Coach's Pregame Prayer by wawooten

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									The Real Travesty of Religion and Public School Athletics: the coach’s PreGame Prayer
Beginning in August at the start of the public school year, only one thing dominates the mind of the majority of students and citizens across the United States- football. Whether it is middle school football on Tuesday nights, high school football on Friday nights, or college football on Saturdays, young boys and girls prepare and participate in the cultural phenomenon as players, cheerleaders, band members, color guard, flag bearers, baton twirlers, avid fans, concession stand workers, ticket sellers, etc. Some have even said that football (high school football in small towns in particular) has become an impromptu religion of sorts.1 Football players, coaches, and the other group members above have traditionally invoked prayer and religion into the game for various reasons, such as to protect them from sustaining injuries due to football’s violent nature, to further the team spirit of football (“Sacrificing” one’s body for the game and his/her teammates), to “solemnize the event, to promote good sportsmanship,”2 to promote “clean competition, individual’s challenge to be ones’ best,”3 and to “satisfy the genuine, good faith wishes of a majority of the citizens”4 who believe in a particular religion. Considering that most of these football games are between public schools that receive federal government funding and must abide by the Constitution, an Establishment Clause conflict arises concerning the separation of church (religion/ prayer) and state (the school’s athletic teams, groups, and associated personnel). The majority of the various First Amendment violations regarding religion and prayer in public school athletics have focused on the pre-game invocation given before an athletic competition.5 In Sante Fe Independent School District v. Doe, the Supreme Court struck down the school system’s policy allowing a student-led invocation given before the high school football game since the student’s public speech took place on government-owned property over

the government’s loudspeaker at a school-sponsored event.6 The school system’s policy was an Establishment Clause violation of the First Amendment, for in reality, the student’s speech is perceived as an actual endorsement of the student’s religion by a state-sponsored entity.7 Similarly, a public high school’s tradition of allowing the random selection of various preachers, rabbis, priests, monks, etc. to give the pre-game invocation was considered an Establishment Clause violation due to the excessive government entanglement with religion and the school’s intention to advance religion.8 Unfortunately, a much greater Constitutional travesty occurs every school day in public school athletics across the nation. The Supreme Court has addressed and set binding precedent to stop the pre-football game invocation that occurs once a week during the fall semester of public schools.9 As of today however, the Supreme Court has not chosen to address the potential Establishment Clause violation that occurs when a coach, as a state actor, imposes his/her view of religion by leading, participating, and/or requiring pre, during, and/or post game prayer of his team of student-athletes. On all levels of public school athletics from middle school to high school to universities, impressionable students are required to participate in prayer and other overtly religious activities at the behest of the coach, for the players do not want to risk losing playing time, “create [any] dissension” on their team, or receive negative retaliation and harassment from teammates and coaching staff.10 Considering that most student-athletes spend more time with their coaches (2-3 hours a day on average) than they will with any teacher (an hour a day on average), coach-inflicted religious coercion is potentially a daily First Amendment violation that has yet to garner the deserved attention of the country and the highest court.


Establishment Clause Analysis/ Test The coach’s actions are a potential violation of the First Amendment’s Establishment Clause that states, “Congress shall make no law respecting an establishment of religion.”11 The Establishment Clause is applied to the states (the public school system is controlled by the state legislature) via the Fourteenth Amendment.12 To determine whether a state commits an Establishment Clause violation, the potential violation must pass the three-prong test expressed in Lemon v. Kurtzman.13 The three parts of the Lemon test are as follows: “First, the statute [or practice] must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion; finally, the statute must not foster 'an excessive government entanglement with religion.’”14 In other words, the state school system “cannot coerce anyone to support or participate in religion or its exercise . . . or act in a way that established a [state] religion or religious faith, or tends to do so.”15 Even though the Supreme Court has not undertaken a student’s case against a public school coach, two relatively recent cases have been tried at the circuit and district court levels on this issue. In Doe v. Duncanville Independent School District, a middle school basketball coach required a seventh grade female student-athlete (along with her team) to recite the Lord’s Prayer before and after practice, games, and bus rides.16 The Texas Appaelate’s Court found that the school district and its coach, as a state actor, were in violation of all three prongs of the Lemon Test. As a defense, the school system claimed it was “accommodating religion in a constitutionally permissible manner” by allowing a “limited public forum” that allowed equal access for student groups to use school facilities.17 The Fifth Circuit Court of Appeals easily differentiated this claim from the Board of Educ. of Westside Community Sch. v. Mergens case since the Doe student played on a school-sponsored team, and the prayer was initiated by the


