Allegheny County v. ACLU
Citation and Court
492 U.S. 573 (1989) — Supreme Court of the United States
Facts
Allegheny County, Pennsylvania permitted two holiday displays on public property: a crèche (nativity scene) inside the Allegheny County Courthouse staircase, erected by a Catholic organization, and a large Hanukkah menorah outside the City-County Building, placed next to a Christmas tree and a sign saluting liberty. The ACLU challenged both displays under the Establishment Clause.
Issue
Whether government display of a crèche inside a courthouse and a menorah outside a public building violate the Establishment Clause of the First Amendment.
Holding
The crèche inside the courthouse violates the Establishment Clause because it sends an unmistakable message of government endorsement of Christianity; the menorah outside, displayed alongside a Christmas tree and liberty sign in a context of holiday pluralism, does not.
Rule / Doctrine
Endorsement test: government action violates the Establishment Clause when it conveys a message that religion or a particular religion is favored or preferred. Context determines whether a display endorses religion — a crèche standing alone in a government building conveys endorsement, while a menorah alongside secular holiday symbols in a pluralistic display does not.
Significance
Allegheny County is significant for applying Justice O’Connor’s endorsement test — developed in Lynch v. Donnelly (1984) — to reach different results for two holiday symbols based on their context. It reflects the Court’s case-by-case analysis of Establishment Clause violations and is frequently cited alongside Lynch and Lee v. Weisman in Establishment Clause courses.