The U.S. Supreme Court case Wallace v. Jaffree (1984) centered around the constitutionality of Alabama's moment of silence statute in public schools, which was intended for "meditation or voluntary prayer." Ishmael Jaffree, a parent of three students in Mobile County Public School System, challenged this law on behalf of his children arguing that it violated the First Amendment's Establishment Clause - prohibiting government endorsement or establishment of religion. The court ruled 6-3 in favor of Jaffree stating that Alabama's law had no secular purpose and was solely intended to endorse prayer within public schools thereby violating the Establishment Clause. This decision reaffirmed previous rulings emphasizing separation between church and state particularly within educational settings.

In the dissenting opinion for Wallace v. Jaffree, Justice Rehnquist argued that the majority misinterpreted both historical context and precedent in their decision to strike down Alabama's moment of silence law as a violation of the Establishment Clause. He contended that there was no evidence to suggest that framers intended to prohibit states from establishing religion, pointing out many instances where state governments maintained established churches during early American history. Furthermore, he criticized the Court's reliance on Lemon v. Kurtzman (1971), arguing its three-pronged test had been inconsistently applied and should be abandoned in favor of an interpretation more consistent with original intent. Lastly, he disagreed with characterizing silent prayer or meditation as religious activities per se; rather they could also be seen as secular exercises promoting moral values or mental discipline.