document_title: Separation of church and state in the United States

question_text: the wall of seperation between church and state is best found in what clause of the constitution

question_tokens: the wall of seperation between church and state is best found in what clause of the constitution

text: Separation of church and state in the United States

text: Early history[edit]

text: Many early immigrant groups traveled to America to worship freely, particularly after the English Civil War and religious conflict in France and Germany.[9] They included nonconformists like the Puritans, who were Protestant Christians fleeing religious persecution from the Anglican King of England. Despite a common background, the groups' views on religious toleration were mixed. While some such as Roger Williams of Rhode Island and William Penn of Pennsylvania ensured the protection of religious minorities within their colonies, others like the Plymouth Colony and Massachusetts Bay Colony had established churches. The Dutch colony of New Netherland established the Dutch Reformed Church and outlawed all other worship, though enforcement was sparse. Religious conformity was desired partly for financial reasons: the established Church was responsible for poverty relief, putting dissenting churches at a significant disadvantage. This, along with many other statements should be footnoted, as it seems more like an opinion than a fact.

text: Former state churches in British North America[edit]

text: Catholic colonies[edit]

text:
When New France was transferred to Great Britain in 1763, the Catholic Church remained under toleration, but Huguenots were allowed entrance where they had formerly been banned from settlement by Parisian authorities.
The Colony of Maryland was founded by a charter granted in 1632 to George Calvert, secretary of state to Charles I, and his son Cecil, both recent converts to Catholicism. Under their leadership many English Catholic gentry families settled in Maryland. However, the colonial government was officially neutral in religious affairs, granting toleration to all Christian groups and enjoining them to avoid actions which antagonized the others. On several occasions low-church dissenters led insurrections which temporarily overthrew the Calvert rule. In 1689, when William and Mary came to the English throne, they acceded to demands to revoke the original royal charter. In 1701 the Church of England was proclaimed, and in the course of the eighteenth century Maryland Catholics were first barred from public office, then disenfranchised, although not all of the laws passed against them (notably laws restricting property rights and imposing penalties for sending children to be educated in foreign Catholic institutions) were enforced, and some Catholics even continued to hold public office.
Spanish Florida was ceded to Great Britain in 1763, the British divided Florida into two colonies. Both East and West Florida continued a policy of toleration for the Catholic Residents.

text: Protestant colonies[edit]

text:
The colony of Plymouth was founded by Pilgrims, English Dissenters or Separatists, Calvinists.
The colonies of Massachusetts Bay, New Haven, and New Hampshire were founded by Puritan, Calvinist, Protestants.
New Netherland was founded by Dutch Reformed Calvinists.
The colonies of New York, Virginia, North Carolina, South Carolina, and Georgia were officially Church of England.

text: Colonies with no established church[edit]

text:
The Province of Pennsylvania was founded by Quakers, but the colony never had an established church.
West Jersey, also founded by Quakers, prohibited any establishment.
Delaware Colony
The Colony of Rhode Island and Providence Plantations, founded by religious dissenters, is widely regarded as the first polity to grant religious freedom to all its citizens.

text: Tabular summary[edit]

text:
Colony
Denomination
Disestablished1

Connecticut
Congregational
1818

Georgia
Church of England
17892

Maryland
Catholic/Church of England
1701/1776

Massachusetts
Congregational
1780 (in 1833 state funding suspended)3

New Brunswick
Church of England

New Hampshire
Congregational
17904

Newfoundland
Church of England

North Carolina
Church of England
17765

Nova Scotia
Church of England
1850

Prince Edward Island
Church of England

South Carolina
Church of England
1790

Canada West
Church of England
1854

West Florida
Church of England
N/A6,7

East Florida
Church of England
N/A6,7

Virginia
Church of England
17868

West Indies
Church of England
1868

text: ^Note 1: In several colonies, the establishment ceased to exist in practice at the Revolution, about 1776;[10] this is the date of permanent legal abolition.

text: ^Note 2: in 1789 the Georgia Constitution was amended as follows: "Article IV. Section 10. No person within this state shall, upon any pretense, be deprived of the inestimable privilege of worshipping God in any manner agreeable to his own conscience, nor be compelled to attend any place of worship contrary to his own faith and judgment; nor shall he ever be obliged to pay tithes, taxes, or any other rate, for the building or repairing any place of worship, or for the maintenance of any minister or ministry, contrary to what he believes to be right, or hath voluntarily engaged to do. No one religious society shall ever be established in this state, in preference to another; nor shall any person be denied the enjoyment of any civil right merely on account of his religious principles."

text: ^Note 3: From 1780 Massachusetts had a system which required every man to belong to a church, and permitted each church to tax its members, but forbade any law requiring that it be of any particular denomination. This was objected to, as in practice establishing the Congregational Church, the majority denomination, and was abolished in 1833.

text: ^Note 4: Until 1877 the New Hampshire Constitution required members of the State legislature to be of the Protestant religion.

text: ^Note 5: The North Carolina Constitution of 1776 disestablished the Anglican church, but until 1835 the NC Constitution allowed only Protestants to hold public office. From 1835 to 1876 it allowed only Christians (including Catholics) to hold public office. Article VI, Section 8 of the current NC Constitution forbids only atheists from holding public office.[11] Such clauses were held by the United States Supreme Court to be unenforceable in the 1961 case of Torcaso v. Watkins, when the court ruled unanimously that such clauses constituted a religious test incompatible with First and Fourteenth Amendment protections.

text: ^Note 6: Religious tolerance for Catholics with an established Church of England was policy in the former Spanish Colonies of East and West Florida while under British rule.

text: ^Note 7: In Treaty of Paris (1783), which ended the American Revolutionary War, the British ceded both East and West Florida back to Spain (see Spanish Florida).

text: ^Note 8: Tithes for the support of the Anglican Church in Virginia were suspended in 1776, and never restored. 1786 is the date of the Virginia Statute of Religious Freedom, which prohibited any coercion to support any religious body.

text: Colonial support for separation[edit]

text: The Flushing Remonstrance shows support for separation of church and state as early as the mid-17th century, stating their opposition to religious persecution of any sort: "The law of love, peace and liberty in the states extending to Jews, Turks and Egyptians, as they are considered sons of Adam, which is the glory of the outward state of Holland, so love, peace and liberty, extending to all in Christ Jesus, condemns hatred, war and bondage." The document was signed December 27, 1657 by a group of English citizens in America who were affronted by persecution of Quakers and the religious policies of the Governor of New Netherland, Peter Stuyvesant. Stuyvesant had formally banned all religions other than the Dutch Reformed Church from being practiced in the colony, in accordance with the laws of the Dutch Republic. The signers indicated their "desire therefore in this case not to judge lest we be judged, neither to condemn least we be condemned, but rather let every man stand or fall to his own Master."[12] Stuyvesant fined the petitioners and threw them in prison until they recanted. However, John Bowne allowed the Quakers to meet in his home. Bowne was arrested, jailed, and sent to the Netherlands for trial; the Dutch court exonerated Bowne.

