[FN1] While similar practices might have gone unchecked in the past, several recent Supreme Court decisions have limited the days of blind indifference to these rituals.
Pre-game prayers are regularly held in public high school and university locker rooms throughout the United States. These rituals are often undertaken without any thought to possible legal consequences because the coach, team, or school have never received any complaints from concerned athletes or parents. However, the Supreme Court has recently limited the various avenues by which prayers can enter into public school activities. [FN2]
The First Amendment protects student-athletes by providing them with certain safeguards against state endorsed adherence to a specific religion, most often the coach's religion. This constitutional protection must be balanced against the coach's right to effectively run his or her team without having every word or action scrutinized. The conflict of prayer in a public university locker room centers on the students' right to be free from state imposed religious indoctrination and the coach's right to free speech. ...
The players' interest in practicing their religion is weighed against a coach's right to motivate his/her team. Both of these rights have to be examined in light of any action undertaken or attributable to the state, and whether those actions constitute endorsement of the prayers by the state. Based on the present state of intercollegiate athletics, the student-athletes' right to be protected from religious indoctrination by a coach supersedes a coach's free speech right. However, voluntary, neutral moments of silence would neither impinge on a student-athlete's rights nor curtail a coach's right to effectively motivate his or her team.
II. The Establishment Scale From Public School Prayer Through Prayer Opening Legislative Sessions
Team prayer in a public university locker room can be looked at as a morale booster and a tool to build team unity. Team prayer also requires the application of the First Amendment to protect the rights of student-athletes opposed to or uncomfortable with the prayer. Even if student-athletes do not object to the prayers, the prayers can constitute a violation of the First Amendment. The First Amendment's Establishment Clause "protects every individual's right to freedom of belief while the Free Exercise Clause protects the individual's freedom to practice his [or her] religion." [FN3] The Establishment Clause requires the state to be "neutral in its relations with groups of religious believers and non-believers; it does not require the state to be their adversary. State power is no more to be used so as to handicap religions then it is to favor them." [FN4]
To help ensure a degree of separation between church and state, a