coercion test: In holding that the Establishment Clause prohibits invocations and benedictions at public school graduation ceremonies, the Court - with nary a mention that it is doing so - lays waste a tradition that is as old as public school graduation ceremonies themselves, and that is a component of an even more longstanding American tradition of nonsectarian prayer to God at public celebrations generally. As its instrument of destruction, the bulldozer of its social engineering, the Court invents a boundless, and boundlessly manipulable, test of psychological coercion. Scalia pointed to several historical examples of calling on divine guidance by American Presidents, including Washington's proclamation of the Thanksgiving holiday in 1789 and the inaugural addresses of both Madison and Thomas Jefferson. He disputed the Court's contention that attendance at high school graduation ceremonies was effectively required as part of social norms, and also the conclusion that students were subtly coerced to stand for the rabbi's invocation. In Scalia's view, only official penalties for refusing to support or adhere to a particular religion created an Establishment Clause violation. Subsequent developments The coercion test is now used to determine the constitutionality of certain government actions under the Establishment Clause, along with Justice O'Connor's "endorsement or disapproval" test. The test "seeks to determine whether the state has applied coercive pressure on an individual to support or participate in religion." A broad reading of the Establishment Clause won out, but it seems to have its greatest current application in a public school context. The Court has ruled against the separationist position in several key funding cases since Lee, including the school voucher case Zelman v. Simmons-Harris. However, a majority of the Court continues to maintain a strict ban on most forms of state-sponsored religious exercises in schools themselves, as evidenced by the 6–3 ruling in Santa Fe Independent School District v. Doe, which struck down student-led prayers before public school football games. See also Ahlquist v. Cranston (D.R.I. 2012) a school prayer case in Cranston, Rhode Island List of United States Supreme Court cases, volume 505 Notes References Further reading . External links Establishment Clause case law United States Supreme Court cases United States education case law 1992 in United States case law 1992 in religion 1992 in education American Civil Liberties Union litigation History of Providence, Rhode Island Graduation Education in Providence, Rhode Island United States Supreme Court cases of the Rehnquist Court