text: New York Historical Society President and Columbia University Professor of History Kenneth T. Jackson describes the Flushing Remonstrance as "the first thing that we have in writing in the United States where a group of citizens attests on paper and over their signature the right of the people to follow their own conscience with regard to God - and the inability of government, or the illegality of government, to interfere with that."[13]

text: Given the wide diversity of opinion on Christian theological matters in the newly independent American States, the Constitutional Convention believed a government sanctioned (established) religion would disrupt rather than bind the newly formed union together. George Washington wrote a letter in 1790 to the country's first Jewish congregation, the Touro Synagogue in Newport, Rhode Island to state:

text: Allowing rights and immunities of citizenship. It is now no more that toleration is spoken of, as if it were by the indulgence of one class of people, that another enjoyed the exercise of their inherent natural rights. For happily the Government of the United States, which gives to bigotry no sanction, to persecution no assistance requires only that they who live under its protection should demean themselves as good citizens, in giving it on all occasions their effectual support.[14]

text: There were also opponents to the support of any established church even at the state level. In 1773, Isaac Backus, a prominent Baptist minister in New England, wrote against a state sanctioned religion, saying: "Now who can hear Christ declare, that his kingdom is, not of this world, and yet believe that this blending of church and state together can be pleasing to him?" He also observed that when "church and state are separate, the effects are happy, and they do not at all interfere with each other: but where they have been confounded together, no tongue nor pen can fully describe the mischiefs that have ensued." Thomas Jefferson's influential Virginia Statute for Religious Freedom was enacted in 1786, five years before the Bill of Rights.

text: Most Anglican ministers, and many Anglicans, were Loyalists. The Anglican establishment, where it had existed, largely ceased to function during the American Revolution, though the new States did not formally abolish and replace it until some years after the Revolution.

text: Jefferson, Madison, and the "wall of separation"[edit]

text: The phrase "[A] hedge or wall of separation between the garden of the church and the wilderness of the world" was first used by Baptist theologian Roger Williams, the founder of the colony of Rhode Island, in his 1644 book The Bloody Tenent of Persecution.[15][16] The phrase was later used by Thomas Jefferson as a description of the First Amendment and its restriction on the legislative branch of the federal government, in an 1802 letter[17] to the Danbury Baptists (a religious minority concerned about the dominant position of the Congregationalist church in Connecticut):

text: Believing with you that religion is a matter which lies solely between man and his god, that he owes account to none other for his faith or his worship, that the legitimate powers of government reach actions only, and not opinions, I contemplate with sovereign reverence that act of the whole American people which declared that their "legislature" should "make no law respecting an establishment of religion, or prohibiting the free exercise thereof," thus building a wall of separation between church and State. Adhering to this expression of the supreme will of the nation in behalf of the rights of conscience, I shall see with sincere satisfaction the progress of those sentiments which tend to restore to man all his natural rights, convinced he has no natural right in opposition to his social duties.

text: Jefferson's letter was in reply to a letter[18] that he had received from the Danbury Baptist Association dated October 7, 1801. In an 1808 letter to Virginia Baptists, Jefferson used the same theme:

text: We have solved, by fair experiment, the great and interesting question whether freedom of religion is compatible with order in government and obedience to the laws. And we have experienced the quiet as well as the comfort which results from leaving every one to profess freely and openly those principles of religion which are the inductions of his own reason and the serious convictions of his own inquiries.

text: Jefferson and James Madison's conceptions of separation have long been debated. Jefferson refused to issue Proclamations of Thanksgiving sent to him by Congress during his presidency, though he did issue a Thanksgiving and Prayer proclamation as Governor of Virginia.[19][20] Madison issued four religious proclamations while President,[21] but vetoed two bills on the grounds they violated the first amendment.[22] On the other hand, both Jefferson and Madison attended religious services at the Capitol.[23] Years before the ratification of the Constitution, Madison contended "Because if Religion be exempt from the authority of the Society at large, still less can it be subject to that of the Legislative Body."[24] After retiring from the presidency, Madison wrote of "total separation of the church from the state."[25] " "Strongly guarded as is the separation between Religion & Govt in the Constitution of the United States," Madison wrote,[26] and he declared, "practical distinction between Religion and Civil Government is essential to the purity of both, and as guaranteed by the Constitution of the United States."[27] In a letter to Edward Livingston Madison further expanded, "We are teaching the world the great truth that Govts. do better without Kings & Nobles than with them. The merit will be doubled by the other lesson that Religion flourishes in greater purity, without than with the aid of Govt."[28] Madison's original draft of the Bill of Rights had included provisions binding the States, as well as the Federal Government, from an establishment of religion, but the House did not pass them.[citation needed]

text: Jefferson's opponents said his position was the destruction and the governmental rejection of Christianity, but this was a caricature.[29] In setting up the University of Virginia, Jefferson encouraged all the separate sects to have preachers of their own, though there was a constitutional ban on the State supporting a Professorship of Divinity, arising from his own Virginia Statute for Religious Freedom.[30] Some have argued that this arrangement was "fully compatible with Jefferson's views on the separation of church and state;"[31] however, others point to Jefferson's support for a scheme in which students at the university would attend religious worship each morning as evidence that his views were not consistent with strict separation.[32] Still other scholars, such as Mark David Hall, attempt to sidestep the whole issue by arguing that American jurisprudence focuses too narrowly on this one Jeffersonian letter while failing to account for other relevant history[33]

text: Jefferson's letter entered American jurisprudence in the 1878 Mormon polygamy case Reynolds v. U.S., in which the court cited Jefferson and Madison, seeking a legal definition for the word religion. Writing for the majority, Justice Stephen Johnson Field cited Jefferson's Letter to the Danbury Baptists to state that "Congress was deprived of all legislative power over mere opinion, but was left free to reach actions which were in violation of social duties or subversive of good order."[34] Considering this, the court ruled that outlawing polygamy was constitutional.

text: Patrick Henry, Massachusetts, and Connecticut[edit]

text: Jefferson and Madison's approach was not the only one taken in the eighteenth century. Jefferson's Statute of Religious Freedom was drafted in opposition to a bill, chiefly supported by Patrick Henry, which would permit any Virginian to belong to any denomination, but which would require him to belong to some denomination and pay taxes to support it. Similarly, the Constitution of Massachusetts originally provided that "no subject shall be hurt, molested, or restrained, in his person, liberty, or estate, for worshipping God in the manner and season most agreeable to the dictates of his own conscience... provided he doth not disturb the public peace, or obstruct others in their religious worship," (Article II) but also that:

text: the people of this commonwealth have a right to invest their legislature with power to authorize and require, and the legislature shall, from time to time, authorize and require, the several towns, parishes, precincts, and other bodies politic, or religious societies, to make suitable provision, at their own expense, for the institution of the public worship of God, and for the support and maintenance of public Protestant teachers of piety, religion and morality, in all cases where such provision shall not be made voluntarily. And the people of this commonwealth have also a right to, and do, invest their legislature with authority to enjoin upon all the subjects an attendance upon the instructions of the public teachers aforesaid, at stated times and seasons, if there be any on whose instructions they can conscientiously and conveniently attend. (Article III)

text: Since, in practice, this meant that the decision of who was taxable for a particular religion rested in the hands of the selectmen, usually Congregationalists, this system was open to abuse. It was abolished in 1833. The intervening period is sometimes referred to as an "establishment of religion" in Massachusetts.

