This week, you will complete your annotated bibliography Find two appropriate non-scholarly sources using a search engine such as Google or Bing. Create APA references for the non-scholarly sources.

1 Prayer in Public Schools Sara Lance Ashford University GEN103: Information Literacy Instructor Smoak April 29 , 2020 For APA 7 th edition, no header is required. The page number should be at the top right of each page. Fill in the title that you’ve chosen for your paper, your name, your instructor’s name and the date. 2 Prayer in Public Schools Research Question: How have the courts weighed factors regarding the legality of prayer in American public schools? Thesis Statement : When considering prayer in public school cases, the courts have sought to balance the Free Exercise and Establishment Clauses of the First Amendment in a way that protects students’ right to pray individually and initiate religious activity but also protec ts students from being pressured into participating in prayer or other religious activi ty in school. Annotation 1: Scholarly Article 1: Reference : Lain, C. B. (2015). God, civic virtue, and the American way: Reconstructing Engel. Stanford Law Review , 67 (3), 479 -555. https://doi -org.proxy - library.ashford.edu/10.31228/osf.io/fzhwp Annotation: This scholarly article focuses on the Supreme Court case Engel v Vitale (decided in 1963), which set the precedent that state -sponsored prayer in school is unconstitutional. The author argues that while the decision was originally seen as, and continues to be seen as, protecting religious minorities from being forced to participate in th e religious practices of the religious majority, the Supreme Court Justices did not view it that way during the decision making process. Rather, the Supreme Court Justices took into account demographic changes (a significant increase in the Catholic popula tion) as well as cultural changes (a substantial decrease in anti -Semitism after the Holocaust) that had created a more pluralistic society; they did not see themselves as protecting a religious Remember to include your research question here. Convert your research question into a thesis statement and type it here . For help, you can refer to the Writing Center’s Thesis Statement Tutorial . Your annotation belongs here. Be sure to include all of the elements outlined in the assignment instructio ns. The APA -formatted reference for your scholarly article goes here. If you need help with formatting, visit the Writing Center. 3 minority but as recognizing that there was not a prayer, no matter now bland and generic, that could avoid offending some parties. In addition, the Supreme Court Justices looked at the plain text of the First Amendment and determined that requiring public school students to recite a state -written prayer was clearly endorsing religion. There was little disagr eement on these points as indicated by the 6 -1 decision, with one vacancy on the court and one justice too ill to participate in deliberations. The author used a variety of sources as evidence for this article, including the text of this and other Supreme Court decisions, quotes from an interview with Justice Black, many newspaper and magazine articles from the time period as well as historical and legal books and journal articles. Many of the sources that I’ve read mentioned the Engel v. Vitale decision and indi cated its importance to this issue but this journal article provides detailed explanation of why and how the case began as well as the reasoning behind the decision, backed up a variety of historical and legal sources. The author thoroughly supported her points throughout the article with extensive sources. In addition to the text of the decision and an interview with Justice Black, the author also used the personal papers o f Justice Black to support her argument. This article provides relatively current information, having been published in 2015. A significant portion of the evidence supporting the thesis from the original court case in the early 1960s but the author also used more contemporary legal, scholarly, and news sources, all the way up to the yea r before this article was published. The author has significant authority on this topic as a Professor of Law and Associate Dean at the University of Richmond School of Law. In addition, this article was published by the Stanford Law Review, which is wel l- known and well -respected as a scholarly law journal. The most obvious limitation of this You will copy and paste the references and annotations for the two scholarly articles and eBook from your week 3 assignment into this assignment. Be sure to make any revisions recommended by your instructor Your annotations should be in your own words; there should be no quotes at all. In -text citations are not needed because you will not have quotes and it is understood that all information comes from the source referenced above the annotation. 4 article is that it focuses on the Engel v Vitale ruling; a number of other court rulings, both by the Supreme Court and by lower courts, are relevant to my research question but are not addressed in this article . This journal article answers my research question by explaining the reasoning behind the Engel v Vitale ruling, which set the original precedent by which other religion in school cases were decided. It provides specific information from the ruling and the historical context in which the ruling was made as well as information about the public and media react ion to the ruling. Annotation 2: Scholarly Article 2: Reference : Warnick, B. R. (2012). Student rights to religious expression and the special characteristics of schools. Educational Theory , 62 (1), 59 -74. https://doi - org.proxy -library.ashford.edu/10.1111/j.1741 -5446.201 1.00435.x Annotation: In this scholarly peer -reviewed article, Warnick examines the difficulty in