coach and not by a student or student group.18 The coach also brought up his First Amendment rights of free speech, association, and free exercise, but “the principal that government may accommodate the free exercise of religion does not supersede the fundamental limitations imposed by the Establishment Clause.”19 Along the same lines, two Jewish cheerleaders at the University of Georgia informed their athletic director that their Cheerleading Coach was using her powerful position to promote the adoption of Christian religion practices and to treat non-Christians unfavorably.20 After a warning letter from the athletic administration that stated, “no more religious overtones in your program … including bible studies [and] prayers on the list server,” the Coach read a prepared statement to the cheerleading squad that was totally inappropriate, harshly singled out the Jewish cheerleader by name, made reference to the “greater good,” and claimed her innocence. 21 Consequently, she was fired and brought suit against the University’s Athletic Association and each administrator personally.22 She lost her case against the school (the student was protected), but her unsuccessful claims for the free exercise of religion, freedom of speech, and the equal protection clause provide informative analysis of a university coach’s rights.23 The school’s letter did not offend her rights to the free exercise of religion.24 She had permission to carry on her bible studies on campus and use school space to conduct those meetings; the school only “mandated the disentanglement of [Georgia Cheerleading Coach] Braswell’s religious activities and the University’s cheerleading program.”25 The free speech claim was dismissed for basically the same reasons since the school’s letter only asked for her to curb her speech while acting in her official capacity as a state actor.26 Lastly, Braswell claimed an equal protection violation since the Georgia head football coach, Mark Richt, supposedly “engaged in similar conduct.”27 Unfortunately, the cheerleading coach could not prove this


claim, and no male employee was in the same situation as her at the time for vis-à-vis analysis.28 Braswell’s downfall was the unlucky situation that “the university’s interest in curbing such conduct is “most obvious when student’s complaints suggest apparent coercion.”29 Coach’s Rights As mentioned earlier, public school coaches do have First Amendment rights as well as certain responsibilities and duties during their employment tenure.30 As employees of the state, and therefore the government, coaches are considered agents of the state and should be aware of the added responsibility of being a state actor (just like a politician, a teacher, or a government employee).31 Even if coaches are not paid (volunteer coaches) or are not employees of the state, they are still held to the same high accountability standard as all other state actors.32 The coach’s responsibilities include, but are not limited to, teaching his players the fundamentals of the game, keeping his players as safe as possible “ promoting the welfare of the sport in an honorable way, and instilling in the player a desire to win.”33 Also, a coach, especially if he wants to keep his job in today’s market of “winning at all costs”, should also consider winning a high priority/ responsibility. In order to fulfill her duties and meet the high standard imposed on state actors, a coach needs to maintain control over his players and their actions. Even though coaching styles vary drastically, one fundamental element of any successful coach’s repertoire is the ability to have obedient players. Coaches acquire this obedience in their roles as dictators, mentors, father/ mother parental figures, and friends.34 Coaches do demand a lot of authority, but they must remember that coaching is not a “constitutionally protected activity.”35 A coach’s strongest claims for invoking prayer in his athletic program is his Constitutional right to free speech and freedom of expression. The coaches will claim that, “the


state in general . . . is [not] free to prohibit any kind of expression because it does not like what is being said.”36 However, the state’s Establishment Clause violation will almost always override an individual’s interest as long as the state’s interest is reasonable and just.37 For instance, if a coach were to institute a “no pray/ no play” policy, a constitutional violation would seem to occur according to the Lemon Test.38 This philosophy was actually adopted by the head football coach at Memphis State University in Tennessee, and the football players rebelled. Sadly, the policy did not come to light for some months since "it is clear that personnel on athletic scholarships are not going to complain."39 Luckily, the Tennessee legislature had passed an ordinance that contained the following clause: “nothing contained in this section shall authorize any teacher or school authority to prescribe the form or content of any prayer.”40 This clause allowed the university to put a stop to the coach’s potential constitutional violation without subjecting the school to litigation as in the Georgia cheerleader case.41 However, if one or more students would have brought suit against the coach and the university, the “no pray, no play” policy would likely be held to violate all three prongs of the Lemon Test.42 First, the coach’s practice does not have a secular purpose since his goal is to have all Christian players by requiring prayer before playing time - a very persuasive tactic because all athletes want to play.43 Second, the primary effect of this practice is to advance the Christian religion by requiring athletes to pray against their will.44 Third, the coach’s prayer requirement causes excessive government entanglement because the coach is a state actor who is requiring prayer at a “regularly-scheduled, school-sponsored function conducted on school property.”45 The “no pray, no play” philosophy seems to be an automatic violation of the Establishment Clause from all angles.