text: The Duke of York had required that every community in his new lands of New York and New Jersey support some church, but this was more often Dutch Reformed, Quaker or Presbyterian, than Anglican. Some chose to support more than one church. He also ordained that the tax-payers were free, having paid his local tax, to choose their own church. The terms for the surrender of New Amsterdam had provided that the Dutch would have liberty of conscience, and the Duke, as an openly divine-right Catholic, was no friend of Anglicanism. The first Anglican minister in New Jersey arrived in 1698, though Anglicanism was more popular in New York.[35]

text: Connecticut had a real establishment of religion. Its citizens did not adopt a constitution at the Revolution, but rather amended their Charter to remove all references to the British Government. As a result, the Congregational Church continued to be established, and Yale College, at that time a Congregational institution, received grants from the State until Connecticut adopted a constitution in 1818 partly because of this issue.

text: Test acts[edit]

text: The absence of an establishment of religion did not necessarily imply that all men were free to hold office. Most colonies had a Test Act, and several states retained them for a short time. This stood in contrast to the Federal Constitution, which explicitly prohibits the employment of any religious test for Federal office, and which through the Fourteenth Amendment later extended this prohibition to the States.

text: For example, the New Jersey Constitution of 1776 provides liberty of conscience in much the same language as Massachusetts (similarly forbidding payment of "taxes, tithes or other payments" contrary to conscience). It then provides:

text: That there shall be no establishment of any one religious sect in this Province, in preference to another; and that no Protestant inhabitant of this Colony shall be denied the enjoyment of any civil right, merely on account of his religious principles; but that all persons, professing a belief in the faith of any Protestant sect, who shall demean themselves peaceably under the government, as hereby established, shall be capable of being elected into any office of profit or trust, or being a member of either branch of the Legislature, and shall fully and freely enjoy every privilege and immunity, enjoyed by others their fellow subjects.[36]

text: This would permit a Test Act, but did not require one.

text: The original charter of the Province of East Jersey had restricted membership in the Assembly to Christians; the Duke of York was fervently Catholic, and the proprietors of Perth Amboy, New Jersey were Scottish Catholic peers. The Province of West Jersey had declared, in 1681, that there should be no religious test for office. An oath had also been imposed on the militia during the French and Indian War requiring them to abjure the pretensions of the Pope, which may or may not have been applied during the Revolution. That law was replaced by 1799.

text: The Pennsylvania Constitution of 1776 provided:

text: And each member, before he takes his seat, shall make and subscribe the following declaration, viz:

text: And no further or other religious test shall ever hereafter be required of any civil officer or magistrate in this State.

text: Again, it provided in general that all tax-paying freemen and their sons shall be able to vote, and that no "man, who acknowledges the being of a God, be justly deprived or abridged of any civil right as a citizen, on account of his religious sentiments or peculiar mode of religious worship."

text: The U.S. Constitution[edit]

text: Article 6[edit]

text: Article Six of the United States Constitution provides that "no religious Test shall ever be required as a Qualification to any Office or public Trust under the United States". Prior to the adoption of the Bill of Rights, this was the only mention of religion in the Constitution.

text: The First Amendment[edit]

text: The first amendment to the US Constitution states "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof" The two parts, known as the "establishment clause" and the "free exercise clause" respectively, form the textual basis for the Supreme Court's interpretations of the "separation of church and state" doctrine.[37] Three central concepts were derived from the 1st Amendment which became America's doctrine for church-state separation: no coercion in religious matters, no expectation to support a religion against one's will, and religious liberty encompasses all religions. In sum, citizens are free to embrace or reject a faith, any support for religion - financial or physical - must be voluntary, and all religions are equal in the eyes of the law with no special preference or favoritism.[38]

text: The First Congress' deliberations show that its understanding of the separation of church and state differed sharply from that of their contemporaries in Europe.[citation needed] As 19th century Union Theological Seminary historian Philip Schaff observed:

text: The American separation of church and state rests upon respect for the church; the [European anticlerical] separation, on indifference and hatred of the church, and of religion itself…. The constitution did not create a nation, nor its religion and institutions. It found them already existing, and was framed for the purpose of protecting them under a republican form of government, in a rule of the people, by the people, and for the people.[citation needed]

text: An August 15, 1789 entry in Madison's papers indicates he intended for the establishment clause to prevent the government imposition of religious beliefs on individuals. The entry says: "Mr. Madison said he apprehended the meaning of the words to be, that Congress should not establish a religion, and enforce the legal observation of it by law, nor compel men to worship God in any manner contrary to their conscience. ..."[39]

text: Some legal scholars, such as John Baker of LSU, theorize that Madison's initial proposed language—that Congress should make no law regarding the establishment of a "national religion"—was rejected by the House, in favor of the more general "religion" in an effort to appease the Anti-Federalists. To both the Anti-Federalists and the Federalists, the very word "national" was a cause for alarm because of the experience under the British crown.[40] During the debate over the establishment clause, Rep. Elbridge Gerry of Massachusetts took issue with Madison's language regarding whether the government was a national or federal government (in which the states retained their individual sovereignty), which Baker suggests compelled Madison to withdraw his language from the debate.

text: Following the argument between Madison and Gerry, Rep. Samuel Livermore of New Hampshire proposed language stating that, "Congress shall make no laws touching religion or the rights of conscience." This raised an uproar from members, such as Rep. Benjamin Huntingdon of Connecticut and Rep. Peter Sylvester of New York, who worried the language could be used to harm religious practice.

text: Others, such as Rep. Roger Sherman of Connecticut, believed the clause was unnecessary because the original Constitution only gave Congress stated powers, which did not include establishing a national religion. Anti-Federalists such as Rep. Thomas Tucker of South Carolina moved to strike the establishment clause completely because it could preempt the religious clauses in the state constitutions. However, the Anti-Federalists were unsuccessful in persuading the House of Representatives to drop the clause from the first amendment.

text: The Senate went through several more narrowly targeted versions before reaching the contemporary language. One version read, "Congress shall make no law establishing one religious sect or society in preference to others, nor shall freedom of conscience be infringed," while another read, "Congress shall make no law establishing one particular religious denomination in preference to others." Ultimately, the Senate rejected the more narrowly targeted language.

text: At the time of the passage of the Bill of Rights, many states acted in ways that would now be held unconstitutional. All of the early official state churches were disestablished by 1833 (Massachusetts), including the Congregationalist establishment in Connecticut. It is commonly accepted that, under the doctrine of Incorporation—which uses the Due Process clause of the Fourteenth Amendment to hold the Bill of Rights applicable to the states—these state churches could not be reestablished today.

