Editing Sandra Day O'Connor (section)

====First Amendment====
O'Connor was unpredictable in many of her court decisions, especially those regarding First Amendment [[Establishment Clause]] issues. Barry Lynn, executive director of [[Americans United for Separation of Church and State]], said, "O'Connor was a conservative, but she saw the complexity of church-state issues and tried to choose a course that respected the country's religious diversity" (Hudson 2005). O'Connor voted in favor of religious institutions, such as in ''[[Rosenberger v. University of Virginia]]'' (1995), ''[[Mitchell v. Helms]]'' (2000), and ''[[Zelman v. Simmons-Harris]]'' (2002). Conversely, in ''[[Lee v. Weisman]]'' she was part of the majority in the case that saw religious prayer and pressure to stand in silence at a graduation ceremony as part of a religious act that coerced people to support or participate in religion, which the Establishment Clause strictly prohibits. This is consistent with a similar case, ''[[Santa Fe Independent School District v. Doe]]'', involving prayer at a school football game. In this case, O'Connor joined the majority opinion that stated prayer at school football games violates the Establishment Clause. O'Connor was the first justice to articulate the "no endorsement" standard for the Establishment Clause.<ref name="S.M.-2013">{{Cite news|url=https://www.economist.com/blogs/democracyinamerica/2013/10/religious-liberty-and-supreme-court|title=Endorsing the endorsement test|last=S.M.|date=October 8, 2013|newspaper=[[The Economist]]|access-date=June 21, 2017|archive-date=December 20, 2016|archive-url=https://web.archive.org/web/20161220144859/http://www.economist.com/blogs/democracyinamerica/2013/10/religious-liberty-and-supreme-court|url-status=live}}</ref> In ''[[Lynch v. Donnelly]]'', O'Connor signed onto a five-justice majority opinion holding that a nativity scene in a public Christmas display did not violate the First Amendment. She penned a concurrence in that case, opining that the crèche did not violate the Establishment Clause because it did not express an endorsement or disapproval of any religion.<ref name="S.M.-2013" /> In ''Board of County Commissioners, Wabaunsee County, Kansas v Umbehr'' (1996) she upheld the application of first amendment free speech rights to independent contractors working for public bodies, being unpersuaded "that there is a 'difference of constitutional magnitude' ... between independent contractors and employees" in circumstances where a contractor has been critical of a governing body.<ref>[https://www.law.cornell.edu/supct/html/94-1654.ZO.html Board of County Commissioners, Wabaun See County, Kansas, Petitioner v Keen A. Umbehr], 28 June 1996, accessed 18 February 2024</ref>