Code of Alabama

Ala. Code § 16-1-20.1 (2026)

Period of Silence for Meditation.

✓ official Alabama Legislature (ALISON) text, current July 2026
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Repealed by Act 98-381, p. 715, § 2, effective April 27, 1998.

(Acts 1981, No. 81-357, p. 523.)

Notes of Decisions
Cited in 15 cases, 1982–2010 · leading case: Wallace v. Jaffree, 472 U.S. 38 (1985).
Wallace v. Jaffree, 472 U.S. 38 (1985). · cites it 24× “I concur in the Court's opinion and judgment that Ala. Code § 16-1-20.1 (Supp. 1984) violates the Establishment Clause of the First Amendment.”
Jaffree by & Through Jaffree v. James, 544 F. Supp. 727 (S.D. Ala. 1982). · cites it 9× “It was the Governor’s contention, and since the Governor and the Attorney General had joint representation the Court assumes the Attorney General’s contention, that this Court has no jurisdiction over the issues because prayer flows from the Almighty and neither this Court nor…”
Jaffree v. Wallace, 705 F.2d 1526 (11th Cir. 1983). · cites it 2× “The objective of the meditation or prayer statute (Ala.Code § 16-1-20.1) was also the advancement of religion.”
Sherman Ex Rel. Sherman v. Koch, 623 F.3d 501 (7th Cir. 2010). · cites it 2× “2479 (quoting Alabama Code § 16-1-20.1). The Court held that Alabama's moment of silence law lacked any secular purpose.”
Chandler v. James, 958 F. Supp. 1550 (M.D. Ala. 1997). · cites it 8× “This first statute, which provided for a moment of silence at the beginning of the school day, see Ala.”
Clark v. State, 896 So. 2d 584 (Ala. Crim. App. 2003). “In Wallace , the United States Supreme Court struck down an Alabama statute, § 16-1-20.1, Ala.Code 1975 (repealed), authorizing a "period of silence .”
Jaffree v. James, 554 F. Supp. 1130 (S.D. Ala. 1983). · cites it 3× “The Allegations The complaint in this case alleges that Senate Bill 61 (1982), Senate Bill 8 (1982) and Ala.Code § 16-1-20.1 violate the rights of the plaintiffs to be free from the state endorsement and establishment of any religion.”
Jaffree Et Al. v. Bd. of Sch. Commissioners of Mobile Cnty. Et Al., 459 U.S. 1314 (1983). “At the time, an Alabama statute provided for a one-minute period of silence “for *1315 meditation or voluntary prayer” at the commencement of each day’s classes in the public elementary schools.”
Walter v. West Virginia Bd. of Educ., 610 F. Supp. 1169 (S.D.W. Va 1985). “4 With respect to that provision, the Eleventh Circuit Court of Appeals opined: The objective of the meditation or prayer statute (Ala.Code § 16-1-20.1) was also the advancement of religion.”
Chandler v. James, 958 F. Supp. 1550 (M.D. Ala. 1997). · cites it 8× “” Ala.Code § 16-1-20.1 (1995). Then, in 1982, a third school prayer statute was passed which “recogniz[ed] that the Lord God is one” and permitted public school teachers to lead willing students in a specified prayer.”
May v. Cooperman, 780 F.2d 240 (3rd Cir. 1985). “Alabama Code § 16-1-20.1 (Supp.1984) (emphasis supplied).”
Croft v. Governor of Texas, 530 F. Supp. 2d 825 (N.D. Tex. 2008). “1, which provided: At the commencement of the first class of each day in all grades in all public schools the teacher in charge of the room in which each class is held may announce that a period of silence not to exceed one minute in duration shall be observed for meditation or…”
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