Though the courts have consistently barred school-sponsored prayers, when Nicholas Weldy surveyed Ohio school superintendents for his University of Dayton doctoral thesis in 2001, more than 40 percent said there had been some form of prayer at graduation.
Some schools turn a blind eye to serve what they perceive as a greater good. At Hull Middle School in Benton Harbor, Mich., pastors walked the halls, broke up fights, and sat in the back of classrooms, their silent presence exuding authority.
"The kids had tremendous respect for them, probably more than for the police or the truancy officer," says Robert Lawrence, who taught at the school for 10 years before it closed in 2011. In this area, clobbered by unemployment, crime, and drugs, so many middle-schoolers had rap sheets that parole officers had a campus office.
Pastors occasionally addressed morning assembly and sometimes used Christian language in the hallways. But, Mr. Lawrence, who was not religious at the time, says, "I never saw a problem with it." The school population was predominantly African-American and culturally rooted in Christianity, so in his view there was no evangelizing: "It was an all-out war against the streets. Any help anyone could bring was more than welcome."