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Completed Lawsuits:

VICTORY: American Humanist Association, John Doe and Jane Doe, as parents and next friends of their minor child, Jill Doe, v. Greenville County School District

The Appignani Humanist Legal Center brought suit against the Greenville County School District in September 2013 challenging the school district’s practices of including prayer in graduation ceremonies and holding elementary school graduations in an evangelical university chapel. The AHA has already succeeded in two appeals to the Fourth Circuit Court of Appeals and is currently on remand from the second appeal.   

In 2014, the AHA successfully appealed the order of Judge G. Ross Anderson Jr., who denied AHA’s motion for a preliminary injunction and motion to allow the individual plaintiffs to proceed anonymously. The Fourth Circuit Court of Appeals admonished: “In denying Plaintiffs’ motion for a preliminary injunction, the district court provided no analysis of the law and made no attempt to apply the four factors [for a preliminary injunction] to the facts as alleged in the complaint.” The Fourth Circuit further agreed with the AHA that Judge Anderson had exhibited such extreme bias against the AHA and its clients that it granted AHA the extraordinary remedy of reassigning the case to a “different district judge on remand.”

On May 18, 2015, the district court held partially in favor of the AHA by declaring that the prayer practice prior to 2013 was unconstitutional, but refused to enjoin future prayers on the reasoning that the school district had adopted a facially-neutral policy.  In its order, the court failed to rule on the constitutionality of the separate practice of using a religious venue to host elementary graduations. The AHA appealed the decision, and Senior Counsel Monica Miller presented oral arguments before the Court on May 10, 2016. On June 21, 2016, the Fourth Circuit ruled in AHA’s favor and vacated and remanded the case back to the district court, with instructions to rule on the merits of the religious venue policy, to determine the extent of AHA’s standing to challenge future prayers, and if standing was found, to reconsider its prior ruling in upholding the practice.   

The AHA won a major victory in December 2017 with the district court holding that the school district’s use of a chapel for graduation ceremonies violated the Establishment Clause and that AHA has standing to challenge future graduation prayers.  The court is still considering the constitutionality of the prayers.


In August 2018, the AHA filed a supplemental memorandum (supported by over 70 exhibits) addressing the outstanding prayer issue. In it, the AHA pointed out that that the district is continuing to subject captive student audiences to graduation prayers, contravening Supreme Court precedent, and even violating the terms of the 2015 injunction by using religious language in written programs, encouraging students to pray, and asking audiences to stand for explicitly Christian prayers. In its July 2019 Order, the U.S. District Court of South Carolina sided with the AHA on the prayer issue and expanded its original injunction order, banning school-sponsored graduation prayers.


C.A. No. 6:13-cv-02471-BHH

Selected Case Documents:

Letter sent to Greenville School District (June 10, 2013)

Complaint (filed September 11, 2013)

Appeal I:

Opening Brief (January 27, 2014)

Reply Brief (March 13, 2014)

Decided May 16, 2014

Appeal II:

Opening Brief (July 21, 2015)

Reply Brief (October 28, 2015)

Oral Arguments (MP3 audio file) (May 10, 2016)

Decided June 21, 2016

District Court Order Issued (December 12, 2017)

Supplemental Memorandum on the Prayer Claim (August 9, 2018)

Court Order (July 18, 2019)


Press Releases:

JULY 19, 2019
VICTORY: Federal Court Bans School-Sponsored Graduation Prayers in South Carolina School District

AUGUST 9, 2018
Atheists Seek to Close the Book on South Carolina Graduation Prayers

DECEMBER 13, 2017

Federal Court Rules in Favor of Humanist Groups of South Carolina Religious Graduation Ceremonies

JUNE 21, 2016

Fourth Circuit Vacates South Carolina Court Ruling on Prayers at Graduation Ceremonies

MAY 10, 2016

AHA Defends Rights of South Carolina Non-Christian Students in Federal Court

MAY 9, 2016
AHA Challenges South Carolina School Districts Religious Graduations in Court

JULY 22, 2015

Humanist Group Appeals Ruling Favoring Religious Graduations at South Carolina School District

MAY 19, 2015

Humanist Group to Appeal South Carolina Court Decision on Religious Graduations

FEBRUARY 4, 2015

Humanist Group Files for Summary Judgment in Public School Prayer Case

JANUARY 27, 2014

Federal Appeal Filed to End Religious Elements in South Carolina Public Schools Graduation Ceremonies

JANUARY 9, 2014

AHA appeals ruling on school events in places of worship

DECEMBER 3, 2013

Case Challenging Prayers, Chapel Use for Public School Graduation Continues in South Carolina

SEPTEMBER 11, 2013

Use of Christian University’s Chapel for Public Elementary School Graduation Results in Lawsuit

JUNE 11, 2013

Christian University’s Chapel Used for Public School Graduation in South Carolina

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