text: Yet the provisions of state constitutions protected religious liberty, particularly the so-called freedom on conscience. During the nineteenth century (and before the incorporation of the First Amendment of the U.S. Constitution through the Fourteenth Amendment), litigants turned to these provisions to challenge Sunday laws (blue laws), bible-reading in schools, and other ostensibly religious regulations.[41]

text: The 14th Amendment[edit]

text: The Fourteenth Amendment to the United States Constitution (Amendment XIV) is one of the post-Civil War amendments, intended to secure rights for former slaves. It includes the due process and equal protection clauses among others. The amendment introduces the concept of incorporation of all relevant federal rights against the states. While it has not been fully implemented, the doctrine of incorporation has been used to ensure, through the Due Process Clause and Privileges and Immunities Clause, the application of most of the rights enumerated in the Bill of Rights to the states.

text: The incorporation of the First Amendment establishment clause in the landmark case of Everson v. Board of Education has impacted the subsequent interpretation of the separation of church and state in regard to the state governments.[42] Although upholding the state law in that case, which provided for public busing to private religious schools, the Supreme Court held that the First Amendment establishment clause was fully applicable to the state governments. A more recent case involving the application of this principle against the states was Board of Education of Kiryas Joel Village School District v. Grumet (1994).

text: The "Separation" principle and the Supreme Court[edit]

text: Jefferson's concept of "separation of church and state" first became a part of Establishment Clause jurisprudence in Reynolds v. U.S., 98 U.S. 145 (1878).[43] In that case, the court examined the history of religious liberty in the US, determining that while the constitution guarantees religious freedom, "The word 'religion' is not defined in the Constitution. We must go elsewhere, therefore, to ascertain its meaning, and nowhere more appropriately, we think, than to the history of the times in the midst of which the provision was adopted." The court found that the leaders in advocating and formulating the constitutional guarantee of religious liberty were James Madison and Thomas Jefferson. Quoting the "separation" paragraph from Jefferson's letter to the Danbury Baptists, the court concluded that, "coming as this does from an acknowledged leader of the advocates of the measure, it may be accepted almost as an authoritative declaration of the scope and effect of the amendment thus secured."

text: The centrality of the "separation" concept to the Religion Clauses of the Constitution was made explicit in Everson v. Board of Education, 330 U.S. 1 (1947), a case dealing with a New Jersey law that allowed government funds to pay for transportation of students to both public and Catholic schools. This was the first case in which the court applied the Establishment Clause to the laws of a state, having interpreted the due process clause of the Fourteenth Amendment as applying the Bill of Rights to the states as well as the federal legislature. Citing Jefferson, the court concluded that "The First Amendment has erected a wall between church and state. That wall must be kept high and impregnable. We could not approve the slightest breach."

text: While the decision (with four dissents) ultimately upheld the state law allowing the funding of transportation of students to religious schools, the majority opinion (by Justice Hugo Black) and the dissenting opinions (by Justice Wiley Blount Rutledge and Justice Robert H. Jackson) each explicitly stated that the Constitution has erected a "wall between church and state" or a "separation of Church from State": their disagreement was limited to whether this case of state funding of transportation to religious schools breached that wall. Rutledge, on behalf of the four dissenting justices, took the position that the majority had indeed permitted a violation of the wall of separation in this case: "Neither so high nor so impregnable today as yesterday is the wall raised between church and state by Virginia's great statute of religious freedom and the First Amendment, now made applicable to all the states by the Fourteenth." Writing separately, Justice Jackson argued that "[T]here are no good grounds upon which to support the present legislation. In fact, the undertones of the opinion, advocating complete and uncompromising separation of Church from State, seem utterly discordant with its conclusion yielding support to their commingling in educational matters."

text: In 1962, the Supreme Court addressed the issue of officially sponsored prayer or religious recitations in public schools. In Engel v. Vitale, 370 U.S. 421 (1962), the Court, by a vote of 6-1, determined it unconstitutional for state officials to compose an official school prayer and require its recitation in public schools, even when the prayer is non-denominational and students may excuse themselves from participation. (The prayer required by the New York State Board of Regents prior to the Court's decision consisted of: "Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers, and our country. Amen.") As the Court stated:

text: The petitioners contend, among other things, that the state laws requiring or permitting use of the Regents' prayer must be struck down as a violation of the Establishment Clause because that prayer was composed by governmental officials as a part of a governmental program to further religious beliefs. For this reason, petitioners argue, the State's use of the Regents' prayer in its public school system breaches the constitutional wall of separation between Church and State. We agree with that contention, since we think that the constitutional prohibition against laws respecting an establishment of religion must at least mean that, in this country, it is no part of the business of government to compose official prayers for any group of the American people to recite as a part of a religious program carried on by government.

text: The court noted that it "is a matter of history that this very practice of establishing governmentally composed prayers for religious services was one of the reasons which caused many of our early colonists to leave England and seek religious freedom in America."[44] The lone dissenter, Justice Potter Stewart, objected to the court's embrace of the "wall of separation" metaphor: "I think that the Court's task, in this as in all areas of constitutional adjudication, is not responsibly aided by the uncritical invocation of metaphors like the "wall of separation," a phrase nowhere to be found in the Constitution."

text: In Epperson v. Arkansas, 393 U.S. 97 (1968), the Supreme Court considered an Arkansas law that made it a crime "to teach the theory or doctrine that mankind ascended or descended from a lower order of animals," or "to adopt or use in any such institution a textbook that teaches" this theory in any school or university that received public funds. The court's opinion, written by Justice Abe Fortas, ruled that the Arkansas law violated "the constitutional prohibition of state laws respecting an establishment of religion or prohibiting the free exercise thereof. The overriding fact is that Arkansas' law selects from the body of knowledge a particular segment which it proscribes for the sole reason that it is deemed to conflict with a particular religious doctrine; that is, with a particular interpretation of the Book of Genesis by a particular religious group." The court held that the Establishment Clause prohibits the state from advancing any religion, and that "[T]he state has no legitimate interest in protecting any or all religions from views distasteful to them." [45]

text:
Those who would renegotiate the boundaries between church and state must therefore answer a difficult question: Why would we trade a system that has served us so well for one that has served others so poorly?

