BOARD OF EDUCATION OF KIRYAS JOEL VILLAGE SCHOOL DISTRICT v. GRUMET
Supreme Court Cases
512 U.S. 687 (1994)
Case Overview
Legal Principle at Issue
Whether a school districting law passed by the New York state legislature in 1989 — that excluded a Judaic religious enclave — violated the Establishment Clause of the First Amendment.
Action
Affirmed (includes modified). Petitioning party did not receive a favorable disposition.
Facts/Syllabus
The New York village of Kiryas Joel is a religious enclave of Satmar Hasidim, practitioners of a strict form of Judaism. Its incorporators intentionally drew its boundaries under the state's general village incorporation law to exclude all but Satmars. The village fell within the Monroe-Woodbury Central School District until a special state statute — 1989 N. Y. Laws, ch. 748 — carved out a separate district that follows village lines. Although the statute gives a locally elected school board plenary authority over primary and secondary education in the village, the board currently runs only a special education program for handicapped children. Other village children attend private religious schools, which do not offer special educational services.
Shortly before the new district began operations, the Village of Kiryas Joel and others filed a lawsuit claiming the state's school districting law violated the Establishment Clause of the First Amendment. Monroe-Woodbury, for its part, sought a declaratory judgment in state court that New York law barred the district from providing special education services outside the district's regular public schools. The New York Court of Appeals disagreed, holding that state law left Monroe-Woodbury free to establish a separate school in the village because it gives educational authorities broad discretion in fashioning an appropriate program. The court added, however, that the Satmars' constitutional right to exercise their religion freely did not require a separate school, since the parents had alleged emotional trauma, not inconsistency with religious practice or doctrine, as the reason for seeking separate treatment.