an establishment of religion must at least mean that in this country it is no part of the business of government to compose official prayers for any group of the American people to recite as a part of a religious program carried on by government." However, the Court has also recognized the significance of the role of religion in the history of the nation and has upheld some religious messages in selected public contexts. As a general rule, the Court has permitted public displays of religious symbols, including in one case a display of the Ten Commandments, if the display is set in a diversified context. The Court also has allowed privately donated displays of religious messages on public grounds, although these cases were not resolved under the Establishment Clause. Despite the Court's decisions upholding public displays with religious messages, it is important to note that these cases are distinguishable from its public prayer decisions. As a general rule, publicly sponsored prayer is prohibited by the Establishment Clause. Legal challenges to public prayers have arisen most frequently in the context of school prayers, and the U.S. Supreme Court consistently has struck down school policies that implement official acts of prayer in school settings. Supreme Court jurisprudence explains that neither neutrality of a prayer, nor its voluntary nature, can cure the constitutional violation of a publicly adopted prayer program in schools. The Court struck down a New York school district's policy that adopted the following prayer for daily recitation: "Almighty God, we acknowledge our dependence on Thee, and we beg Thy blessings upon us, our parents, our teachers and our Country." Finding "no doubt" that the daily invocation was a religious activity, the Court rejected the school district's justification of the prayer as a nondenominational, voluntary activity. According to the Court, "the Establishment Clause … does not depend upon any showing of direct governmental compulsion and is violated by the enactment of laws which establish an official religion whether those laws operate directly to coerce nonobserving individuals or not." Similarly, the Court struck down Pennsylvania and Maryland state policies that required passages from the Bible be read aloud daily in public schools. The passages were chosen from the Christian Bible and students were permitted to be excused during the exercise. The Court again rejected the voluntary nature of the exercise as a justification of adopting a religious activity under the Establishment Clause. Although students may have been permitted to be excused from the exercise, their attendance at school was required by law and they remained confined to the building in which the activity took place and under the supervision of school employees who participated in the exercise. When considering challenges to school programs that include public prayers, the Court has emphasized the importance of a secular purpose. Programs that clearly indicate an intent to promote prayer in schools do not comport with the Establishment Clause. In 1981, Alabama amended a statute authorizing a moment of silence "for meditation" to authorize a moment of silence "for meditation or voluntary prayer." The sponsor of the legislation stated in the legislative record that the change was intended to return prayer to schools. Because there was no evidence of a secular purpose, the Court held that the legislature's action was unconstitutional, explaining that "the legislative intent to return prayer to the public schools is, of course, quite different from merely protecting every student's right to engage in voluntary prayer during an appropriate moment of silence during the schoolday." The Court has extended the constitutional restrictions on prayer during the school day to other school-related activities, such as graduations and sporting events. Underlying this rule is the Court's understanding that "the Constitution guarantees that government may not coerce anyone to support or participate in religion or its exercise." In Lee v. Weisman , the Court struck down a school's policy to invite local clergy to deliver nonsectarian prayers at school graduation ceremonies because of the state's involvement in the prayer and the coercive effect that the practice would have on students. The Court noted that the school decided whether to have a prayer at the graduation; which religious participant would deliver the prayer; and what the guidelines for the content of the prayer would be. The Court interpreted the school's involvement in each step of this process to mean that the prayer was attributable to the state. According to the Court, the school's actions were unconstitutional regardless of the steps it took to maintain neutrality in the prayer and its delivery. Because of the heightened concerns related to the First Amendment in elementary and secondary schools, the Court has noted that prayer activities in schools "carry a particular risk of indirect coercion." This risk was an underlying factor in the Court's earlier school prayer decisions that involved daily prayers and scripture readings. Just as the Court rejected attempts to justify those activities through their voluntary nature, it likewise rejected arguments that a student's attendance at his or her graduation ceremony was actually voluntary. Noting the social significance of one's graduation, the Court explained that "[a]ttendance may not be required by official decree, yet it is apparent that a student is not free to absent herself from the graduation exercise in any real sense of the term 'voluntary,' for absence would require forfeiture of those intangible benefits which have motivated the student through youth and all her high school years." The pressure on students to conform through attendance at and participation in the ceremony, "though subtle and indirect, can be as real as any overt compulsion." Accordingly, the Court distinguished the legitimacy of other public prayers that it had held constitutional from those offered in school settings "because the State has in every practical sense compelled attendance and participation in an explicit religious exercise at an event of singular importance to every student, one the objecting student had no real alternative to avoid." The Court later considered whether the constitutional restrictions on prayer at school events would extend to prayers at extracurricular football games. A Texas high school adopted a prayer policy that allowed two student elections, which determined, first, whether invocations would be delivered at football games and, second, who would deliver such invocations. Once the students voted to deliver invocations and chose their preferred speaker, that speaker was designated to deliver the invocation at every game for the entire season. The Court distinguished the case from others in which it had upheld government support for religious speech because the school did not open the practice "to indiscriminate use … by the student body generally." The Court explained that "the majoritarian process implemented by the District guarantees … that minority candidates will never prevail and that their views will effectively be silenced." The Court noted that the school's involvement was equally impermissible as in the case of prayer during a graduation ceremony and again rejected the school's justification that it had attempted to include a majority of the audience subjected to the prayer exercise. The Court emphasized the constitutional requirement for a secular purpose, noting that the secular purpose must be sincere and that the history of the school's actions regarding the policy indicated "that the District intended to preserve the practice of prayer before football games." The nature of a high school football game as an extracurricular activity did not resolve the Court's concern that students may feel indirectly coerced to participate. The Court recognized that for some students attendance at a football game may be required for class credit and even for those who attend without any official commitment, attendance at such events is "part of a complete educational experience." Those who disagree with the Court's decisions limiting school prayer have argued that restricting religious activities in schools carries its own risk of violating the First Amendment. These concerns suggest that such restrictions may violate requirements of the Establishment Clause by demonstrating a disapproval or hostility to religion or the requirements of the Free Exercise by interfering with individuals' ability to exercise their beliefs at public events. One of the Court's standards for considering potential Establishment Clause violations requires that government actions are neutral between religions and between religion and non-religion. The Court has explicitly addressed this argument, explaining that the drafters included individuals with "faith in the power of prayer who led the fight for adoption of our Constitution and also for our Bill of Rights with the very guarantees of religious freedom that forbid the sort of governmental activity" that adopts an official prayer. However, according to the Court, "by no means do [the religion clauses] impose a prohibition on all religious activity in our public schools." The restriction is imposed only on the school sponsoring a religious practice, but students remain free to pray voluntarily "at any time before, during, or after the schoolday."