Carson v. Makin
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Carson v. Makin and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Carson v. Makin.
The Supreme Court ruled that Maine's nonsectarian requirement for tuition assistance payments violates the Free Exercise Clause of the First Amendment. The Court found that the program discriminates against religious schools by excluding them from receiving public benefits solely due to their religious character. This decision emphasizes that once a state decides to subsidize private education, it cannot disqualify schools solely because they are religious.
Holding
The single most important “bottom line” of what the Court decided in Carson v. Makin.
The Court held that Maine's nonsectarian requirement for tuition assistance payments violates the Free Exercise Clause.
Constitutional Concepts
These are the Constitution-related themes that appear in Carson v. Makin. Click a concept to see other cases that involve the same idea.
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Why Free Exercise of Religion is relevant to Carson v. Makin
The Court held that Maine's nonsectarian requirement for tuition assistance payments violates the Free Exercise Clause.
Syllabus excerpt (verbatim)Maine's 'nonsectarian' requirement for otherwise generally available tuition assistance payments violates the Free Exercise Clause.
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Why Establishment of Religion is relevant to Carson v. Makin
The case involves the balance between the Establishment Clause and the Free Exercise Clause, with Maine's law being challenged as promoting stricter separation of church and state than the Federal Constitution requires.
Syllabus excerpt (verbatim)Maine's decision to continue excluding religious schools from its tuition assistance program after Zelman thus promotes stricter separation of church and state than the Federal Constitution requires.
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Why Equal Protection is relevant to Carson v. Makin
The petitioners alleged that the nonsectarian requirement violated the Equal Protection Clause, although the Court's decision primarily focused on the Free Exercise Clause.
Syllabus excerpt (verbatim)Petitioners sued the commissioner...alleging that the 'nonsectarian' requirement violated...the Equal Protection Clause of the Fourteenth Amendment.
Key Quotes
Short excerpts from the syllabus in Carson v. Makin that support the summary and concepts above.
Maine's 'nonsectarian' requirement for otherwise generally available tuition assistance payments violates the Free Exercise Clause.
A State need not subsidize private education, but once a State decides to do so, it cannot disqualify some private schools solely because they are religious.
Maine's program cannot survive strict scrutiny.
