Brief for Psychology and Neuroscience Scholars in Support of Respondent
Mark W. Mosier
Sarah Suwanda
Alexander J. Cave
SimpleOriginal

Summary

Adolescents are behaviorally and neurobiologically predisposed to follow the lead of authority figures, like coaches, and similarly susceptible to pressure—even unconscious, non-explicit pressure—to conform to their peers’ actions.

2022 | Federal Juristiction

Brief for Psychology and Neuroscience Scholars in Support of Respondent

Keywords adolescent athletes; prayers; peer pressure; Establishment Clause; neurobiology; coercive nature of prayers; adolescent brain development; adolescent sensitivity to rewards; neurobiological research; social approval; adolescent vulnerability to negative influences; dual system; neuroimaging; brain imaging; reward-processing brain regions; developmental trajectories
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Summary of Argument

This Court has held that a pregame prayer at a high school football game violated the Establishment Clause because it had “the improper effect of coercing those present to participate in an act of religious worship.” Santa Fe Indep. Sch. Dist. v. Doe, 530 U.S. 290, 312 (2000). Applying this precedent, the lower courts concluded that Petitioner’s postgame prayers at high school football games also violated the Establishment Clause because they, too, coerced students to participate in acts of religious worship. Pet. App. 17–23, 153–60.

Petitioner contends that there can be no coercion here, because he does not think he pressured any stu- dent athlete to participate in his prayers. Pet. Br. 5 (citing Petitioner’s own declaration). But whether Petitioner’s actions were coercive does not depend on Petitioner’s characterization of his actions, even if that characterization were accurate. But see JA 295 (Petitioner sought to “continue” his “practice of praying with students” (emphasis added)). Nor does the coer- cive effect of his postgame prayers turn on whether those prayers were well intentioned, Pet. Br. 7; but see Pet. App. 16 (finding that Petitioner intended to send a message about “appropriate behavior”), or whether Respondent disclaimed responsibility for them, Pet. Br. 9, 33. What matters is whether the student athletes felt coerced to participate in the prayers.

They did. “At least one student felt compelled to join Coach Kennedy’s post-game prayers, contrary to the player’s own beliefs, because he feared he would get less playing time if he did not participate.” Pet. App. 71. Some parents likewise indicated that “their children had participated in the prayers to avoid being separated from the rest of the team or to ensure playing time.” Pet. App. 136; see also JA 186, JA 356. Sev- eral students, and their parents, thanked Respondent for its actions to address the “awkward situations where they did not feel comfortable declining to join with the other players in Mr. Kennedy’s prayers.” JA 359. And when Petitioner did not visibly pray, none of his players did, either. JA 181.

The Court has observed that officially sponsored prayer in public schools poses “heightened concerns with protecting freedom of conscience from subtle coercive pressure.” Lee v. Weisman, 505 U.S. 577, 592 (1992). The coercive pressure to participate in Petitioner’s prayers was anything but subtle. Petitioner prayed on the 50-yard line, immediately following the team’s games, before the players left the field, while spectators remained in the stands. Pet. App. 15, 72.

Petitioner’s actions created pressure to participate to which adolescent student athletes would likely succumb, even if doing so were contrary to their own beliefs and even if the pressure was never explicit. The adolescent student athletes would be influenced to follow Petitioner’s lead because he controlled benefits they valued (such as playing time) and because of his status as a role model and authority figure. Com- pounding that direct pressure, the sight of some teammates, along with classmates and community members, joining Petitioner in prayer influenced more reluctant student athletes to do the same. This pressure to conform—whether explicit or implicit—was undoubtedly amplified by an innate desire to abide by the norms of the team itself, for adolescents are especially vulnerable to peer influence when faced with the possibility of social approval or disapproval.

The fact that most of the team joined Petitioner’s prayers meant that everyone else would likely feel compelled to do so as well. To refuse would be to risk social reprobation from Petitioner, teammates, and classmates. That student athletes felt both direct and indirect pressure—all traceable to Petitioner—to participate in a religious ritual led by a public high school employee underscores what is already well-known by this Court and well-studied in psychology and neurobiology: Adolescents are behaviorally and neurobiologically predisposed to follow the lead of authority figures, like coaches, and similarly susceptible to pres- sure—even unconscious, non-explicit pressure—to conform to their peers’ actions.

I. The Court must consider the coercive nature of Petitioner’s prayers from the perspective of an adolescent. Petitioner’s prayers most directly impacted adolescent student athletes. And as the Court has long recognized—including in cases involving prayer at public schools—psychological and neuroscientific research confirms that adolescents are especially susceptible to outside influences. Recent scientific research, including neuroimaging work, confirms that this vulnerability is the result of two distinct, yet interconnected trajectories of adolescent brain development. While adolescents develop a heightened sensi- tivity to rewards around the time of puberty, including socioemotional rewards, their ability to control their impulses and regulate their behavior develops much more gradually. As a result of these dual systems, rewards have far greater impact on adolescent behavior than adult behavior.

II. This Court, other courts, and even Petitioner himself have noted the influence that coaches have over adolescent student athletes. Coaches are role models with immense power to dispense rewards of great value to student athletes, such as roster spots, playing time, and college recommendations. That power, coupled with adolescents’ heightened rewardsensitivity and still maturing self-control, gives coaches potent influence over athletes’ behavior— even when coaches do not apply explicit pressure. Moreover, because adolescents are especially inclined toward authority figures and role models, a coach’s status as an authority figure and respected mentor adds to his influence.

