Mitchell v. Helms Case Brief

Why is the case important?

The Respondent, Helms (Respondent), filed suit alleging that the application of Chapter 2 in Jefferson Parish Louisiana was in violation of the establishment clause, because of the large number of parochial schools who would receive the government funds associated with the Chapter.

Facts of the case

“Chapter 2 of the Education Consolidation and Improvement Act of 1981 provides for the allocation of funds for educational materials and equipment, including library materials and computer software and hardware, to public and private elementary and secondary schools to implement “”secular, neutral, and nonideological”” programs. In Jefferson Parish, Louisiana, about 30% of Chapter 2 funds are allocated for private schools, most of which are Catholic or otherwise religiously affiliated. Mary Helms and other public school parents file suit alleging that Chapter 2, as applied in Jefferson Parish, violated the First Amendment’s Establishment Clause. The District Court initially agreed, finding that Chapter 2 had the primary effect of advancing religion because the materials and equipment loaned to the Catholic schools were direct aid and that the schools were pervasively sectarian. However, after the presiding judge who made the initial ruling retired, the case was reviewed by a new judge, who reversed that decision. Thereafter, based on different precedent, the court upheld Chapter 2. In reversing, the Court of Appeals held Chapter 2 unconstitutional.”

Question

The issue in this case is whether the allotment of state aid to religious-based schools is necessarily a violation of the Establishment Clause, when those funds are ear marked for non-religious purposes.

Answer

Reversed.
Based on its holding in Agostini, the Supreme Court held that it is not facially unconstitutional to allot funds to religious schools, provided there is no indication that the funds will be used for a purpose other than that which is intended.

Conclusion

In reversing the lower court’s decision, the court held that Chapter 2 was not such a law because it neither resulted in religious indoctrination by the government, because the law determined eligibility neutrally, allocated aid based on private choices, and did not provide aid that had an impermissible content, nor defined its recipients by reference to religion. To the extent that Meek v. Pettenger, 421 U.S. 349, 44 L. Ed. 2d 217 (1975) and Wolman v. Walter, 433 U.S. 229, 53 L. Ed. 2d 714, (1977) , conflicted with the holding, those cases were overruled. The plurality opinion rejected any distinction between direct and indirect aid and was concerned neither with the issue of divertibility nor whether the school receiving the aid was pervasively sectarian.

  • Case Brief: 2000
  • Petitioner: Mitchell
  • Respondent: Helms
  • Decided by: Rehnquist Court

Citation: 530 US 793 (2000)
Argued: Dec 1, 1999
Decided: Jun 28, 2000