Equal Access In Braswell and Doe, both Establishment Clause perpetrators tried to take advantage of the loophole provided by Board of Education of Westside Community Schools v. Mergens and used by many religious groups across the nation to develop a presence on public school campuses.46 The Mergens’ “limited open forum” provides equal access to school facilities and resources for all “non-curriculum related” groups on campus.47 Other requirements for the “limited public forum” include limiting the teacher or state actor’s role to a “custodial capacity merely to ensure order and good behavior” and requiring the religious activity to occur during “non-instructional” time.48 One can see the possibility of allowing a coach to offer different preachers, rabbis, gurus, etc. the opportunity to say a pre-game prayer as long as he provides all religions an equal opportunity to be represented.49 This hypothetical situation seems to be facially safe from an Establishment Clause violation viewpoint, but a closer examination provides numerous reasons for concern. First, the prayer must be student-initiated and without the coach’s participation. The coach can only oversee the prayer; he must act in a “non-participatory capacity, ensure[ing] good order and behavior.”50 Next, many public schools now allow students the ability to receive school credit, scholarships, and engage in athletic participation during the school day. Any school allowing any of the above examples would be in violation of the “non-instructional” time or “non-curriculum related” group requirements.51 Lastly, Justice O’Conner warns the state to be wary of “indirect school sponsorship of peer pressure” as student-initiated prayer in a nonvoluntary group or school-sponsored activity (school sports now predominantly fall into these categories) may be overbearing on a student athlete of a religious minority.52


In addition to the concerns mentioned above, the coach’s equal access policy will also have potential problems passing the Lemon Test.53 If it is coach-initiated or has any religiousbased purpose, the policy will fail the first part of the Lemon Test.54 For example in Jager v. Douglas County Sch. Dist, a Native American student band member had no problem with a secular pre-game invocation (and we assume neither would the court) as the student respected the “longstanding custom and tradition [and the need] to add a solemn and dignified tone . . . to remind the spectators and players of the importance of sportsmanship and good play.”55 He only took issue with the religious component of the prayer that “followed the good faith wishes of a majority of the citizens . . . to publicly express support for Protestant Christianity.”56 When the school district would not accept Jager’s compromise, they basically put the “nail in their own coffin.” The Court then knew the school’s only purpose for moving forward on the pre-game invocation was for non-secular reasons.57 The coach and/or school actors must not try to fool the court by masking their true non-secular purposes. The coach’s equal access plan would also probably fail the primary effect prong and the excessive government entanglement prong of the Lemon Test.58 By allowing a religious speaker to come to a “school-sponsored event at a school-owned facility,” the coach’s plan will most likely fail the second part of the Lemon test as the school’s plan for the pre-game invocation did in Jager.59 Even though the school’s plan did pass the final prong of the Lemon Test in Jager, the coach’s equal access plan would not pass as the coach would be choosing the speaker and would have monitoring control over the content of the speech.60 The equal access plan for coach-allowed prayer in public high school has an uphill battle to fight to receive constitutional approval.


Moment of Silence Coaches may not violate the Establishment Clause by offering their players the right to engage in a moment of silence with the option to pray to any of their Gods or reflect upon the upcoming event. Currently, numerous states have statutes that allow a moment of silence before school to “help settle down the students.”61 However, in Wallace v. Jaffree, the Supreme Court denied the Alabama statute that allowed a moment of silence before school and found that the statute’s secular purpose was to advance religion and therefore, failed the Lemon Test.62 A Lemon Test analysis of a public school coach-imposed moment of silence hinges on the intentions of the coach.63 If the coach is asking for a moment of silence to “solemnize the event,” reflect on the game (secular intention), or to wish for a successful and injury-free outcome, the moment of silence will have the necessary secular purpose.64 In most instances however, if a coach is imposing a moment of silence instead of his longstanding tradition of prayer in order not to defy the Establishment Clause, the coach’s intentions will fail the Lemon Test as the Alabama statute did in Wallace.65 Even though a moment of silence allows for voluntary prayer, the coach or state actor instituting the moment of silence must be able to prove their “purely secular intentions.”66 A correctly-intentioned moment of silence before the game is a safe, effective technique to prepare young athletes for the important and sometimes, dangerous endeavor they are about to undertake, but the chances a state actor is not trying to advance religion or does not have a secular purpose are very slim. Public School Systems Viewpoints In most school systems in America, students begin representing their schools in athletic competition in the sixth or seventh grade (middle school) and continue until they graduate from


