## Facts

- Illinois enacted a 1941 law making Good Friday a state holiday, closing state facilities including public schools (not colleges or universities).
- A 1942 gubernatorial proclamation described Good Friday as having special meaning in the Christian world and commended its sacred rites and ceremonies.
- In 1989, Illinois repealed Good Friday as a general state holiday but retained it as a statewide holiday for public elementary and secondary schools; schools close and teachers are paid as for other holidays.
- Illinois school holidays included mostly secular holidays; Christmas and Thanksgiving were treated as widely secularized, while Good Friday was characterized as a distinctly religious observance.
- Illinois separately provided religious accommodations allowing students to be excused for religious observances; some districts also closed for certain non-Christian holidays without statewide mandate.
- A public school teacher and taxpayer filed a 42 U.S.C. § 1983 action alleging the Good Friday school-holiday statute violated the Establishment Clause by using tax funds to pay teachers for that day off.
- The district court granted summary judgment for the plaintiff and entered declaratory and injunctive relief barring enforcement; the state superintendent appealed.

## Issues

1. Whether the court of appeals had jurisdiction despite technical defects in the form of the district court’s judgment and injunction.
2. Whether a taxpayer and teacher had standing to challenge the paid Good Friday school holiday under the Establishment Clause.
3. Whether a statute requiring statewide closure of public schools on Good Friday with paid leave for teachers violates the Establishment Clause.

## Decision

- The court exercised appellate jurisdiction because the declaratory and injunctive relief was sufficiently clear and final, and noncompliance with Rule 58 formalities was not jurisdictional.
- The plaintiff had taxpayer standing to challenge a practice financed by tax revenues (paid Good Friday leave for public school teachers).
- The Good Friday paid school-holiday statute violated the Establishment Clause.
- The court affirmed summary judgment for the plaintiff and left the injunction against enforcement in place.

## Legal Principles

- Appellate jurisdiction is not defeated by technical noncompliance with judgment-form requirements when the district court’s disposition is final and the relief ordered is clear.
- Taxpayer standing is available in Establishment Clause challenges where the plaintiff contests a governmental practice supported by tax funds.
- A statewide, paid public-school closure on a day with exclusively religious significance, without a sufficient secular or neutral-accommodation justification, constitutes unconstitutional governmental endorsement or advancement of religion.
- Existing, generally applicable religious-excusal accommodations can undercut a claim that a religion-specific school holiday is necessary as an accommodation.

## Conclusion

The Seventh Circuit held that Illinois’s statutory requirement that all public elementary and secondary schools close on Good Friday with paid leave for teachers impermissibly endorsed a Christian religious observance, affirmed the district court’s summary judgment and injunction, and confirmed taxpayer standing to bring the challenge.


Metzl v. Leininger, 57 F.3d 618 (7th Cir. 1995)