## Facts

- Kiryas Joel, New York, was incorporated as a village whose boundaries were drawn to include an exclusively Satmar Hasidic Jewish community.
- The village was originally within the Monroe–Woodbury Central School District.
- In 1989, New York enacted a special statute creating the Kiryas Joel Village School District, matching the school district’s boundaries to the village lines.
- The new district was governed by a locally elected board and, in practice, operated a special education program for disabled children; most other village children attended private religious schools.
- Respondents sued, alleging the statute violated the Establishment Clause; New York courts held the statute unconstitutional, and the Supreme Court granted certiorari.

## Issues

1. Whether a state violates the Establishment Clause by creating a public school district whose boundaries intentionally coincide with a single religious enclave.
2. Whether a statute that grants governmental authority through case-specific, nonneutral criteria constitutes an impermissible establishment of religion, even if justified as an accommodation.

## Decision

- The Supreme Court affirmed, holding the statute unconstitutional under the Establishment Clause.
- The Court concluded the statute was an anomalous, case-specific delegation of governmental power to a religiously homogeneous community rather than a neutral, generally available arrangement.
- The Court distinguished permissible religious accommodation from impermissible establishment, finding that alternative, religion-neutral means existed to provide special education services.
- Justice Souter announced the judgment of the Court; multiple concurrences emphasized neutrality, symbolic endorsement, and risks of religious line-drawing in government structure.
- Justice Scalia, joined by the Chief Justice and Justice Thomas, dissented, viewing the law as a permissible accommodation aimed at special education needs.

## Legal Principles

- The Establishment Clause requires governmental neutrality between religions and between religion and nonreligion.
- A legislature may not confer governmental authority through a statute tailored to a specific religious community; case-specific favoritism triggers Establishment Clause concern.
- Religious accommodation is permissible when it alleviates burdens without singling out a particular faith for unique governmental power and when implemented through neutral, generally applicable mechanisms.
- Government structuring that aligns political authority with religious identity risks endorsement and invites religiously based political division, which the Establishment Clause forbids.

## Conclusion

Because New York created a public school district defined by, and for, a single religious enclave through special, nonneutral legislation, the statute crossed from accommodation into establishment and violated the Establishment Clause.


Bd. of Educ. of Kiryas Joel Vill. Sch. Dist. v. Grumet, 512 U.S. 687 (1994)