What Groups Can Churches Allow to Use Facilities

Topic:
MUNICIPAL Government; RELIGIOUS GROUPS; CONSTITUTIONAL LAW; FIRST Subpoena ISSUES; MUNICIPALITIES; MUNICIPAL BUILDINGS;
Location:
MUNICIPALITIES; RELIGION;

May 22, 2007		2007-R-0353
USE OF PUBLIC BUILDINGS FOR RELIGIOUS PURPOSES
By: George Coppolo, Chief Chaser

You asked whether a town that allows its town hall to be used by private organizations for private purposes tin permit religious organizations or religious related organizations to apply it for religious programs. You as well asked if it does, must it do so for any religious group or can it be selective?

Our office is non authorized to give legal opinions and this report should non be considered ane.

SUMMARY

It does not appear that either land or federal police prohibits such a town from assuasive religious or religious based organizations to use its town hall for religious purposes as long as the employ does non interfere with governmental functions and the boondocks does not favor sure religions over other religions in allowing the apply.

Nosotros could non find any statutes that address this precise issue. We found one statute that authorizes The University of Connecticut trustees to convey university state to provide sites for buildings to house religious activities for students attending the university. These religious buildings must exist built past, and under the auspices of, religious organizations (CGS � 10-136). But we could not locate whatever law addressing the use of town halls past religious groups.

There are U.Due south. Supreme Court decisions that establish general rules state and local governments must follow when granting or denying religious or religious-based organizations permission to use public buildings for private purposes. These rulings are based on the Courtroom ' s interpretations of the Offset Amendment ' s rights concerning freedom of speech and organized religion, and its prohibitions concerning establishing or favoring one religion over others.

A town is under no obligation to make its facilities available to members of the public for non-regime functions and activities. Merely once a town creates a public forum past allowing its facilities to be used by private groups for individual purposes, it must satisfy constitutional rules regarding its inclusion and exclusion policies. When government creates such a forum past its policies, it is non required to let people and groups to engage in every type of speech, and it may be justified in reserving its forum for certain groups or for the discussion of sure topics. Just the brake must not discriminate against spoken communication on the basis of viewpoint, and must be reasonable in light of the purpose served by the forum. And the town may not by its policies appear to be favoring ane religion over another or all other religions.

Because the Courtroom ' southward rulings are fact specific and frequently require subjective and objective determinations in order to apply them to different situations it is not ever possible to know alee of time whether a policy and its application to a particular arrangement and activity will violate the First Amendment.

To further complicate the matter, although no Connecticut statute addresses your question, 1 erstwhile Connecticut case addresses many of the aforementioned issues. Scofield v. Eighth School Commune, an 1858 Connecticut Supreme Courtroom case, dealt with a taxpayer who objected to the use of his district ' s schoolhouse for religious worship and instruction (27 Conn. 499 (1858)). He complained that utilize by groups other than schoolchildren would increment the wear and tear on the schoolhouse furniture, thus forcing the town to enhance taxes in club to replace it.

The court found that Mr. Scofield had a legitimate ground for objection. It issued an injunction confronting the use of school facilities past religious groups for worship, Sunday schoolhouse, and other religious activities. The court enunciated its position that the objection of even ane taxpayer to the use of schoolhouse facilities for religious worship and instruction during non-school hours was sufficient to order a terminate to the activity. The case does not appear to have been reversed or overturned, and may still exist good case law today.

But it seems unlikely that a Connecticut case today would be analyzed this mode in light of recent federal court decisions. And in whatever upshot, the federal constitution and its rights and obligations supplant any conflicting state statute and court decision based on an estimation of country law including the state ' s constitution.

Following is (1) a full general discussion of the Beginning Amendment rights and prohibitions that a boondocks should consider when creating and applying its policies and practices concerning the right of individual organizations to use its facilities; (2) a brief overview of the controlling constitutional principles and prohibitions, (3) a more in depth word of leading Supreme Courtroom cases, and (4) a summary of a 2007 federal court of appeals instance that illustrates how complicated an area of law this tin can be.

FIRST Subpoena RIGHTS AND PROHIBITIONS

The First Amendment to the Usa Constitution prohibits Congress from enacting any law

1. respecting the establishment of faith (this is chosen the First Amendment ' s Establishment Clause),

two. prohibiting the complimentary exercise of religion (this is chosen the Free Practise Clause), or

3. abridging the freedom of oral communication (this is called the Freedom of Spoken communication Clause).