balancing two different parts of the First Amendment of the Constitution, the Establishment Clause with the Free Exercise Clause, to show why it is difficult to determine what religious activities are permissibl e for students in the public school environment. The Establishment Clause prevents any part of the government from establishing or endorsing religion while the Free Exercise Clause guarantees individuals the right to freely engage in religious activities. Within the public school environment, students have the right to engage in student -initiated prayer or other religious activity. Student -initiated religious activity must be accommodated by school officials and it is often accommodated by allowing the use of school property and other resources, which may give the appearance of official Only the first word of the title, the subtitle, and proper nouns should be capitalized. Also, remember to italicize the name of the journal. 5 endorsement of the religious activity. This can create difficulty in determining when student -initiated religious activity has crossed the line into unconstitutional activity. The author also argues that school are unique areas in American society because education is compulsory, they serve a range of ages, and because students a re expected to gain a wide range of competencies, eventually becoming capable members of society who understand how ideas (both religious and secular) function to produce political outcomes. These three elements that make schools a special place in America n society contribute to the difficulty with balancing the Free Exercise Clause with the Establishment Clause and make the issue particularly controversial. Warnick used many scholarly sources as references. He cited numerous education, legal, and philoso phy journal articles and books to support his points as well as relevant Supreme Court cases. This article is different from ma ny of the sources I’ve read because it explains why the issue of religious expression in schools is complicated, both from the viewpoint of allowing students the freedom of expression in a constitutional way and from the viewpoint of ensuring that students receive a complete educational experience. In this article, the author argues that the issue of prayer and religious activity in public school is nuanced and complex; he supports that thesis well by citing many educational, legal and philosophical source s that validated each element of his argument. The article was published in 2012, so it is relatively current . The author, Bryan R. Warnick, has authority on this issue as professor of Philosophy of Education at Ohio State University. The journal, Educa tional Theory , was founded in 1951 and is a peer -reviewed journal so this article is credible. The article is interesting but limited in usefulness to me because the factors that courts consider is not the main focus . Instead, the author discussed Provide enough detail in your annotations to fully describe your sources and explain how they fit into your research project. Be sure to discuss the sources (evidence) that the author used to support his/her points. 6 balanc ing the Free Exercise Clause and the Free Establishment Clause as part of a larger discussion of the complexities of prayer and re ligious activities in public school. This article answers my research question by explaining how the two clauses of the First Amendment that are relevant to the issue of religious activity in public school, the Free Exercise Clause and the Establishment Clause, apply in a school setting and how they can be difficult to reconcile. An notation 3 : eBook : Reference: Haiman, F. S. (2003). Religious Expression and the American Constitution . Michigan State University Press. Annotation: This eBook examines man y different facets of the First Amendment of the Constitution, generally focusing on how it has been applied in court cases related to religion in American society and the evolution of First Amendment cases throughout American history. Of particular relev ance to my research question is chapter four, “Religious Expression in Public Schools.” This chapter is broken into six parts, covering prayer in school and school -sponsored events, the Pledge of Allegiance, use of school resources for religious meetings o utside of school hours, evolution curriculum, school officials’ religious expression, and censorship of library and curricular resources. The author discusses many Supreme Court and lower court cases, arguing that schools, because they are viewed as shapi ng young minds, are a particular focus of conflict over the proper church -state balance. The courts have endeavored to both protect the rights of students The title of the eBook should be italicized . Because this eBook came from the Ashford Library database, no URL is included in the reference. For the eBook, you may choose to focus on a specific chapter that is of particular importance to your topic. Be sure to clearly explain that chapter’s relevance and discuss the author’s arguments and evidence in that chapter. 