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Introduction The issue of separation between church and state has invoked great controversy in American society. When asked the question, should schools be allowed to start the day off with a prayer, seventy-two percent polled responded yes (The American National Election Study of 1980). Yet the Supreme Court has continually denied allowing prayer to seep into the public school system. The Supreme Court has repetitively ruled that the infiltration of religion, via prayer, in the public …

…S. 203) With regards to “that citadel” Justice Clark is referring to the notion of prayer in school. It is clear that the Justices are interpreting the Establishment Clause to prohibit the advancement of religion in any form. Despite the complexities that have been associated with the Establishment Clause the Justices have been consistent in the separation of prayer from school. From Everson (1947) to Doe (2000) the Justices continually disallow any intermingling of prayer and school. Conclusion