open forum for student groups could not deny that forum to a student group wishing to use it for prayer and religious discussion, despite the university’s contention that to permit students to use university facilities for religious purposes would violate the Establishment Clause. Although the Court in Widmar expressly noted that its holding there did not necessarily apply in the secondary school context, see 454 U.S. at 274 n. 14, 102 S.Ct. at 276 n. 14, many members of Congress believed that secondary school students should enjoy the same constitutional rights as their older counterparts. In the absence of an authoritative Supreme Court pronouncement, however, the lower federal courts divided on the question. Compare Brandon v. Guilderland Board of Educ., 635 F.2d 971 (2d Cir.1980) (<HOLDING>), cert. denied, 454 U.S. 1123, 102 S.Ct. 970,
holding no violation of federal establishment clause holding that tax exemption for church property does not violate establishment clause holding that the establishment clause forbids studentinitiated religious meetings on public secondary school property holding that establishment of christmas day as legal public holiday did not violate establishment clause recognizing that the court had to first consider whether the object in question can be defined as religious for establishment clause purposes