The Supreme Courtroom has held that the First Amendment ' s rights and prohibitions relative to the federal regime also apply to the states past the Due Process Clause of the Fourteenth Amendment (Democratic Party of U.S. v. Wisconsin ex rel. LaFollette, 450 U.S. 107 (1981)). Thus they utilize to policies and deportment of state and local governments.

RELEVANT FIRST Subpoena LEGAL PRINCIPLES –OVERVIEW

Supreme Court Decisions

The Supreme Court has held that religious worship and discussion are forms of voice communication and association protected past the First Subpoena. Beginning with Widmar v. Vincent, 454 U.S. 263, 267(1981) the Supreme Court has consistently held that once the government establishes a forum open mostly to use by the public, it assumes an obligation to justify its discriminations and exclusions under applicable ramble rulings. Under these rulings, the government must grant both religious and non-religious groups access to the forum on equal terms. In other words, the government tin exclude religious speech merely if (1) the content of that speech is non germane to the purposes of the forum, or (two) the expressive activity violates standard time, identify, and manner restrictions on the forum ' southward use. (see Rosenberger five. Rector and Visitors of the Univ. of Virginia, 515 U.S. 819, 830 (1995)). But the authorities cannot exclude religious speech only because of its religious character.

In one leading case, the Courtroom held that a school lath ' south policy refusing to allow a church building to testify a religious pic at a public school after schoolhouse hours when other civic and social organizations could use the facilities favored non-religious over religious viewpoints (Lamb ' south Chapel v. Center Moriches Spousal relationship Gratuitous School, 508 U. Due south. 385 (1993)). Thus, the court concluded the policy violated the First Amendment ' s Free Speech communication clause. The Court also concluded that the apply of school property to show the film did non violate the Starting time Subpoena ' s Establishment Clause, considering the film was open to the public and non scheduled during school hours or sponsored past the school.

In another leading case, the Court held that a public school ' s refusal to permit a club to meet in a schoolhouse after hours because of the club ' south religious nature violated the First Amendment ' s freedom of speech and religion guarantees (Skillful News Order five. Milford Key Schoolhouse, 533 U.South. 98 (2001)). The Court concluded that the schoolhouse ' due south policies regarding school utilise by private organizations after hours created a limited public forum. When government creates such a forum past its policies, it is not required to allow people and groups to engage in every type of oral communication, and it may exist justified in reserving its forum for certain groups or for the discussion of sure topics. Merely the brake must not discriminate confronting speech on the basis of viewpoint, and must be reasonable in light of the purpose served by the forum.

The Court ruled that the school ' southward exclusion of a Christian children ' s lodge from meeting after hours at the school based on its religious nature was unconstitutional viewpoint bigotry in violation of the First Subpoena. Information technology noted that the school had opened its express public forum to activities that served a diverseness of purposes, including events "pertaining to the welfare of the community," and had interpreted its policy to permit discussions of subjects such as "the development of graphic symbol and morals from a religious perspective. "But the school excluded the guild because its activities, which included learning Bible verses, relating Bible stories to member ' s lives, and praying, were the equivalent of religious educational activity itself."

Complexity of Legal Problems-Contempo Courtroom of Appeals Instance

Because the Court ' s rulings are fact specific and require subjective and objective determinations it is non always possible to know ahead of time whether a policy and its application to a item organization and activeness will violate the First Amendment. A 2007 federal circuit court decision illustrates this difficulty and incertitude. A non-profit religious organization went to court seeking to enjoin the county regime from excluding it from holding worship services in a public library coming together room. It alleged that such exclusion constituted viewpoint discrimination in violation of Offset Amendment. In a two to one decision, the 9th Circuit Courtroom of Appeals decided that the county ' s policy and its decision to exclude this religious organization did not violate the constitution (Faith Center Church Evangelistic Ministries v. Glover, 480 F3d 891 (C.A.9 (Cal.),2007)).

The court decided that the county ' s prohibition confronting a religious organization conducting worship services in its public library coming together room, which was a limited public forum, was reasonable in calorie-free of the room ' south purpose. The prohibition did non establish a free speech violation in the courtroom ' s view because it was viewpoint neutral. The county had a legitimate interest in excluding activities that might interfere with the library ' due south primary function as a sanctuary for reading, writing, and quiet contemplation, and the county reasonably could conclude that controversy apropos, and distraction considering of religious worship within the library might alienate patrons and undermine the library'due south purpose of making itself bachelor to the entire community.