high school. Therefore, most student-athletes will begin their public school sporting participation at the tender ages of 12-13 years old. As mentioned in Edwards v. Aguillard, the state must be particularly careful of the “special context of the public elementary and secondary school system [as] . . . [the Supreme Court] has been particularly vigilant in monitoring compliance with the Establishment Clause.”67 Considering the delicate minds of young studentathletes and the powerful influences held by their coaches, the State should take an active role in preventing coach-imposed prayer and religious beliefs instead of relying on a child to stand up against a coach, to damage his relationship with his teammates, or to risk religious harassment and retaliation. The Establishment Clause in the United States Constitution, at a minimum, “guarantees that government may not coerce anyone to support or participate in religion or its exercises.”68 The public school systems should take heed of these words and begin to monitor and prevent Establishment Clause violations against the most impressionable, youngest students. On the college level, an Establishment Clause violation will be harder to ascertain due to the increased maturity level of the audience. As mentioned in Tilton v. Richardson, college students are “more mature than other students and . . . are less impressionable and susceptible to religious indoctrination.”69 Also, many student athletes are recruited by multiple universities and their respective culture and are probably aware of the religious, or lack of religious, environment they are choosing to attend. However, college coaches do not have a free pass to try to indoctrinate their players to their beliefs as the cheerleading coach at the University of Georgia found out.70 Even though the bar is set higher for an Establishment Clause violation against a college student, the instrumental power and influence of the head coach at a university leaves an open avenue for First Amendment violations.


Public debate on this issue is beginning to build as many of the top college football coaches are devout Christians, members of the Fellowship of Christian Athletes, and are not afraid to voice their beliefs.71 Head coaches at the University of Georgia, Florida State University, Penn State University, and the Air Force Academy participate in such religious activities as taking their teams on voluntary trips to different churches, having pre-game chapel services, saying the “Lord’s Prayer” after the game, and allowing banners in their locker room that say, “I am a Christian first and last, [and] I am a member of Team Jesus Christ."72 The legal departments from these universities claim that, “because participation was voluntary, the university has found no violations of the Constitution.”73 However, as one expert notes, “this is a lawsuit waiting to happen, and I believe university administrations are playing a game of chicken . . . eventually, one kid is going to say, 'I've had enough,' and step forward."74 According to the Lemon Test, these heralded public university coaches seem to be in direct violation of the Establishment Clause.75 First, all of these coaches have a non-secular purpose in mind for their prayers and religious activities. Even though many of the coaches do believe their actions are for “boosting team morale and building [team] unity more than hard gospel,” their intentions are not “purely secular intentions.”76 As one coach exclaimed, “I want my boys to be saved.”77 Second, their actions do primarily advance religion in light of their voluntary nature. Since many of the student’s scholarships and potential future careers depend on pleasing the coach and receiving playing time, players are coerced into following the “hierarchal nature of the player-coach relationship, where the coach is all-powerful. . . . And if they don't go along with what the coach offers, they fear that they will become secondstringers."78 Lastly, the coach’s religious activities foster an excessive government entanglement with religion since these violations occur on school grounds by a state actor in a highly public


setting played out in the media everyday. The coach may only want to “love these guys and put them in a situation where they can grow up to be the best men they can be,” but by abusing his public school coaching post and inherently coercive pressure, he is violating the country’s Constitution and setting a bad example for his student-athletes.79

Conclusion While most Americans have debated the constitutionality of the pre-game invocation at public schools, these same Americans have chosen to overlook the coercive religious pressure applied by their children’s coaches every day in schools all over America. The coach is a mentor, parental figure, dictator, and role model; he should not be a preacher, priest, rabbi or monk. A coach is a state actor with a controlled, highly impressionable audience for 2-3 hours a day on school property, and the government, at the behest of the American Public, should take proactive measures to ensure that no Establishment Clause violations are occurring in a majority of public schools across the nation. The government should expect no student, especially a student in the religious minority, to challenge his coach and subject himself to team, school staff, and public ridicule. If the coach offers a moment of silence with good non-secular intentions, the coach’s action would not be considered advancing religion under the Lemon test.80 Hopefully, the recent media spotlight will motivate the American public to take preventive and proactive action to protect the American youth from the potential coercive coach-instituted religious practices occurring in American public school athletics. Public school students should be able to decide on their own spiritual path without state-imposed influences; this is the minimum promise the Constitution guarantees for the American student.



