Sloan v. Lemon
Headline: Pennsylvania tuition-reimbursement law struck down as unconstitutional for advancing religion, blocking state payments to parents and preventing taxpayer-funded support of mainly religious private schools.
Holding: The Court held that Pennsylvania’s tuition-reimbursement program violates the constitutional prohibition on government support of religion because its practical effect is to advance religious schools.
- Blocks state payments to parents for private school tuition under this program.
- Prevents taxpayer funding that primarily aids religious private schools.
- Discourages states from adopting similar tuition-reimbursement schemes.
Summary
Background
Pennsylvania passed a Parent Reimbursement Act to pay parents $75 for elementary and $150 for secondary private school tuition, funded from cigarette-tax revenue and run by a state authority. The law followed an earlier decision that had invalidated a different Pennsylvania aid program, and it forbade state supervision of private schools and placed no limits on how parents could use the money. Pennsylvania taxpayers and parents sued, and a three-judge District Court held the new plan unconstitutional and enjoined payments. The appeals were consolidated with a related New York case decided the same day.
Reasoning
The Court asked whether the program’s practical effect was to support religion. Comparing the Pennsylvania law to the New York program, the Court found no constitutionally meaningful difference. The State singled out parents who send children to nonpublic schools for a special benefit that, in practice, preserves and supports religion-oriented institutions. Differences in amounts, funding source, or the use of an independent administering authority did not change the result. The Court rejected arguments that the law could be split so nonreligious private schools could get aid while excluding religious ones, and it said equal-protection claims cannot force the State to violate the constitutional ban on government support of religion.
Real world impact
The ruling prevents Pennsylvania from disbursing these tuition reimbursements and stops taxpayer funding that would primarily aid religious private schools. Parents who expected payments under this Act cannot receive them, and similar state tuition-reimbursement plans face the same constitutional hurdle. This decision affirms the lower court’s injunction and is a final Supreme Court holding on the point.
Dissents or concurrances
The opinion notes there are dissenting opinions from the Chief Justice and from Justice White, indicating some Justices disagreed with the majority’s conclusion.
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