Witters v. Washington Department Of Services For The Blind

474 U.S. 481 (1986)

Facts

P applied to D for vocational rehabilitation services pursuant to Wash. Rev. Code § 74.16.181 (1981). P suffered from a progressive eye condition and was eligible for vocational rehabilitation assistance under the terms of the statute. P was attending Inland Empire School of the Bible, a private Christian college in Spokane, Washington, and studying the Bible, ethics, speech, and church administration in order to equip himself for a career as a pastor, missionary, or youth director. D denied P aid stating that the D constitution forbids the use of public funds to assist an individual in the pursuit of a career or degree in theology or related areas, and on its conclusion that P's training was 'religious instruction.' P appealed and the ruling was upheld in the different administrative departments. P then instituted an action in State Superior Court for review of the administrative decision; the court affirmed on the same state-law grounds cited by the agency. The State Supreme Court affirmed as well but chose to base its ruling on the Establishment Clause of the Federal Constitution. The court stated: 'The Supreme Court has developed a 3-part test for determining the constitutionality of state aid under the establishment clause of the First Amendment. 'First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion . . .; finally, the statute must not foster 'an excessive government entanglement with religion.'' The court held that '[the] provision of financial assistance by the State to enable someone to become a pastor, missionary, or church youth director clearly has the primary effect of advancing religion.' The Supreme Court granted certiorari.