The Supreme Court's 1962-1963 decisions in Engel v. Vitale and Abington v. Schempp banned state-sponsored prayer and Bible reading in public schools. For decades, the Lemon test (1971) governed Establishment Clause cases, often striking down religious activity in public schools.
Kennedy v. Bremerton School District (2022) sided with a public-school football coach who knelt to pray on the field after games, holding the conduct was private religious expression protected by the Free Exercise Clause. The Court signaled the Lemon test was no longer good law, suggesting a more "history and tradition" oriented analysis.
Since Kennedy, states and districts have explored chaplain programs, posting of the Ten Commandments, religious-release time, and student-led religious activities. Courts continue to draw lines between protected private religious expression by individuals and impermissible government endorsement.