Seven of the circuit ' s judges filed a lengthy dissenting opinion to the full pane ' s conclusion non to allow the case to be re-considered by the entire Ninth Circuit. These judges indicted that they believed the county ' s policies and denial in this case violated the First Amendment and they disagreed with the majority opinion ' s distinction betwixt religious services and a religious viewpoint.

Following is a more than in depth discussion of 2 leading U.S. Supreme Court cases that nosotros referred to above.

LAMB ' S CHAPEL V. CENTER MORICHES UNION Gratis Schoolhouse DISTRICT

Facts

Lamb ' s Chapel, an evangelical church applied to the school commune for permission to use school facilities to show a six-part motion-picture show serial containing lectures by Doctor James Dobson, a licensed psychologist, former associate clinical professor of pediatrics at the University of Southern California, acknowledged writer, and radio commentator. The moving picture series discussed Dobson ' due south views on the undermining influences of the media that could only be balanced past returning to traditional, Christian family values instilled at an early stage.

The district denied the Chapel ' s applications to use the school, because the film appeared to be church related.

Procedural History and Lower Court Rulings

The Church brought suit in federal district court, challenging the denial as a violation of the Freedom of Speech and Associates Clauses, the Free Exercise Clause, and the Establishment Clause of the First Amendment, equally well as the Equal Protection Clause of the Fourteenth Amendment.

District Court. The district court rejected all the Church building ' due south claims. With respect to the gratuitous-oral communication claim, the district courtroom characterized the school district ' s facilities as a "limited public forum." The court noted that (ane) the enumerated purposes that state police allowed access to schoolhouse facilities did not include religious worship or educational activity, (2) one of the district ' due south rules explicitly prohibited using school facilities for religious purposes, and (3) the Church had conceded that its showing of the film series would be for religious purposes. The courtroom stated that once a express public forum is opened to a particular blazon of spoken communication, the offset amendment prohibits selectively denying access to other activities of the same type. Pointing out that the school had not opened its facilities to organizations similar to Lamb ' s Chapel for religious purposes, the court concluded that the denial was viewpoint neutral and, thus, non a violation of the Beginning Amendment ' due south Freedom of Speech Clause. The court also rejected the Church building ' s claim that denying its application demonstrated a hostility to organized religion non justified under the First Amendment ' s Institution Clause of the First Subpoena.

Appeals Court . The Second Circuit Court of Appeals affirmed the judgment of the District Courtroom. Information technology held that the schoolhouse property, when non in utilise for schoolhouse purposes, was neither a traditional nor a designated public forum; rather, it was a limited public forum open up merely for designated purposes, a classification that allows it to remain non-public except as to specified uses. The court observed that exclusions in such a forum need merely exist reasonable and viewpoint neutral, and ruled that denying access to the Church for the purpose of showing its film did not violate this standard.

Supreme Court ' south Ruling

The Supreme Court ruled that excluding events that had a religious purpose was unconstitutionally applied in this instance.

Supreme Court ' s Reasoning

Control over access to public property that is not a designated public forum open to the public use for communicative purposes, can exist based on subject thing and speaker identity then long as the distinctions drawn are reasonable in light of the purpose served by the forum and are viewpoint neutral.

Although the policy prohibiting all uses for religious purposes treats all religions akin, the critical question is whether the policy discriminates on the basis of viewpoint to permit schoolhouse belongings to be used for the presentation of all views about family problems and child rearing except those dealing with the subject matter from a religious standpoint.

The lower courts did non fifty-fifty suggest that a lecture or motion picture almost child rearing and family values would not be a use for social or civic purposes otherwise permitted by the school ' s public access rules. The District did not place those topics off limits to any and all speakers. Nor was there any indication that the application to exhibit the particular film series was, or would take been, denied for whatsoever reason other than the fact that the presentation would take been from a religious perspective. The Court noted that this application of the school district ' s rules seem to clearly violate the Court ' southward prior holdings that the government violates the Start Amendment when it denies access to a speaker solely to suppress his betoken of view on an otherwise includible subject.

