The U.S. Supreme Court case Lamb's Chapel and John Steigerwald v. Center Moriches Union Free School District et al., 1992, revolved around the issue of First Amendment rights in relation to public property use for religious purposes. The Center Moriches Union Free School District had a policy that allowed community groups to use its facilities after school hours but prohibited any uses related to religious purposes. Lamb’s Chapel, an evangelical church, requested permission from the district on multiple occasions to show a film series at the school during off-hours which was denied each time due to its religious nature. Lamb's Chapel sued the district arguing this denial violated their First Amendment rights of free speech and religion by discriminating against them based on viewpoint discrimination - treating speech differently because it is associated with a particular viewpoint or ideology. The Supreme Court unanimously ruled in favor of Lamb’s Chapel stating that once government property is opened up as a public forum for communication, all forms of expression must be permitted unless there are compelling reasons not otherwise protected by law.

In the dissenting opinion for Lamb's Chapel and John Steigerwald v. Center Moriches Union Free School District et al., Justice Scalia, joined by Chief Justice Rehnquist, agreed with the majority that denying access to school facilities for religious use was unconstitutional viewpoint discrimination. However, they disagreed on why it was unconstitutional. The dissent argued that the First Amendment's Establishment Clause did not require government neutrality between religion and irreligion nor prohibit government aid to religion as long as it is not used to coerce religious practice or belief. They criticized the Court’s reliance on Widmar v Vincent (1981), arguing instead that this case should be resolved under principles of free speech rather than freedom of religion because a law prohibiting private religious speech in public forums would violate both clauses of the First Amendment.