III. In addition to the influence Petitioner exerted as a coach and role model, the Court must also account for the compounding influence that peers, and teammates in particular, have on one another. Adolescents are driven, more so than any other age group, by their desire for social approval among their peers, their heightened sensitivity to rewards in the presence of peers, and their fidelity to the team identity. Those salient influences were clearly at play here, where Petitioner’s prayers were attended not only by spectators and media but by a majority of the team. Here, too, the compounding effect of peer influence can be traced back to Petitioner. As a coach and role model for the team, the natural result of the direct coercive effect of Petitioner’s prayers was that some players would join—thereby increasing the pressure on their more reluctant teammates to do the same.

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Summary of Argument

I. Adolescent Vulnerability to Coercion

Recent psychological and neuroscientific research confirms that adolescents are particularly susceptible to external influences due to their developing brains. They exhibit heightened sensitivity to rewards, including social approval, while their impulse control and self-regulation abilities are still maturing.

II. Influence of Coaches as Authority Figures

Coaches hold significant power over student athletes as role models and dispensers of valuable rewards such as playing time. This power, combined with adolescents' heightened reward sensitivity and respect for authority figures, gives coaches substantial influence over athletes' behavior, even without explicit pressure.

III. Compounding Effect of Peer Influence

Adolescents are highly motivated by social approval and peer acceptance. The presence of teammates and classmates participating in postgame prayers amplifies the pressure on reluctant individuals to conform. This influence is traceable to the coach's role in fostering team identity and the direct coercive effect of their prayers.

Case Analysis

In the case under consideration, students reported feeling compelled to participate in postgame prayers led by their coach, despite their personal beliefs. This coercion arose from the following factors:

  • Direct Pressure: Fear of reduced playing time or separation from the team.

  • Indirect Pressure: Social disapproval from the coach, teammates, and classmates.

  • Neurobiological Predisposition: Adolescents' heightened reward sensitivity and susceptibility to peer influence.

The combination of these factors created a coercive environment that undermined the students' freedom of conscience. It is crucial to consider the perspective of adolescents, who are the primary targets of such practices, when evaluating the coercive nature of postgame prayers in high school football.

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Summary of Argument

I. Adolescent Perspective

Adolescents are particularly vulnerable to external influences due to their developing brains. They have heightened sensitivity to rewards, including social approval, while their impulse control is still maturing.

II. Influence of Coaches

Coaches hold significant power over student athletes as role models and authority figures. They can influence athletes' behavior through rewards such as playing time, even without explicit pressure.

III. Peer Influence

Adolescents are highly motivated by peer approval and team identity. When a majority of the team participates in an activity, it creates pressure on others to conform.

Analysis

In the case of Petitioner's postgame prayers, the following factors created a coercive environment:

  • Coach's Influence: Petitioner's position as coach gave him significant influence over players.

  • Public Setting: Prayers were conducted on the 50-yard line after games, with spectators present.

  • Peer Pressure: The majority of the team participated, increasing pressure on others to join.

Students reported feeling compelled to participate due to:

  • Fear of losing playing time

  • Desire to avoid separation from the team

  • Social pressure from teammates and classmates

Conclusion

The coercive nature of Petitioner's prayers stemmed from the combined influence of his authority as a coach, the public setting, and the peer pressure created by the team's participation. This pressure was particularly potent for adolescents, given their heightened susceptibility to external influences.

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Summary of Argument

What's the Issue?

A high school football coach prayed on the field after games, and some students felt pressured to join in, even if it went against their beliefs. The question is: Did the coach's prayers violate the rule that the government can't promote religion?

Why It's a Problem

When the government, like a public school, promotes religion, it can make people feel pressured to participate, even if they don't want to. This is especially true for students, who might feel like they have to go along with what their coach or teacher says.

What the Evidence Shows

  • Some students felt like they had to join the prayers to avoid losing playing time or being left out of the team.

  • Parents said their kids felt pressured to pray to fit in.

  • When the coach didn't pray, none of the players did either.

Why Students Are Especially Vulnerable

Teenagers are still developing their brains and are more likely to:

  • Be influenced by authority figures like coaches.

  • Want to fit in with their friends and teammates.

  • Be sensitive to rewards, like playing time.

The Coach's Influence

Coaches have a lot of power over student athletes. They can decide who plays and who doesn't, and they're often seen as role models. This gives them a lot of influence over students' behavior.

The Power of Peers

Teenagers are also very influenced by their peers. They want to be accepted and fit in, so they're more likely to go along with what their friends are doing. When some players joined the coach's prayers, it put pressure on others to do the same.

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Summary of Argument

Some people think it's not okay for a coach to pray after a football game because it might make players feel like they have to pray too, even if they don't want to.

The coach in this story says he didn't make anyone pray, but some players felt like they had to because they were afraid they wouldn't get to play as much if they didn't. Some parents also said their kids prayed because they didn't want to be left out or lose playing time.

Why Kids Might Feel Pressured

Kids are still learning how to make their own decisions and stand up for what they believe in. They also look up to adults like coaches and want to do what they do.

When a coach prays, it can make kids feel like they should too, because the coach is someone they respect and who can give them things they want, like playing time.

How Friends Can Make It Worse

Kids also care a lot about what their friends think. If they see their friends praying with the coach, they might feel like they have to do it too, even if they don't really want to.

All of these things together can make kids feel pressured to pray, even if the coach doesn't say they have to. It's important to remember that everyone has the right to choose whether or not they want to pray.

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Footnotes and Citation

Cite

Brief for Psychology and Neuroscience Scholars as Amici Curiae in Support of Respondent, Kennedy v. Bremerton School District, No. 21-418 (U.S. Apr. 1, 2022).

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