Studies against prayer in public schools typically refer to funding. Private schools can be religious-based as they are run by, and receive funds from, private sources. Public schools, however, receive government subsidies, therefore rendering any religious reference or law unconstitutional as per the Establishment Clause of the First Amendment. Opposition sees required prayer unnecessary, saying that students can pray on their own if they so desire.
Studies in favor of prayer in public schools say that praying would not be mandatory. The studies cite other examples of voluntary implementation of religious beliefs into government such as Christmas celebrations and National Days of Prayer. Those in favor of public school prayer respond to the constitutional argument by stating that since U.S. citizens have freedom of religion, they have the right to pray. Banning prayer, not allowing it, is what these "pro prayer" people deem unconstitutional.
An example of a compromise between the pro and con camps is the suggestion to allow a "moment of silence" in place of prayer in schools. Some of those in favor see this as a way for students to pray silently without imposing their religious beliefs on other students. In this compromise, students who do not wish to pray can study, read a book or perform other activities. Supporters see this as a fair middle-ground solution, while those opposed state it is a veiled circumvention of the anti-prayer laws.
Many parents have sued schools over the issue of prayer. Students shocked by or uncomfortable with morning prayer sessions or song choices in school ceremonies reach out to their parents who then take action. According to the "Brown Daily Herald," in 2011, a student at Cranston High School West in Rhode Island sued school officials over a prayer painted on the wall of the auditorium. In 2003, the Texas Education Code in public schools passed a "minute of silence" that resulted in a lawsuit by one family because a specific teacher referred to the time as specifically "for prayer."