The pic serial involved hither dealt with a subject otherwise permissible under the school ' s access rules, and the school prohibited it being shown only because the film series dealt with the subject from a religious standpoint. The principle that has emerged from the Court ' s prior cases is that the Outset Amendment forbids the government from regulating speech communication in means that favors some viewpoints or ideas at the expense of others. That principle applies to this instance.

The school district argued that if it allowed its property to be used for religious purposes it would be an establishment of religion forbidden past the Kickoff Amendment. The Court suggested in a previous case (Widmar five. Vincent, 454 U.S. 263, 271, (1981)) that the state ' s involvement in fugitive an Institution Clause violation may be a compelling 1 justifying an abridgment of free spoken communication otherwise protected by the First Amendment.

The Court concluded that fears of an Establishment Clause violation are unfounded. The Court noted that this film series would not take been during schoolhouse hours, would not accept been sponsored by the schoolhouse, and would have been open up to the public, not simply church members. The school ' s property had repeatedly been used by a wide variety of private organizations. Under these circumstances in that location would have been no realistic danger that the community would think that the schoolhouse district was endorsing religion or any particular creed, and any benefit to religion or to the Church would have been no more than incidental. The challenged governmental activeness has a secular purpose, does not have the primary or primary effect of advancing or inhibiting religion, and does non foster an excessive entanglement with religion.

The school district also claimed that it justifiably denied use of its property to a "radical" church for the purpose of proselytizing, since to do then would atomic number 82 to threats of public unrest and even violence. Just the Court observed that there was cipher in the record to support such a justification. The Court noted that even if there were evidence, it would be difficult to defend as a reason to deny the presentation of a religious point of view about a subject the commune otherwise opens to give-and-take on district holding.

The New York State Attorney General claimed that the exclusion of the church is justified because the purpose of the access rules is to promote the interests of the public in general rather than sectarian or other private interests. But the Court pointed out that the school ' south admission rules allow district property to be used for social, civic, or recreational use only if information technology can be non-exclusive and open to all residents of the school commune that form a homogeneous group deemed relevant to the event. The Courtroom of Appeals ruled that because the schoolhouse had the power to allow or exclude certain discipline matters, it was entitled to deny use for any religious purpose, including the purpose in this example. The Chaser General also defends this every bit a permissible subject-matter exclusion rather than a denial based on viewpoint. The Court rejected these arguments.

The Attorney General also argued that there was no express finding that the Church ' s application would take been granted absent the religious connection. The Court pointed out that this was beside the bespeak because the case turned on the validity of the reason the school gave for denying the Church's application, namely, that the motion-picture show series sought to exist shown appeared to be church related.

Practiced NEWS CLUB 5. MILFORD CENTRAL Schoolhouse (533 U.S. 98 (2001))

Facts

Under New York law, the Milford Key School (Milford) enacted a policy authorizing district residents to apply its building after schoolhouse for, amid other things, (1) instruction in education, learning, or the arts and (2) social, civic, recreational, and entertainment uses pertaining to the customs welfare. Two district residents were sponsors of the Good News Club, a private Christian organization for children ages 6 to 12. Pursuant to Milford's policy, they submitted a request to hold the Society ' s weekly after school meetings in the school. Milford denied the asking because the proposed employ—to sing songs, hear Bible lessons, memorize scripture, and pray—was the equivalent of religious worship prohibited by the community use policy.

Procedural History and Lower Court Rulings

The club, filed suit nether 42 U.s.C. � 1983 alleging that the denial of the club's application violated its free spoken language rights under the Kickoff and Fourteenth Amendments.

The District Courtroom decided in favor of Milford. It concluded that the lodge's subject thing was religious in nature, not merely a discussion of secular matters from a religious perspective that Milford otherwise permits. Because the school had not immune other groups providing religious instruction to apply its express public forum, the court held that information technology could deny the lodge access without engaging in unconstitutional viewpoint bigotry.

The 2nd Circuit affirmed the District Court ' due south decision. It rejected the Club ' southward contention that Milford ' southward restriction was unreasonable, and held that, because the Club ' s field of study matter was essentially religious and its activities fell exterior the bounds of pure moral and grapheme development, Milford ' s policy was field of study bigotry, which the First Amendment allows, and non viewpoint discrimination, which the First Amendment prohibits.

Supreme Courtroom ' s Decision

The Supreme Court ruled that Milford violated the Order ' due south complimentary speech rights guaranteed by the First Subpoena when it excluded it from meeting after hours at the school.

