The Adolescent Family Life Act was designed to address the problem of adolescent pregnancy, and among other things provided grants to public and nonprofit organizations engaged in "educational services relating to family life and problems associated with adolescent premarital sexual relations."
Congress recognized that "legislative or governmental action alone" was insufficient to deal with the problem, and accordingly the Act required that all federally funded services should "emphasize the provision of support by family members, religious and charitable organizataions." In addition, all applicants for federal grants had to demonstrate how they would involve religious and charitable organizations in the delivery of services and counseling.
A number of agencies associated with churches and religious denominations received federal funding under the Act, triggering a lawsuit challenging the validity of the Act. A federal district court struck down the Act, and the case was appealed directly to the Supreme Court.
In a 5-4 decision, the Court concluded that the Act did not violate the nonestablishment of religion clause. "Nothing in our previous cases," noted the Court, "prevents Congress from … recognizing the important part that religion or religious organizations may play in resolving certain secular problems." Further, "religious institutions need not be quarantined from public benefits that are neutrally available to all." However, the Court acknowledged that government funding cannot go to "pervasively sectarian" institutions, or toward "indoctrination into the beliefs of a particular religious faith."
But, the Court concluded that "nothing in our prior cases warrants the presumption" that religious agencies receiving funding under the Act "are not capable of carrying out their functions under the Act in a lawful, secular manner." Bowen v. Kendrick, 108 S. Ct. 2562 (1988)
