In Lee v. Weisman, the United States Supreme Court held that nonsectarian prayers delivered at public school graduation ceremonies violate the Establishment Clause of the Constitution. In reaching its decision, the Court purposefully disregarded the analytical framework established by Lemon v. Kurtzman, and its progeny, in favor of a coercion test. In so doing, the Court's decision not only failed to solve the problems associated with the Lemon framework, but also left Establishment Clause jurisprudence in a greater state of disarray and uncertainty than previously had existed.
William Jonathan Martin II, Lee v. Weisman: No Reason To Give Thanks, 44 Mercer L. Rev. 985 (1993).