James Salzer. Southern high schools invite God to gridiron. August 28, 2000.

Sante Fe Independent School District v. Doe, 120 S. Ct. 2266, 2271 (2000). Id. at 2272. Jager v. Douglas County Sch. Dist., 862 F.2d 824, 828 (11th Cir. 1989). Id.; Santa Fe, 120 S. Ct. 2266 (2000). Sante Fe, 120 S. Ct. at 2266. Id. Jager, 862 F.2d at 824. Sante Fe, 120 S. Ct. at 2266. Doe v. Duncanville Indep. Sch. Dist., 994 F.2d 160, 162 (5th Cir., 1993). Wallace v. Jaffree, 472 U.S. 38, 49-50 (1985). Id. Duncanville Indep. Sch. Dist., 994 F.2d at162; Lemon v. Kurtzman, 403 U.S. 602












(1971) (the potential violation must pass all three prongs of the Lemon Test simultaneously to gain Constitutional acceptance).

Id. Duncanville Indep. Sch. Dist., 994 F.2d at 166.



The Lord's Prayer, an undeniably Christian religious saying, states: Our Father Which art in heaven, Hallowed be thy name. Thy kingdom come.


Thy will be done in earth, as it is in heaven. Give us this day our daily bread. And forgive us our debts, as we forgive our debtors. And lead us not into temptation, but deliver us from evil: For thine is the kingdom, and the power, and the glory, for ever. Amen. Matthew 6:9-13; Id. at 164. 17 Id., Westside Comm. Schools Bd. of Educ. v. Mergens, 496 U.S. 226, 258 (1990). A student religious group was afforded the same rights to school facilities as other school groups (such as the chess club, national honor society, and the Subsurfers) due to the school’s creation of a “limited open forum” for all “non-curriculum related groups.”

Id., Duncanville Indep. Sch. Dist., 994 F.2d at164. Id. at 165. Braswell v. Bd. of Regents, 369 F. Supp. 2d 1371, 1373 (D. Ga. 2005).




Id. at 1372. The letter stated, “On or about June, 2003, [NAME REDACTED] issued a complaint with the UGA Legal Affairs Department accusing me of religious discrimination against her. It is my position that her accusations are totally without merit. I have retained counsel to investigate the matter and prove my position. However, because the allegations were made, the UGA Athletic Department has mandated that [NAME REDACTED] be placed, without having to try out, on this squad. Because this is an ongoing investigation, I will have no further comment regarding this situation at this time, except to say this. From this point forward, we will act in a manner that is consistent with what is the "greater good" for this squad. [NAME REDACTED] is a member of this team and is to be treated like any other member. I will not tolerate any negative action, discussion or comments regarding [NAME REDACTED], as a result of this situation. We will move on with the business of being the best cheer squad that we can be.” Also, the Coach read the letter with the Jewish cheerleaders in attendance and against the wishes of her counsel. 22 Id. at 1370.

Id. at 1374-76. Id. at 1375. Id. at 1375-76. Id. at 1376.






Id. Id. Id. at 1375. Engel v. Vitale, 370 U.S. 421, 442 (1962). Id. Gil Fried and Lisa Bradley. Applying the First Amendment to Prayer in a Public






University Locker Room: An Athlete's and Coach's Perspective. 4 Marq. Sports L.J. 301, 315. This assumption applies to both paid and volunteer coaches, as volunteer coaches are still supervised by state actors the same as paid coaches or athletic administrators.

See also Phillip S. Sloan, The Athlete and the Law 13 (1983); Omar S. Parker, The

Authority of a College coach: A Legal Analysis, 49 Or. L. Rev. 442, 449-50 (1970).

Harry M. Cross, The College Athlete and the Institution, 38 Law and Contemporary

Problems 150, 168-169 (1973). The fatherly/motherly position is often created due to the student-athlete being away from his/her parents for the first time when they enter the pressure filled environment of a university athletic program.

