in 1985, westside senior bridget mergens was denied the ability to create an after-school christian bible club. the principal at the time rejected the idea since he said a religious club violated the first amendment's establishment clause. in addition, the club lacked a school sponsor that was required when forming a club. mergens argued that the district's decision was in violation of the federal equal access act requiring that groups seeking to express messages containing “religious, political, philosophical, or other content” not be denied the ability to form clubs. in 1990,westside community board of education v. mergens was heard by the supreme court. in an 8-1 decision, the court said that since the club did not study school curriculum, it was permitted under the equal access act.