In recent decades, public school buildings have become increasingly important venues for religious worship services. This is an outgrowth of two factors. First, school districts today commonly make their facilities available during non-school hours to a variety of community groups. This partially reflects schools’ desire to support local community activity, but in many cases they also have significant financial incentives to charge rent for the space. School district community-use policies are typically open to a range of uses and groups, including religious, thus making the space available to religious groups. Indeed, excluding religious uses from a school-created forum could potentially violate the First Amendment, as reflected in a series of Supreme Court decisions.