 Justice Sandra Day O'Connor in her opinion on the 2005 Ten Commandments ruling.[46]

tag: div

text: In Lemon v. Kurtzman, 403 U.S. 602 (1971), the court determined that a Pennsylvania state policy of reimbursing the salaries and related costs of teachers of secular subjects in private religious schools violated the Establishment Clause. The court's decision argued that the separation of church and state could never be absolute: "Our prior holdings do not call for total separation between church and state; total separation is not possible in an absolute sense. Some relationship between government and religious organizations is inevitable," the court wrote. "Judicial caveats against entanglement must recognize that the line of separation, far from being a "wall," is a blurred, indistinct, and variable barrier depending on all the circumstances of a particular relationship."

text: Subsequent to this decision, the Supreme Court has applied a three-pronged test to determine whether government action comports with the Establishment Clause, known as the "Lemon Test". First, the law or policy must have been adopted with a neutral or non-religious purpose. Second, the principle or primary effect must be one that neither advances nor inhibits religion. Third, the statute or policy must not result in an "excessive entanglement" of government with religion.[47] (The decision in Lemon v. Kurtzman hinged upon the conclusion that the government benefits were flowing disproportionately to Catholic schools, and that Catholic schools were an integral component of the Catholic Church's religious mission, thus the policy involved the state in an "excessive entanglement" with religion.) Failure to meet any of these criteria is a proof that the statute or policy in question violates the Establishment Clause.

text: In 2002, a three judge panel on the Ninth Circuit Court of Appeals held that classroom recitation of the Pledge of Allegiance in a California public school was unconstitutional, even when students were not compelled to recite it, due to the inclusion of the phrase "under God." In reaction to the case, Elk Grove Unified School District v. Newdow, both houses of Congress passed measures reaffirming their support for the pledge, and condemning the panel's ruling.[48] The case was appealed to the Supreme Court, where the case was ultimately overturned in June 2004, solely on procedural grounds not related to the substantive constitutional issue. Rather, a five-justice majority held that Newdow, a non-custodial parent suing on behalf of his daughter, lacked standing to sue.

text: When the Louisiana state legislature passed a law requiring public school biology teachers to give Creationism and Evolution equal time in the classroom, the Supreme Court ruled that the law was unconstitutional because it was intended to advance a particular religion, and did not serve the secular purpose of improved scientific education.[49] (See also: Creation and evolution in public education)

text: The display of the Ten Commandments as part of courthouse displays was considered in a group of cases decided in summer of 2005, including McCreary County v. ACLU of Kentucky and Van Orden v. Perry. While parties on both sides hoped for a reformulation or clarification of the Lemon test, the two rulings ended with narrow 5–4 and opposing decisions,[vague] with Justice Stephen Breyer the swing vote.

text: On December 20, 2005, the United States Court of Appeals for the Sixth Circuit ruled in the case of ACLU v. Mercer County that the continued display of the Ten Commandments as part of a larger display on American legal traditions in a Kentucky courthouse was allowed, because the purpose of the display (educating the public on American legal traditions) was secular in nature.[50] In ruling on the Mount Soledad cross controversy on May 3, 2006, however, a federal judge ruled that the cross on public property on Mount Soledad must be removed.[51]

text: In what will be the case is Town of Greece v. Galloway, 12-696, the Supreme Court agreed to hear a case regarding whether prayers at town meetings, which are allowed, must allow various faiths to lead prayer, or whether the prayers can be predominately Christian.[52] On May 5, 2014, the U.S. Supreme Court ruled 5-4 in favor of the Town of Greece by holding that the U.S. Constitution not only allows for prayer at government meetings, but also for sectarian prayers like predominately Christian prayers.[53]

text: The Treaty of Tripoli[edit]

text: In 1797, the United States Senate ratified a treaty with Tripoli that stated in Article 11:

text: As the Government of the United States of America is not, in any sense, founded on the Christian religion; as it has in itself no character of enmity against the laws, religion, or tranquillity, of Mussulmen; and, as the said States never entered into any war, or act of hostility against any Mahometan nation, it is declared by the parties, that no pretext arising from religious opinions, shall ever produce an interruption of the harmony existing between the two countries.[54]

text: Interpretive controversies[edit]

text: Some scholars and organizations disagree with the notion of "separation of church and state", or the way the Supreme Court has interpreted the constitutional limitation on religious establishment.[55] Such critics generally argue that the phrase misrepresents the textual requirements of the Constitution, while noting that many aspects of church and state were intermingled at the time the Constitution was ratified. These critics argue that the prevalent degree of separation of church and state could not have been intended by the constitutional framers. Some of the intermingling between church and state include religious references in official contexts, and such other founding documents as the United States Declaration of Independence, which references the idea of a "Creator" and "Nature's God", though these references did not ultimately appear in the Constitution nor do they mention any particular religious view of a "Creator" or "Nature's God."

text: These critics of the modern separation of church and state also note the official establishment of religion in several of the states at the time of ratification, to suggest that the modern incorporation of the Establishment Clause as to state governments goes against the original constitutional intent.[citation needed] The issue is complex, however, as the incorporation ultimately bases on the passage of the 14th Amendment in 1868, at which point the first amendment's application to the state government was recognized.[56] Many of these constitutional debates relate to the competing interpretive theories of originalism versus modern, progressivist theories such as the doctrine of the Living Constitution. Other debates center on the principle of the law of the land in America being defined not just by the Constitution's Supremacy Clause, but also by legal precedence, making an accurate reading of the Constitution subject to the mores and values of a given era, and rendering the concept of historical revisionism irrelevant when discussing the Constitution.

text: The "religious test" clause has been interpreted to cover both elected officials and appointed ones, career civil servants as well as political appointees. Religious beliefs or the lack of them have therefore not been permissible tests or qualifications with regard to federal employees since the ratification of the Constitution. Seven states, however, have language included in their Bill of Rights, Declaration of Rights, or in the body of their constitutions that require state office-holders to have particular religious beliefs, though some of these have been successfully challenged in court. These states are Texas, Massachusetts, Maryland, North Carolina, Pennsylvania, South Carolina, and Tennessee.[57]

text: The required beliefs of these clauses include belief in a Supreme Being and belief in a future state of rewards and punishments. (Tennessee Constitution Article IX, Section 2 is one such example.) Some of these same states specify that the oath of office include the words "so help me God." In some cases these beliefs (or oaths) were historically required of jurors and witnesses in court. At one time, such restrictions were allowed under the doctrine of states' rights; today they are deemed to be in violation of the federal First Amendment, as applied to the states via the 14th amendment, and hence unconstitutional and unenforceable.

text: While sometimes questioned as possible violations of separation, the appointment of official chaplains for government functions, voluntary prayer meetings at the Department of Justice outside of duty hours, voluntary prayer at meals in U.S. armed forces, inclusion of the (optional) phrase "so help me God" in the oaths for many elected offices, FBI agents, etc., have been held not to violate the First Amendment, since they fall within the realm of free exercise of religion.[citation needed]

text: Relaxed zoning rules and special parking privileges for churches, the tax-free status of church property, the fact that Christmas is a federal holiday, etc., have also been questioned, but have been considered examples of the governmental prerogative in deciding practical and beneficial arrangements for the society. The national motto "In God We Trust" has been challenged as a violation, but the Supreme Court has ruled that ceremonial deism is not religious in nature. A circuit court ruling affirmed Ohio's right to use as its motto a passage from the Bible, "With God, all things are possible", because it displayed no preference for a particular religion.[58]

text: Jeffries and Ryan (2001) argue that the modern concept of separation of church and state dates from the mid-twentieth century rulings of the Supreme Court. The central point, they argue, was a constitutional ban against aid to religious schools, followed by a later ban on religious observance in public education. Jeffries and Ryan argue that these two propositions—that public aid should not go to religious schools and that public schools should not be religious—make up the separationist position of the modern Establishment Clause.

