Determining when prayer is permissible in school can be a difficult task. Typically, when thinking about prayer in public schools, many people assume that all forms of prayer are strictly prohibited. However, this is not always the case. In fact, the U.S. Supreme Court has stated that there is no constitutional principle barring a student from voluntarily praying throughout the school day. Santa Fe Independent School District v. Doe. Ultimately, potential First Amendment violations arise when a school official promotes prayer or school resources are utilized to further prayer.