Court ' s Reasoning

The majority reasoned as follows. (The majority ' south reasoning is taken directly from the majority ' s summary of its ruling.)

The parties agreed, and the Courtroom assumed that Milford operated a express public forum. A state or local government agency that establishes a express public forum doesn ' t take to let people engage in every blazon of spoken language. It can reserve its forum for certain groups or the give-and-take of certain topics. But the ability to restrict oral communication in this way is not without limits. The restriction can ' t discriminate against oral communication based on its viewpoint, and must be reasonable in light of the forum's purpose.

Regarding the Club ' s free spoken communication rights, the Court adamant that by denying the Club access to the school'due south limited public forum because information technology was religious in nature, Milford violated the Outset Amendment ' s free speech clause considering information technology discriminated against the club because of its religious viewpoint. That exclusion, in the Court ' s view is duplicate from the exclusions it institute unconstitutional in Lamb ' s Chapel v. Middle Moriches Union Costless School Commune, where a school commune prevented a private grouping from presenting films at the schoolhouse based solely on the religious perspective of the films, and in Rosenberger, where a university refused to fund a student publication because it addressed issues from a religious perspective.

The only apparent difference, co-ordinate to the Court, between the activities of Lamb ' south Chapel and the Club is the Club teaches moral lessons from a Christian perspective through live storytelling and prayer, whereas Lamb ' s Chapel taught lessons through films.

The Courtroom rejected the Second Circuit ' s view that something that is essentially or decidedly religious in nature cannot also exist characterized as the teaching of morals and grapheme development from a particular viewpoint. What matters for Free Oral communication Clause purposes, in the Court ' due south view is that there is no logical difference in kind betwixt the invocation of Christianity past the Society and the invocation of teamwork, loyalty,

patriotism past other associations to provide a foundation for their lessons. Considering Milford'south brake is viewpoint discriminatory, the Court did not have to determine whether it is unreasonable in light of the forum'due south purposes.

Regarding the Get-go Amendment ' south Institution Clause the Court ended that permitting the Club to meet on the school ' s premises would not have violated the Establishment Clause. The Court noted that it rejected Establishment Clause defenses similar to Milford'southward in Lamb's Chapel, because the films would (1) not have been shown during schoolhouse hours; (2) not accept been sponsored by the school; and (3) have been open to the public, not just church members. Thus, the Courtroom determined that there was no realistic danger that the community would think that the district was endorsing religion. The Court had reached this same conclusion Widmar v. Vincent (454 U.S. 263, 272-273), where a university's forum was already available to other groups.

The Court noted that every bit in Lamb ' southward Chapel, the club ' s meetings were to be held after school hours, not sponsored by the school, and open to any student who obtained parental consent, not only to club members. As in Widmar, Milford made its forum available to other organizations.

The Courtroom rejected Milford ' s endeavour to distinguish those cases by emphasizing that its policy involves elementary schoolhouse children who could perceive that the school is endorsing the club and will feel coerced to participate because the order ' due south activities take identify on school grounds, even though they occur during non-schoolhouse hours. The Court rejected this statement for a number of reasons.

1. Allowing the social club to speak on schoolhouse grounds would ensure, not threaten, neutrality toward organized religion, thus Milford faces an uphill boxing in arguing that the Establishment Clause compels information technology to exclude the guild.

ii. To the extent the Court considers whether the community would feel coercive pressure to engage in the social club ' southward activities, the relevant community is the parents who choose whether their children will nourish club meetings, not the children themselves.

three. Whatever significance it may take assigned in the Establishment Clause context to the proposition that elementary school children are more than impressionable than adults, the Courtroom has never prohibited private religious conduct during not-schoolhouse hours simply because information technology takes place on school premises where unproblematic schoolhouse children may be nowadays.

4. Even if the Court were to consider the possible misperceptions by schoolchildren in deciding whether in that location is an Establishment Clause violation, the facts of this case do not support Milford's claim.

5. Finally, it cannot be said that the danger that children would misperceive the endorsement of religion is whatsoever greater than the danger that they would perceive a hostility toward the religious viewpoint if the club were excluded from the public forum.

Religion Middle CHURCH EVANGELISTIC MINISTRIES V. GLOVER C.A.ix (CAL.), 2007

A contempo Ninth Circuit Court of Appeals case illustrates how difficult applying the rules the Supreme Court has established can be and how different interpretations are possible.