text: Jeffries and Ryan argue that no-aid position drew support from a coalition of separationist opinion. Most important was "the pervasive secularism that came to dominate American public life," which sought to confine religion to a private sphere. Further, the ban against government aid to religious schools was supported before 1970 by most Protestants (and most Jews), who opposed aid to religious schools, which were mostly Catholic at the time. After 1980, however, anti-Catholic sentiment has diminished among mainline Protestants, and the crucial coalition of public secularists and Protestant churches has collapsed. While mainline Protestant denominations are more inclined towards strict separation of church and state, much evangelical opinion has now largely deserted that position. As a consequence, strict separationism is opposed today by members of many Protestant faiths, even perhaps eclipsing the opposition of Roman Catholics.[citation needed]

text: Critics of the modern concept of the "separation of church and state" argue that it is untethered to anything in the text of the constitution and is contrary to the conception of the phrase as the Founding Fathers understood it. Philip Hamburger, Columbia Law school professor and prominent critic of the modern understanding of the concept, maintains that the modern concept, which deviates from the constitutional establishment clause jurisprudence, is rooted in American anti-Catholicism and Nativism.[citation needed] Briefs before the Supreme Court, including by the U.S. government, have argued that some state constitutional amendments relating to the modern conception of separation of church and state (Blaine Amendments) were motivated by and intended to enact anti-Catholicism.[59]

text: J. Brent Walker, Executive Director of the Baptist Joint Committee, responded to Hamburger's claims noting; "The fact that the separation of church and state has been supported by some who exhibited an anti-Catholic animus or a secularist bent does not impugn the validity of the principle. Champions of religious liberty have argued for the separation of church and state for reasons having nothing to do with anti-Catholicism or desire for a secular culture. Of course, separationists have opposed the Catholic Church when it has sought to tap into the public till to support its parochial schools or to argue for on-campus released time in the public schools. But that principled debate on the issues does not support a charge of religious bigotry"[60]

text: Steven Waldman notes that; "The evangelicals provided the political muscle for the efforts of Madison and Jefferson, not merely because they wanted to block official churches but because they wanted to keep the spiritual and secular worlds apart." "Religious freedom resulted from an alliance of unlikely partners," writes the historian Frank Lambert in his book The Founding Fathers and the Place of Religion in America. "New Light evangelicals such as Isaac Bachus and John Leland joined forces with Deists and skeptics such as James Madison and Thomas Jefferson to fight for a complete separation of church and state."[61]

text: Politics and religion in the United States[edit]

text: Robert N. Bellah has in his writings that although the separation of church and state is grounded firmly in the constitution of the United States, this does not mean that there is no religious dimension in the political society of the United States. He used the term "Civil Religion" to describe the specific relation between politics and religion in the United States. His 1967 article analyzes the inaugural speech of John F. Kennedy: "Considering the separation of church and state, how is a president justified in using the word 'God' at all? The answer is that the separation of church and state has not denied the political realm a religious dimension."[62]

text: Robert S. Wood has argued that the United States is a model for the world in terms of how a separation of church and state—no state-run or state-established church—is good for both the church and the state, allowing a variety of religions to flourish.[63] Speaking at the Toronto-based Center for New Religions, Wood said that the freedom of conscience and assembly allowed under such a system has led to a "remarkable religiosity" in the United States that isn't present in other industrialized nations.[63] Wood believes that the U.S. operates on "a sort of civic religion," which includes a generally shared belief in a creator who "expects better of us." Beyond that, individuals are free to decide how they want to believe and fill in their own creeds and express their conscience. He calls this approach the "genius of religious sentiment in the United States."[63]


document_title: Ecosystem management

question_text: in ecology what term is used to describe the wise management of natural resources

root

text: Ecosystem management

text: Formulations[edit]

text: A variety of definitions exist: Robert T. Lackey defined ecosystem management as "the application of ecological and social information, options, and constraints to achieve desired social benefits within a defined geographic area and over a specified period." [5] F. Stuart Chapin and coauthors define it as "the application of ecological science to resource management to promote long-term sustainability of ecosystems and the delivery of essential ecosystem goods and services",[6] while Norman Christensen and coauthors defined it as "management driven by explicit goals, executed by policies, protocols, and practices, and made adaptable by monitoring and research based on our best understanding of the ecological interactions and processes necessary to sustain ecosystem structure and function"[7] and Peter Brussard and colleagues defined it as "managing areas at various scales in such a way that ecosystem services and biological resources are preserved while appropriate human use and options for livelihood are sustained".[8]

tag: p

text: The definitions of ecosystem management are typically vague.[9] Several core principles define and bound the concept and provide operational meaning:

text:
ecosystem management reflects a stage in the continuing evolution of social values and priorities; it is neither a beginning nor an end;
ecosystem management is place-based and the boundaries of the place must be clearly and formally defined;
ecosystem management should maintain ecosystems in the appropriate condition to achieve desired social benefits;
ecosystem management should take advantage of the ability of ecosystems to respond to a variety of stressors, natural and man-made, but all ecosystems have limited ability to accommodate stressors and maintain a desired state;
ecosystem management may or may not result in emphasis on biological diversity;
the term sustainability, if used at all in ecosystem management, should be clearly defined—specifically, the time frame of concern, the benefits and costs of concern, and the relative priority of the benefits and costs; and
scientific information is important for effective ecosystem management, but is only one element in a decision-making process that is fundamentally one of public and private choice.[10]

tag: ol

text: A fundamental principle is the long-term sustainability of the production of goods and services by the ecosystem;[6] "intergenerational sustainability [is] a precondition for management, not an afterthought".[7] It also requires clear goals with respect to future trajectories and behaviors of the system being managed. Other important requirements include a sound ecological understanding of the system, including connectedness, ecological dynamics and the context in which the system is embedded. An understanding of the role of humans as components of the ecosystems and the use of adaptive management is also important.[7] While ecosystem management can be used as part of a plan for wilderness conservation, it can also be used in intensively managed ecosystems[7] (see, for example, agroecosystem and close to nature forestry).

text: As a concept of natural resource management, ecosystem management remains both ambiguous and controversial, in part because some of its formulations rest on policy and scientific assertions that are contested.[11] These assertions are important to understanding much of the conflict surrounding ecosystem management. Professional natural resource managers, typically operating from within government bureaucracies and professional organizations, often mask debate over controversial assertions by depicting ecosystem management as an evolution of past management approaches.

text: Stakeholders[edit]

text: Stakeholders are individuals or groups of people who are affected by environmental decisions and actions, but they also may have power to influence the outcomes of environmental decisions relating to ecosystem management.[12] The complex nature of decisions made in ecosystem management, from local to international scales, requires stakeholder participation from a diversity of knowledge, perceptions and values of nature.[13][14] Stakeholders will often have different interests in ecosystem services.[15] This means effective management of ecosystems requires a negotiation process that develops mutual trust in issues of common interest with the objective of creating mutually beneficial partnerships.[16]

text: Adaptive management[edit]

text: Adaptive management is based on the concept that predicting future influences/disturbance to an ecosystem is limited and unclear.[17] Therefore, the goal of adaptive management is to manage the ecosystem so it maintains the greatest amount of ecological integrity, but also to utilize management practices that have the ability to change based on new experience and insights.[18][19]

text: Adaptive management aims to identify uncertainties in the management of an ecosystem while using hypothesis testing to further understand the system.[20] In this regard, adaptive management encourages learning from the outcomes of previously implemented management strategies.[21] Ecosystem managers form hypotheses about the ecosystem and its functionality and then implement different management techniques to test the hypotheses.[22] The implemented techniques are then analyzed to evaluate any regressions or improvements in functionality of the ecosystem caused by the technique.[23] Further analysis allows for modification of the technique until it successfully meets the ecological needs of the ecosystem.[24] Thus, adaptive management serves as a “learning by doing” method for ecosystem management.

