Debate continues over the place of religious expression, including music, in public schools. In "Nurre v. Whitehead" (2009), a high school senior in Washington sued the superintendent for denying the wind ensemble that she was part of the opportunity to perform an instrumental version of "Ave Maria" at her commencement ceremony due to its religious connotations. Due to the threat of litigation over the place of religious music at graduations and other activities, the author suggests that school business officials and other education leaders must be careful to balance the rights of all involved. In so doing, as suggested by the partial dissent in "Nurre", educators must consider whether forbidding the use of religious music in schools is likely to stifle student expression. At the same time, while seeking to comply with the First Amendment's requirement that school officials "make no law respecting an establishment of religion," educators must be equally as careful to avoid the charge that the student raised in "Nurre", namely, that the superintendent was hostile to religion.