DOI: 10.1177/019263650008462009
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Abstract: This article concerns two seemingly antagonistic Court decisions— Sante Fe Independent School District v. Jane Doe, 13 Fla. Law. W. Fed. S425; and Adler v. Duval County School Board, 13 Fla. Law. W. Fed. C460. While the Sante Fe decision struck down a school prayer school board policy, the Duval County decision allowed such policy. The authors seek to reconcile these two court decisions and offer a short history of prayer in U.S. public schools.

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