text: Adaptive management has had mixed success in the field of ecosystem management, possibly because ecosystem managers may not be equipped with the decision-making skills needed to undertake an adaptive management methodology.[25] Additionally, economic, social and political priorities can interfere with adaptive management decisions.[26] For this reason, adaptive management should be a social process as well as scientific, focusing on institutional strategies while implementing experimental management techniques.[27]

text: Natural resource management[edit]

text: The term natural resource management is frequently used when dealing with a particular resource for human use rather than managing the whole ecosystem.[28] A main objective of natural resources management is the sustainability for future generations, which appoints ecosystem managers to balance natural resources exploitation and conservation over long-term timeframe.[29] The balanced relationship of each resource in an ecosystem is subject to change at different spatial and temporal scales.[30] Dimensions such as, watersheds, soils, flora and fauna, need to be considered individually and on a landscape level. A variety of natural resources are utilized for food, medicine, energy and shelter.[31]

text: The ecosystem management concept is based on the relationship between sustainable resource maintenance and human demand for use of natural resources.[32] Therefore, socioeconomics factors significantly affect natural resource management.[33] The goal of a natural resource manager is to fulfill the demand for a given resource without causing harm to the ecosystem, or jeopardizing the future of the resource.[34] Partnerships between ecosystem managers, natural resource managers and stakeholders should be encouraged in order to promote a more sustainable use of limited natural resources.[35] Natural resource managers must initially measure the overall integrity of the ecosystem they are involved in. If the ecosystem supporting resources is healthy, managers can decide on the ideal amount of resource extraction, while leaving enough to allow the resource to replenish itself for subsequent harvests.[36] Historically, some natural resources have experienced limited human disturbance and therefore have been able to subsist naturally . However, some ecosystems such as forests, which typically provide considerable timber resources; have sometimes undergone successful reforestation processes and consequently have accommodated the needs of future generations. A successfully managed resource, will provide for current demand while leaving enough to repopulate and provide for future demand.

text: Human populations have been increasing rapidly, introducing new stressors to ecosystems, such as climate change and influxes of invasive species. As a result, the demand for natural resources is unpredictable.[37] Although ecosystem changes may occur gradually, the cumulative changes can have negative effects for humans and wildlife.[38] Geographic Information Systems (GIS) and Remote Sensing Applications can be used to monitor and evaluate natural resources by mapping them in local and global scales. These tools will continue to be highly beneficial in natural resources management.[39]

text: Strategic management[edit]

text: Strategic management encourages the establishment of goals that will benefit the ecosystem while keeping socioeconomic and politically relevant issues in mind.[40] Strategic management differs from other types of ecosystem management because it keeps stakeholders involved and relies on their input to develop the best management strategy for an ecosystem. Similarly to other modes of ecosystem management, this method places a high level of importance on evaluating and reviewing any changes, progress or negative impacts and prioritizes flexibility in adapting management protocols as a result of new information.[41]

text: Landscape level conservation[edit]

text: Landscape level conservation is a method that considers wildlife needs at a broader landscape level scale when implementing conservation initiatives.[42] This approach to ecosystem management involves the consideration of broad scale interconnected ecological systems that acknowledges the whole scope of an environmental problem.[43] In a human–dominated world, weighing the landcape requirements of wildlife versus the needs of humans is a complicated matter.[44]

text: Landscape level conservation is carried out in a number of ways. A wildlife corridor, for example, is a connection between otherwise isolated habitat patches that are proposed as a solution to habitat fragmentation.[45] In some landscape level conservation approaches, a key species vulnerable to landscape alteration is identified and its habitat requirements are assessed in order to identify the best option for protecting their ecosystem.[46] However, lining up the habitat requirements of numerous species in an ecosystem can be difficult, which is why more comprehensive approaches to further understand these variations have been considered in landscape level conservation.[47]

text: Human-induced environmental degradation is an increasing problem globally, which is why landscape level ecology plays an important role in ecosystem management.[48] Traditional conservation methods targeted at individual species need to be modified to include the maintenance of wildlife habitats through consideration of both human-induced and natural environmental factors.[49]

text: Command and control management[edit]

text: Command and control management utilizes a linear problem solving approach where a perceived problem is solved through controlling devices such as laws, threats, contracts and/or agreements.[50] This top-down approach is used across many disciplines and works best with problems that are relatively simple, well-defined and work in terms of cause and effect.[51] The application of command and control management has often attempted to control nature in order to improve product extractions, establish predictability and reduce threats.[52] Some obvious examples of command and control management actions include: the use of herbicides and pesticides to safeguard crops in order to harvest more products; the culling of predators in order to obtain larger, more reliable game species; and the safeguarding of timber supply, by suppressing forest fires.

text: Attempts at command and control management often backfire (a literal problem in forests that have been ‘protected’ from fire by humans and are subsequently full of fuel build-up) in ecosystems due to their inherent complexities. Consequently, there has been a transition away from command and control management due to many undesirable outcomes and a stronger focus has been placed on more holistic approaches that focus on adaptive management and finding solutions through partnerships.[53]


document_title: Flight (Grey's Anatomy)

question_text: where is the board going when the plane crashes greys anatomy

text: Flight (Grey's Anatomy)

text: Plot[edit]

text: After their plane crashes in the woods, Dr. Meredith Grey (Ellen Pompeo), Dr. Lexie Grey (Chyler Leigh), Dr. Cristina Yang (Sandra Oh), Dr. Arizona Robbins (Jessica Capshaw), Dr. Derek Shepherd (Patrick Dempsey), and Dr. Mark Sloan (Eric Dane) desperately fight to stay alive. Meredith is relatively unscathed, while the rest have serious injuries: the pilot, Jerry (James LeGros), has a major spine injury, and Yang dislocates her arm. Robbins' femur is broken and sticking through the skin, Sloan has serious internal injuries; though initially adrenaline keeps him on his feet. Shepherd is sucked out the side of the plane and awakens alone in the wood; his mangled hand having been pushed through the door of the plane. However, none are in as bad shape as Lexie, who is crushed under a piece of the plane. While Meredith searches for Shepherd, Yang and Sloan try to move the debris off Lexie. Eventually, the two realize that they cannot save her, so Sloan holds her hand while she dies, telling her that he loves her. As Sloan tells her of the life the two were meant to have together, Lexie dies with a smile on her face just as Meredith and Yang are approaching.

