Case: Schultz v. Medina Valley Independent School District

Summary posted to the Clearinghouse on August 4, 2020:

On May 26, 2011, an agnostic graduating senior at Medina Valley High School, his older brother (a former student at the school), and their parents filed suit against the Medina Valley Independent School District in the U.S. District Court for the Western District of Texas. Represented by Americans United for Separation of Church and State and by private counsel, the plaintiffs asked the court for declaratory and injunctive relief, nominal damages, and attorneys’ fees, alleging that the School District had violated their First Amendment rights. Specifically, the plaintiffs claimed that the school district, was in violation of the Establishment Clause by engaging in a course of conduct that included “presenting, sponsoring, encouraging, inviting, or coercing prayers at school and school-sponsored activities and events; displaying and permitting the display of crosses and other religious icons; and retaliating against students who complain[ed] about the unlawful promotion of religion or who decline[d] to participate in religious prayers, practices, or rituals.”

The plaintiffs moved for a temporary restraining order and preliminary injunction on the same day that they filed their complaint, hoping to enjoin the school district from featuring prayer at the upcoming high school graduation ceremony scheduled for June 4, 2011, two weeks after the complaint was filed. After a hearing on May 31, the District Court (Judge Fred Biery) granted their motion on June 1, finding that the plaintiffs were likely to succeed on the merits and that failing to issue an injunction would result in irreparable harm to the plaintiffs. It ordered the terms “invocation” and “benediction” stricken and any official group prayer removed from the graduation program.

The school district made an emergency interlocutory appeal to the Fifth Circuit, and on June 3, 2011, a three-judge panel (Judges W. Eugene Davis, Jerry E. Smith and Leslie H. Southwick) issued a per curiam opinion granting the motion to dissolve the temporary restraining order and preliminary injunction. The panel stated that they were not persuaded that the plaintiffs were “substantially likely to prevail on the merits, particularly on the issue that the individual prayers or other remarks to be given by students at graduation were, in fact, school-sponsored.”

The injunction was dissolved, and although the terms “invocation” and “benediction” had already been removed from the printed program, the graduation ceremony the following day included prayer as originally planned.

On July 11, 2011, the district court urged the parties to attempt to settle rather than engage in protracted litigation, and the parties agreed to try mediation. At the end of the summer, however, they reported that they had been unable to reach an agreement.

On September 6, 2011, the school district moved to dismiss the complaint for lack of jurisdiction. This motion was mooted by the plaintiffs’ submission of an amended complaint on November 2, but the school district submitted a second motion to dismiss the amended complaint for lack of jurisdiction on December 9, 2011. A month later, the district moved for summary judgment. The plaintiffs subsequently moved for partial summary judgment on the issue of school prayer.

The court never ruled on any of these motions, however, because the parties were able to settle their dispute in February 2012. On February 8, they submitted a joint motion to approve a proposed agreement. Under the terms of the settlement, the school district agreed to stop initiating, soliciting, or directing prayers at school events, displaying religious symbols and texts at schools, and inviting religious speakers to proselytize, or to play any part in writing or editing student graduation speeches. It further agreed to train its staff in how to comply with the agreement, educate students on religious diversity, and refrain from retaliating against or disparaging the plaintiffs. The agreement allowed student-led prayer at events. The court retained jurisdiction to enforce the settlement for ten years.

On February 9, 2012, the court entered a consent decree approving the settlement.

The following month, the court was called upon to enforce it—the school superintendent and the high school band director each made statements that could be construed as disparaging of the plaintiffs (the former referring to the lawsuit as a “witch hunt” and the latter calling the plaintiffs liars) shortly after the settlement was approved.

On March 19, 2012, the court issued an order requiring the district to apologize, and requiring the plaintiffs to accept the apology. Both did so.

As of August 4, 2020, the case is inactive, but the court retains jurisdiction through February 2022.