<P> Until the lawsuit, it was commonplace for students to participate in many types of religious activities while at school, including religious instruction itself . Nonreligious students were compelled to participate in such activities and were not usually given any opportunity to opt out . The Murray suit was combined with an earlier case, so the Court might have acted without Murray's intervention . With the success of the lawsuit, the intent of the Constitution with regard to the relationship between church and state again came under critical scrutiny and has remained there to this day . While students do continue to pray in public schools, even in organized groups such as "See You at the Pole", the lawsuit disallowed schools from including prayer as a compulsory activity required of every student . The success of O'Hair's lawsuit led to subsequent lawsuits by Mormon and Catholic families in Texas in 2000 to limit compulsory prayer at school - sponsored football games . </P> <P> Following these two cases came the Court's decision in Lemon v. Kurtzman (1971), a ruling that established the Lemon test for religious activities within schools . The Lemon test states that, in order to be constitutional under the Establishment Clause, any practice sponsored within state - run schools (or other public state - sponsored activities) must adhere to the following three criteria: </P> <Ol> <Li> Have a secular purpose; </Li> <Li> Must neither advance nor inhibit religion; and </Li> <Li> Must not result in an excessive entanglement between government and religion . </Li> </Ol> <Li> Have a secular purpose; </Li>

Who was president when prayer was taken out of schools