text: Lexie's death devastates Meredith, who is still desperately trying to find her husband. Eventually, she and Shepherd reunite and they fix his hand as best as they can. Meanwhile, back at Seattle Grace Mercy West Hospital, no one is aware of what has happened to the other doctors. Dr. Richard Webber (James Pickens, Jr.) prepares the annual dinner for the departing residents, which Dr. Alex Karev (Justin Chambers), Dr. Jackson Avery (Jesse Williams), and Dr. April Kepner (Sarah Drew) are dreading. Avery makes the choice to take a job offer at Tulane Medical Center, and he and Kepner share a moment. Dr. Ben Warren (Jason George) and Dr. Miranda Bailey (Chandra Wilson) decide to get married, even though Warren is going to start his surgical internship in Los Angeles. After realizing Dr. Teddy Altman (Kim Raver) was offered a chief position at United States Army Medical Command (MEDCOM) and is refusing to leave Seattle out of loyalty, Dr. Owen Hunt (Kevin McKidd), the chief of surgery, fires her to free her from the hospital where her husband died. As the episode ends, Hunt picks up his messages to discover the surgical team never made it to Boise. The residents, finally excited to celebrate at Webber's dinner, are left waiting for their stranded friends. The remaining crash survivors are left struggling to stay awake as their last match goes out. In the closing monologue, Meredith repeats the opening to the speech that Webber gave in the pilot episode of the series.

text: Production[edit]

text:
"It was so hard. It was physically and emotionally challenging because you're constantly at extremely high stakes. The physicality for Cristina, she had to do a lot of things with one arm, and I had to do a lot of things with one shoe. You're running around the mountain with one shoe and one arm basically and doing things that way. And it's like we've had this cushy time on stages and in the hospital. But being out in the open on the side of a mountain was exhilarating; you cannot beat location work. I've done very little greenscreen work, but it's just a pooper. I don't care how much you blow that fan on my face, there's not a helicopter coming at me. It's really hard to manufacture the clear reality of what that is, but when you are on a mountain and you are freezing, you're freezing."

— Oh's impressions on shooting in the mountains[1]

text: The episode was written by Shonda Rhimes, and directed by Rob Corn.[2] Featured music included The Paper Kites' "Featherstone" and Feist's 'Graveyard".[3] Filming took place in Big Bear Lake, California, a location previously used in the seventh season for Yang and Shepherd's fishing trip.[4] Commenting on the filming conditions, Leigh said: "It would rain and be sunny and hot. I never died before [on camera]. That sounds funny saying that. I think everyone has an emotional wellspring and that happened to be a moment where I was sprung. Everybody was very accommodating — the crew, cast. And I opted to stay underneath [the wreckage] for the most part over two days rather than trying to get in and out."[5]

text: In regard to the episode, Rhimes commented before it originally aired that it was difficult to write, largely because of the death of a main character. She compared it to writing the season six finale, by explaining that the former was "more painful" to write.[6] After the episode aired, Rhimes repeated in a tweet that it was hard for her to write the finale, adding: "I did not enjoy it. It made me sick and it made me sad."[7] Rhimes also explained the departure of Leigh, whose character died after the plane crash, by saying that the two came to an agreement on the decision to kill Lexie, after extensive discussion. Speaking of Raver's departure whose character left Seattle Grace for MEDCOM, Rhimes elaborated that Raver was offered a contract renewal, but declined.[7]

text: Reception[edit]

text: The episode received mixed reviews among television critics, and it outperformed the previous episode in terms of both viewership and ratings. "Flight" was originally broadcast on May 17, 2012 in the United States on the American Broadcasting Company (ABC). The episode was watched in the United States by a total of 11.44 million people,[8] a 16.5% (1.62 million) increase from the previous episode "Migration", which garnered 9.82 million viewers.[9] In terms of viewership, "Flight" ranked fourth for the night, behind the season finales of Fox's American Idol, and CBS's Person of Interest and The Mentalist.[8] In terms of Grey's Anatomy's other season finales, the episode was the show's second least-viewed finale, just behind the seventh season's, which garnered 9.89 million viewers.[10] The episode did not rank in the top three for viewership, but its 4.1/11 Nielsen rating ranked first in its 9:00 Eastern time-slot and second for the night, registering the show as Thursday's No. 1 drama, for both the rating and share percentages of the key 18–49 demographic. Its rating lost to American Idol, but beat out CBS's The Big Bang Theory, Person of Interest, and The Mentalist.[8] In addition to its rating being in the top rankings for the night, it was an increase from the previous episode, which netted a 3.5/10 rating/share in the 18–49 demographic.[9] The episode also showed an increase in ratings in comparison to the previous year's finale, which attained a 3.6/9 rating/share in the 18–49 demographic.[10]

text: Poptimal's Tanya Lane wrote, "Wow…just wow. Grey's Anatomy has once again managed to shock with its season finale." While she appreciated the "realism and authenticity that Grey's is known for", she found the episode was "almost too much" as it was "extremely gory and difficult to watch, initially because of the grisly wounds" but later because of the "heavy and emotional things that transpired". She thought Pompeo gave one of her best performances when her character learned that her sister was dead.[11] Digital Spy's Ben Lee found Leigh's and Dane's performances "phenomenal" and added that he had probably never seen a better performance from Dane. He described the moment the two actors shared as "truly poignant". To him, Lexie's death felt like a finale, which was thus too early. As for what was happening in Seattle Grace, he thought it was "a bit pointless" and "uninteresting" except Altman's departure, which he deemed "the most significant moment at the hospital".[12] Entertainment Weekly's Tanner Stransky commented of Lexie's death: "It was an intense death. I mean, how awful was it to watch one of Grey’s longest-running characters pass away so quickly -- and rather unceremoniously? I get that Ms. Rhimes had to do what she had to do -- and every show needs to be shaken up once in a while -- but I don't love that Lexie was the one to die. Could it have been someone less important somehow? I guess it would have been too obvious to do Kepner. And you probably just don't kill off a hottie like Mark Sloan, right?" Stransky also complained about Robbins' screams at the beginning of the episode, but enjoyed Bailey's story.[13]

text: In an Entertainment Weekly poll that judged all the television season finales of the year, Lexie's death was voted the "Top Tissue Moment",[14] while Robbins' injured leg and Shepherd's mangled hand were voted the "Most Disturbing Image".[15] The ending of the episode was also considered as the "Best Ending to an Otherwise So-So Season".[16] Lexie's death was also nominated under the "Best (Presumed) Death" category,[17] while the plane crash's aftermath was nominated as the "Best Non-romantic Cliffhanger",[18] and the episode in entirety was nominated for the special award for "Biggest Regret That I Didn't See It, I Just Heard or Read About It".[19] Entertainment Weekly later named the scene where Meredith is crying one of the best crying scenes of 2012.[20] In TVLine's review of 2012, Lexie's death was runner-up for "Biggest Tearjerker".[21] The episode is nominated at the NAACP Image Awards under the Outstanding Writing in a Dramatic Series category for Rhimes.[22]