7 and faculty to freely exercise their chosen religion while also protect against state coercion to en gage in a specific religion (or any religion) or state endorsement of religion. In general, the goal of the courts has been for the state to be neutral in regard to religion and neither favor or disfavor either a specific religious sect or religious pract ice over nonpractice. The author supported his points in this book by cit ing and referencing Supreme Court and lower court cases, media reports, and scholarly legal articles. This article is similar to other sources that I read on this topic in that it d iscusses some of the same cases and made some similar points. However, it also discussed many lower court cases that were not mentioned in other sources and it addressed issues beyond prayer and student religious activities in school, like religious expre ssion of school officials, censorship of library and curriculum materials, and the teaching of evolution. The thesis of the relevant chapter of this eBook is best summarized by saying that the courts have wor ked to balance the rights enumerated in the First Amendment on various religious issues that find their way into public schools. The author supported that thesis we ll by exploring those various topics and explaining how court rulings have evolved over time, building on precedent. Although the author cited some scholarly secondary sources, the majority of sources cited and referenced are court cases, illustrating the focus of the author on discussing court rulings. This eBook is less current than other sources chosen for this project, having been published in 2003. However, it is still current enough for this topic and contains significant useful information. The auth or, Franklyn S. Haiman, was Emeritus Professor of Communication Studies at Northwestern University. He wrote additional scholarly works on the First Amendme nt and a national award for freedom of expression was named in his honor. It would appear that he w as an authority No source can cover all aspects of a topic so they all have some limitations. Think carefully about where the source might be lacking. 8 on this issue. The eBook was published by the Michigan State University Press , which indicates that this is a scholarly book and that it is a credible source. The limitation of this source is primarily that it is older and so does not inc lude any cases or scholarship written since 2003. In addition, the author largely used court cases as sources; while there are some scholarly secondary sources cited and referenced, there are clearly fewer scholarly secondary sources used in this source t han in other scholarly sources used for this project. While this source provides a thorough history of the evolution of the history of religion in public school cases, it does not place them in the context of the scholarly discussion as well as other sour ces in the project. This eBook addresses my research question by looking at issues beyond just prayer in public school. By examining other issues that fall under the First Amendment legal umbrella, it is easier to see how the courts have worked to find a balance between the Free Expression and Establishment Clauses. In addition, because this eBook also discusses lower court cases, it was easier to understand how the precedent set by the Supreme Court cases affected subsequent cases that came before these courts. An notation 4 : Non -Scholarly Source 1 : Reference : Linder, D. (n.d.). Explor ing constitutional conflicts: P rayer in public schools . Exploring Constitutional Law . http://law2.umkc.edu/faculty/PROJECTS/FTRIALS/conlaw/schoolprayer.html Annotation: This website was created by Doug Linder, a Professor of aw at the University of Misso uri -Kansas City Law School and it is designed to be an educational resource on Be sure to provide the specific URL (web address) for the non - scholarly sources that you use. 9 constitutional issues. This web page specifically addresses the issue of prayer in public schools and it discusses four important Supreme Court cases: Engel v Vitale (1962), Wa llace v Jaffree (1985), Lee v Weisman (1992), and Santa Fe Independent School District v Doe (2000). For each of the four cases, there is a paragraph describing the specifics of each case and how the court ruled. The Engel v Vitale (1962) case concerned student recitation of a state -written prayer, which the court ruled 6 -1 was unconstitutional regardless of whether students were given the option of opting out. In Wallace v Jaffree (1985), the practice of providing a daily moment of silence along with the instruction that students should use it for meditation or silent prayer was challenged and the justices found it to be unconstitutional, 5 to 4. Of particular import ance to this decision were statements by legislators that their goal was to encourage stu dents to pray. In the Lee v Weisman (1992) case, the Supreme Court considered the practice of inviting clergy to perform invocations and benedictions at public school graduations. The justices ruled 5 - 4 that this was an unconstitutional practice. The San ta Fe Independent School District v Doe (2000) case looked at student speech delivered at football games in one Texas school district. Although the school policy did not specify that the speeches should be religious, in practice the speeches were religiou s and students often prayed. In addition, because the student speakers were selected by popular vote and the student body was majority fundamentalist Christian, the speech reflected only that religious view. A majority of the justices (6 -3) decided that an observer was likely to conclude that the school officials endorsed religious speech because it was delivered using school resources at a school sponsored event and with the apparent approval of school officials. The author provided links to the Supreme Court rulings for each of the cases that he discussed but did not Discuss the authority and currency in your annotations as you explain the credibility of your sources. 