In the Santa Fe v. Doe pre-game prayer case, the Supreme Court upheld, as constitutional under the Establishment Clause, a school district's policy permitting students to vote on whether an "invocation and/or message" should be delivered (and by which student) over the public address system before football games

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The Supreme Court ruled that the school district's policy allowing student-led prayer before football games was unconstitutional as it violated the Establishment Clause. The Court held that such prayers were not truly voluntary as they were sponsored by the school and therefore constituted state-sponsored religious activity.

In the Santa Fe V