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The Supreme Court formulated the 'coercion test' when it held unconstitutional the practice of including invocations and benedictions in the form of 'nonsectarian' prayers at public school graduation ceremonies. Lee, 505 U.S. at 599. Declining to reconsider the validity of the Lemon test, the Court in Lee found it unnecessary to apply the Lemon test to find the challenged practices unconstitutional. Id. at 587. Rather, it relied on the principle that 'at a minimum, the Constitution guarantees that government may not coerce anyone to support or participate in religion or its exercise, or otherwise to act in a way which establishes a state religion or religious faith, or tends to do so.' Id. (citations and internal quotation marks omitted).
The Court first examined the degree of school involvement in the prayer, and found that 'the graduation prayers bore the imprint of the State and thus put school-age children who objected in an untenable position.' Id. at 590. The next issue the Court considered was 'the position of the students, both those who desired the prayer and she who did not.' Id. Noting that 'there are heightened concerns with protecting freedom of conscience from subtle ...
