## Facts

- New York Education Law § 414 authorized local school boards to permit community use of school property during nonschool hours for specified purposes related to community welfare.
- A school board adopted rules permitting certain “social, civic and recreational” community uses but prohibiting use “by any group for religious purposes.”
- An evangelical church and its pastor sought to rent school facilities after hours to show a film series on family and child-rearing issues presented from a Christian viewpoint, open to the public.
- The school district denied the requests solely because the film series was considered “church related” and therefore “religious.”
- The district court and court of appeals upheld the denial, treating the facilities as a limited or nonpublic forum and viewing the exclusion as reasonable and viewpoint neutral.

## Issues

1. Whether denying access to school facilities for an after-hours film series on family and child-rearing issues because it was presented from a religious standpoint violates the Free Speech Clause.
2. Whether allowing the church to use the facilities on the same terms as other community groups would violate the Establishment Clause.

## Decision

- The Supreme Court reversed unanimously.
- Assuming the property was at most a limited or nonpublic forum, the Court held the exclusion was unconstitutional viewpoint discrimination because the district permitted discussion of family issues generally but barred discussion of the same subject from a religious viewpoint.
- The Court rejected the Establishment Clause justification, holding that permitting after-hours, non-school-sponsored use on equal terms would not constitute an establishment of religion.
- Concurring opinions agreed with the judgment; separate writings criticized strict reliance on the Lemon framework.

## Legal Principles

- In a limited or nonpublic forum, the government may impose reasonable access limits tied to the forum’s purpose, but restrictions must be viewpoint neutral.
- Excluding speech on an otherwise permitted subject because it is offered from a religious standpoint is viewpoint discrimination.
- Equal access for private religious speech in public school facilities after hours, on the same terms as comparable secular uses and without school sponsorship, does not violate the Establishment Clause.
- Establishment Clause concerns do not justify suppressing private speech where neutral access policies and contextual safeguards prevent a reasonable perception of government endorsement.

## Conclusion

A school district that opens its facilities for community discussion of family and parenting topics may not exclude a church’s presentation of those topics because it is religious; doing so is viewpoint discrimination, and allowing equal after-hours access does not violate the Establishment Clause.


Lamb's Chapel v. Ctr. Moriches Union Free Sch. Dist., 508 U.S. 384 (1993)