In Lee v. Weisman (1992), the court prohibited clergy-led prayer at middle school graduation ceremonies.

The effect of this was to prohibit prayer in any Reform synagogue and in many Conservative synagogues.

When the Supreme Court handed down its landmark decision in 1963 prohibiting organized prayer in public schools, many educators took the ruling to mean that any mention of Bible was prohibited.

Happily, on two separate occasions, the Eleventh U.S. Circuit Court of Appeals vacated that part of the district judge's order prohibiting voluntary, vocal prayer.

In the 1930's, however, the First Amendment was not yet interpreted by the courts as prohibiting prayer in the public schools.

"The Lee decision did not prohibit student-initiated, student-led prayer," Mr. Whitehead said, but only what the Court called "pervasive state involvement."

The interpretation of the Establishment Clause is particularly strict when it comes to primary and secondary public schools, and prohibits prayer that appears to have the imprimatur of the administration on it.

This led her to vote to prohibit public prayer at high school graduations and football games, but to insist on equal access for student religious publications and clubs.

While the Supreme Court prohibited organized prayer in public schools in 1962, it has not resolved all the thorny aspects of what is and is not proscribed prayer.

The classroom has long been the most inflammatory pressure point along the church-state boundary, dating to the Supreme Court decisions of the early 1960's that prohibited organized prayer in public schools.