The following excerpt is from Garnett By and Through Smith v. Renton School Dist. No. 403, 865 F.2d 1121 (9th Cir. 1989):
Other circuits considering use of school facilities for religious meetings have held such use to unconstitutionally advance religion. In Brandon v. Board of Educ., 635 F.2d 971 (2d Cir.1980), the court held that permitting prayer meetings in a public high school, even under a neutral equal access policy, would impermissibly advance religion. The court stressed the appearance of school sponsorship that would arise:
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