Agostini v. Felton
Headline: Court overturns Aguilar and allows public school teachers to provide Title I remedial instruction inside parochial schools, reducing extra costs and changing how federal education aid reaches religious-school students.
Holding: The Court ruled that Aguilar is no longer good law, overruled portions of Ball and Aguilar, and granted Rule 60(b)(5) relief so Title I instruction may be provided on parochial premises under safeguards.
- Allows government-paid Title I teachers to teach inside religious schools under neutral safeguards.
- Reduces extra compliance costs, restoring federal funds for more student services.
- Shifts future disputes to lower courts and litigation about program details and safeguards.
Summary
Background
A city's public school system (the New York City Board of Education) and a group of parents sought to provide Title I remedial education to disadvantaged children, many of whom attend parochial schools. In 1985 the Court in Aguilar barred sending public school teachers into those religious schools and a District Court entered a permanent injunction. Because of that injunction the Board moved services off-site, spent large sums to lease sites and transport students, and reported over $100 million in extra costs that reduced Title I funds for students.
Reasoning
The Court asked whether later decisions and legal developments meant Aguilar should no longer control. It applied the rule that a long-term injunction may be changed when there has been a significant change in law or facts. The majority concluded later cases (including Zobrest, Witters, and Rosenberger) undercut Aguilar’s assumptions, rejected a presumption that public employees on parochial premises will inevitably indoctrinate, and emphasized Title I’s neutral eligibility rules and safeguards. The Court held Aguilar and related parts of Ball were no longer good law and granted relief under the federal rule, instructing the lower court to vacate the 1985 injunction.
Real world impact
The decision permits government-paid Title I teachers to provide neutral, supplemental instruction on religious school premises when programs follow the Court’s safeguards. That change will reduce extra compliance costs for affected school systems, free federal Title I money for student services, and require local officials and courts to sort out program details going forward by focusing on safeguards and neutral administration.
Dissents or concurrances
Three Justices dissented (Souter, Stevens, and Ginsburg). They argued the Court misapplied the rule for changing injunctions, maintained Aguilar remained sound, and warned that allowing on-site instruction risks governmental endorsement or direct subsidy of religion; one dissent urged waiting for another proper case.
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