Facts

The Contra Costa County ("county") makes available to the public its public library meeting rooms during operating hours. The canton ' s stated goal in making these meeting rooms available is "to encourage the utilize of library meeting rooms for educational, cultural, and customs related meetings, programs, and activities." Under the library ' s coming together room policy, "[n]on-profit and civic organizations, for-profit organizations, schools and governmental organizations" may use the meeting room space for "meetings, programs, or activities of educational, cultural, or community involvement."

The County regulates employ of the meeting rooms in the following ways:

1. library meeting rooms are available on a first-come, showtime-served basis;

2. the applicant must submit an application that identifies the bidder and purpose of the meeting;

3. access to the coming together room is contingent upon approval by the library staff, and the County library reserves the correct to deny an application or revoke permission previously granted;

four. an applicant must pay a fee for use of the meeting room when a meeting is non open up to the general public, when it charges an admission fee, or when information technology involves sales or solicitations;

v. schools may non utilise a meeting room "for instructional purposes equally a regular part of the curriculum"; and

half-dozen. the library meeting room "shall not be used for religious services."

Organized religion Centre Evangelistic Ministries Outreach reserved a meeting room at the library for a four-hour catamenia. In its promotional flyers, Faith Center described the scheduled meeting as having ii components: two hours in the morning for a "Wordshop" entitled "The Making of an Intercessor, an End-Fourth dimension call to Prayer for every Laic, and how to pray fervent, effectual Prayers that God hears and answers," and 2 hours in the afternoon for a "Praise and Worship" meeting, including a sermon. The library ultimately advised Faith Center that it could conduct its "Wordshop" simply not its "Praise and Worship" session.

District Court Ruling

1. The district court enjoined the County ' southward policy because it was likely to result in impermissible viewpoint discrimination. (Religion Ctr. Church Evangelistic Ministries v. Glover, 2005 WL 1220947 (N.D. Cal. 2005) The district court based its order on 4 legal bounds:

ane. religious worship is speech protected past the Commencement Amendment;

two. religious worship cannot exist distinguished from other forms of religious oral communication;

3. the exclusion of religious worship from otherwise permissible speech communication of a religious nature constitutes viewpoint discrimination;

four. at that place was no compelling Establishment Clause concern to justify Faith Center ' south exclusion.

The district court fabricated clear that it proceeded on the basis that the afternoon "praise and worship" session constituted pure religious worship services. Religion Center did non dispute this contention because it argued that fifty-fifty if the afternoon session was mere religious worship, the court could not draw a constitutionally permissible distinction between afternoon worship and the residue of Organized religion Centre ' s religious speech activities.

Religion Center appealed the District Courtroom ' s ruling to the Ninth Excursion Court of Appeals.

Circuit Court of Appeals Ruling

A divided three-member panel of the Ninth Excursion Court of Appeals disagreed with the distinction the District Courtroom made. The majority alleged that pure religious worship is not a secular activeness that conveys a religious viewpoint on an otherwise permissible bailiwick thing, (Faith Ctr., 462 F.3d at 1210). In the majority ' southward view religious worship is non a viewpoint only a category of word, and a coating exclusion of religious worship services from the forum is a permissible one based on the content of speech communication. Judge Tallman dissented, describing the county as having drawn an arbitrary line.

The court considered a motion to rehear the case "en banc," which ways the entire Ninth Circuit Court membership, instead of a three-judge panel, would make up one's mind the case. But at that place was not a majority in favor of doing this.

Dissenting Judges

Vii of the member Ninth Circuit filed a potent dissenting opinion concerning the denial of the motion to rehear the case en banc. The dissenters alleged that by permitting the canton to justify its discrimination and exclusion on the religious nature of the speech, the bulk has effectively relegated religious worship to an junior condition vis-�-vis community and cultural voice communication that claims a secular component. The dissenters claimed that this disparate treatment finer nullifies the Supreme Court ' s statement in Widmar that religious worship and discussion are forms of voice communication and association protected by the First Subpoena, and runs counter to the equal access cases that follow Widmar, including Good News Society v. Milford Cent. Sch., 533 U.South. 98 (2001); Rosenberger, 515 U.S. 819 ; and Lamb ' s Chapel v. Ctr. Moriches Sch. Dist., 508 U.Southward. 384, (1993) ).

GC:ts

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Source: https://www.cga.ct.gov/2007/rpt/2007-R-0353.htm

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