10 offer other supporting sources as evidence. However, as a Professor of Law, the author has significant authority on this topic and his writing is credible. Although this web page offers less detail on the specific cases than other sources that I’ve read, it provides a useful and concise legal summary for four of the major prayer in p ublic school cases and shows how they are connected. Although the author provided only short summaries of the cases, he also refrained from injecting personal opinion into his writing on the topic, which was not the case for many other sources. This web page highlights the limitations that the Establishment Clause puts on prayer in public schools and, after explaining the basic facts of four Supreme Court cases on this issue, asks the reader a series of questions meant to stimulate further thought on the issue. There is not an argument presented by the author himself, only the decisions of the Supreme Court in those four cases. The author provides a short summary of the cases and links to the full cases , so he provides support for the arguments on the web page. The author is a Law Professor at the University of Missouri -Kansas City Law School , so he has au thority on this topic. The web page is published by the University of Missouri - Kansas City , so it is credible. The obvious limitation of this source is that it is very basic and other sources provide more in -depth information. In addition, it is not cle ar when it was published, nor is it clear when any of the linked sources were published so it is impossible to determine currency. However, none of the information provided on the web page will change as they get older. The web page answers my research qu estion by highlighting four major prayer in public school cases and explaining the legal basis on which they were decided. While it does not provide all of the information that I need, it Note t he limitations of the source and explain how they impact your research project. Explain why they are or are not an issue for your project. 11 does provide a summary of the four cases and an explanation of the basic framework that the courts have used to decide these cases. An notation 5 : Non -Scholarly Source 2 : Reference : Rogers, M. (2009, May 19). Justice Souter and the Supreme Court’s church -state balance . The Brookings Institution . https://www.brookings.edu/opinions/justice - souter -and -the -supreme -courts -church -state -balance/ Annotation: This is an article on a think tank website that was written just after Supreme Court David Souter stepped down from the Supreme Court and before President Obama named his replacement. It discusses the positio ns that Justice Souter took on cases related to the church -state balance with an eye toward how his replacement might change the future Supreme Court rulings in this area. By looking at his writings in Supreme Court rulings in cases specifically related t o religion in public schools and in American society more generally, the author argues that, while only one of nine justices, Justice Souter was a strong voice on these matters and overall argued for more broad interpretations of both the Establishment Cla use and the Free Exercise Clause of the First Amendment. He was concerned with protecting the rights of all Americans to practice their chosen religions, even, and perhaps especially, if they practiced religions that departed from the norm. In arguing fo r a strong interpretation of the Establishment Clause, he again was concerned with the rights of believers of minority religions and of nonbelievers , but he also argued that state endorsement of the majority religion would weaken its integrity. Essentially , Justice Souter argued that the most effective way to protect Americans’ right to freely Be sure to discuss the evidence that the author used to support his/her points. 12 engage in the religious activities of their choice was to prevent the government from any promotion of religion while also guarding against state burdens on religious practice. To support her points, the author cited and referenced numerous Supreme Court cases that addressed the issue of church -state balance. The organization that published this article, the Brookings Institution, is sometimes viewed as a left -leanin g organization. However, all of the author’s points were supported by citations and references to primary source documentation (the Supreme Court rulings). This article is different from other sources that I’ve read because it looks at the arguments made by only one Supreme Court Justice during his time on the court, rather looking at individual cases. As mentioned above, the author su pported her thesis throughout the article by citing relevant Supreme Court rulings. The article was written in 2009, which seems a bit old, but it was written immediately after Justice Souter stepped down and when his impact on the Supreme Court was of in terest to the public. However, it could be the case that a more considered view of his record would be possible after more year go by. The article was published by a think tank that is considered to be of a left -leaning political persuasion. However, t he author, Melissa Rogers, has served as the executive director of the White House Office of Faith -Based and Neighborhood Partnerships, the director of the Center for Religion and Public Affairs at Wake Forest University Divinity School, the executive directo r of the Pew Forum on Religion and Public Life and the general counsel of the Baptist Joint Committee for Religious Liberty. She has also written a book, Religious Freedom and the Supreme Court . She clearly has authority on this topic , the article is wel l-cited, and her writing is credible. A significant limitation of this source is that it is quite brief . Another limitation is that, while the author cited Supreme Court cases, she Discuss any potential bias in the source and explain why that is or is not a concern with the source that you chose. 13 did not cite any scholarly secondary sources , so she did not place the in formation into the relevant scholarly discussion on this topic. This article answers my research question by providing an explanation of how one Supreme Court Justice has applied the Establishment and Free Exercise Clauses of the First Amendment to cases t hat involve questions of church -state balance. Because this article explained Justice Souter’s arguments in a number of cases that looked at different questions, it is easier to see a more holistic theory of how these two clauses fit together.