Pinard v. Clatskanie Sch. Dist. 319 F. Supp. 2d. 1214, 1216 (Ore. Dist. Ct., 2004). Charles Alan Wright, The Constitution on the Campus, 22 Van. L. Rev. 5, 1027, 1039



Widmar v. Vincent, 454 U.S. 263 (1981). Farrell, Memphis State coach is Accused of Imposing Religious Beliefs on Players, 29


The Chronicle of Higher Education 6, 26 (1984).

Id. Tenn. Code Ann. § 49-6-1004 (a) (1983).




Braswell v. Bd. of Regents, 369 F. Supp. 2d 1371, 1373 (D. Ga. 2005). Lemon v. Kurtzman, 403 U.S. 602 (1971). Id. Id. Id., Sante Fe Independent School District v. Doe, 120 S. Ct. 2266, 2275 (2000). Board of Education of Westside Community Schools v. Mergens, 496 U.S. 226, 238






(1990); Braswell v. Bd. of Regents, 369 F. Supp. 2d 1371. 1373 (D. Ga. 2005); Doe v. Duncanville Indep. Sch. Dist., 994 F.2d 160, 164 (5th Cir. 1993).

Id., Mergens, 496 U.S. at 233. Duncanville Indep. Sch. Dist., 994 F.2d at164. Gil Fried and Lisa Bradley. Applying the First Amendment to Prayer in a Public



University Locker Room: An Athlete's and Coach's Perspective. 4 Marq. Sports L.J. 301, 310.

Mergens, 496 U.S. at 233-235. Duncanville Indep. Sch. Dist., 994 F.2d at164. Gil Fried and Lisa Bradley. Applying the First Amendment to Prayer in a Public



University Locker Room: An Athlete's and Coach's Perspective. 4 Marq. Sports L.J. 301, 310; Mergens, 496 U.S at 251.

Lemon v. Kurtzman, 403 U.S. 602, 606 (1971). Id. Jager v. Douglas County Sch. Dist., 862 F.2d 824, 828 (11th Cir. 1989). Id. Id.







Lemon, 403 U.S. at 607. Jager, 862 F.2d at 830. Id. Id. Abington Sch. Dist. v. Schempp, 374 U.S. 203, 208 (1963); Wallace v. Jaffree, 472





U.S. 38, 67 (1985).

Id. at 38. Lemon v. Kurtzman, 403 U.S. 602, 604 (1971). Sante Fe Independent School District v. Doe, 120 S. Ct. 2266, 2271 (2000). Wallace v. Jaffe, 472 U.S. 38, 67 (1985), Lemon v. Kurtzman, 403 U.S. 602, 606





Gil Fried and Lisa Bradley. Applying the First Amendment to Prayer in a Public

University Locker Room: An Athlete's and Coach's Perspective. 4 Marq. Sports L.J. 301, 309.

Jager v. Douglas County Sch. Dist., 862 F.2d 824, 827 (11th Cir. 1989). Sante Fe, 120 S. Ct. at 2272. Tilton v. Richardson, 403 U.S. 672, 686 (1971). See also Roemer v. Board of Public



Works of Maryland, 426 U.S. 736, 750 (1976).

Braswell v. Bd. of Regents, 369 F. Supp. 2d 1371 (D. Ga. 2005). Joe Drape. Increasingly, Football's Playbooks Call for Prayer.

71 (Oct. 30, 2005)

Bob Condotta. DeBerry has habit of winning.

dyn/content/article/2005/06/03/AR2005060301508_pf.html. August 31, 2005; Joe


Drape. Increasingly, Football's Playbooks Call for Prayer (Oct. 30, 2005). Currently, Georgia, Penn State, and Florida State are all in the Top 25 Division 1 Football teams in the country. Air Force Academy has subsequently removed the banner due to a Pentagon task force investigating broader allegations of religious intolerance at the Air Force Academy.

Id. Id. Lemon, 403 U.S. at 607. Joe Drape. Increasingly, Football's Playbooks Call for Prayer.



76 (Oct. 30, 2005); Gil Fried and Lisa Bradley. Applying the First Amendment to Prayer in a Public University Locker Room: An Athlete's and Coach's Perspective. 4 Marq. Sports L.J. 301, 309.

Joe Drape. Increasingly, Football's Playbooks Call for Prayer. (Oct. 30, 2005).

Id. Id. Lemon, 403 U.S. at 606.




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