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Christmas and the Constitution 2023


And it came to pass in those days that a decree went out from Caesar Augustus that all the world should be registered. This census first took place while Quirinius was governing Syria. So all went to be registered, everyone to his own city. Joseph also went up from Galilee, out of the city of Nazareth, into Judea, to the city of David, which is called Bethlehem, because he was of the house and lineage of David, to be registered with Mary, his betrothed wife, who was with child. So it was, that while they were there, the days were completed for her to be delivered. And she brought forth her firstborn Son, and wrapped Him in swaddling cloths, and laid Him in a manger, because there was no room for them in the inn. Now there were in the same country shepherds living out in the fields, keeping watch over their flock by night. And behold, an angel of the Lord stood before them, and the glory of the Lord shone around them, and they were greatly afraid. Then the angel said to them, “Do not be afraid, for behold, I bring you good tidings of great joy which will be to all people. For there is born to you this day in the city of David a Savior, who is Christ the Lord. And this will be the sign to you: You will find a Babe wrapped in swaddling cloths, lying in a manger.” And suddenly there was with the angel a multitude of the heavenly host praising God and saying: “Glory to God in the highest, And on earth peace, goodwill toward men!” Luke 2:1-14 (NKJV) ***** For God so loved the world that He gave His only begotten Son, that whoever believes in Him should not perish but have everlasting life. For all have sinned and fall short of the glory of God… [T]he wages of sin is death, but the gift of God is eternal life in Christ Jesus our Lord…. God demonstrates His own love toward us, in that while we were still sinners, Christ died for us. … if you confess with your mouth the Lord Jesus and believe in your heart that God has raised Him from the dead, you will be saved. John 3:16; Romans 3:23, 6:23, 5:8, 10:9 (NKJV)

Christmas is the time of year that Christian citizens cerebrate one of the most significant events in all of human history, the birth of Jesus Christ. Every year though, like the ancient King Herod, someone tries to kill Baby Jesus sleeping in His manger. Seeking to ban God from the public square, lawyers annually allege the Nativity violates the Establishment Clause of Constitution. See, in the following pages, how the Supreme Court stole the meaning of Christmas – and a the Faith & Freedom Center helped to restore freedom of religious conscious in our nation.


Competing Worldviews, and The First Amendment


How does a person’s worldview influence judicial decision-making concerning the Nativity? The Establishment Clause in the First Amendment to the United States Constitution states: “Congress shall make no law respecting an establishment of religion…”[1] All agree that a government action violates the Establishment Clause if government officially establishes one religion against others. Assuming government does not overtly establish a state religion, how does one decide whether a government action, in connection with the Nativity, survives or fails an Establishment Clause challenge? Any correct determination necessarily requires an understanding of what the Establishment Clause means.

When it comes to judicial review of government action and the Establishment Clause, competing legal-philosophical approaches produce inconsistent judicial precedents, providing little predictability for government officials trying to act constitutionally.[2] Here, the tried and true legal philosophy grounded in America’s deeply rooted cultural and legal traditions (looking to God’s “self-evident” truth), inevitably collides with a legal philosophy embracing an ever-evolving, morally-relative approach.

Some judges interpreting the Establishment Clause see the Constitution through its framers Judeo-Christian / Unalienable Worldview lens. Because they share the Framers’ objective Judeo-Christian Worldview, and because they desire to preserve the unalienable rights that view protects in the Constitution, these judges adhere to the Framers’ intent in their interpretive endeavors. For example, former Chief Justice Burger, writing for the Court in Marsh v. Chambers, recognized the importance of tradition and history in interpreting the Establishment Clause:


[H]istorical evidence sheds light not only on what the draftsmen intended the Establishment Clause to mean, but also on how they thought that Clause applied to [a] practice authorized by the First Congress — their actions reveal their intent.[3]

Looking to such tradition and history, the Court held it did not violate the Establishment Clause for a chaplain, employed by the government, to lead a legislature in prayer prior to a legislative session. The Court in Greece v. Galloway[4] thereafter noted that Marsh stands for the proposition that it is not necessary to define the precise boundary of the Establishment Clause where history shows that the specific practice is permitted. Any test the Court adopts must acknowledge a practice that was accepted by the Framers and has withstood the critical scrutiny of time and political change. The line we must draw between the permissible and the impermissible is one which accords with history and faithfully reflects the understanding of the Founding Fathers. Similarly, in Lee v. Weisman, Justice Scalia, joined by three other justices, stated that: “the meaning of the Clause is to be determined by reference to historical practices and understandings.”[5]

Many judges seeking the Framers’ original intent behind the Establishment Clause see there a desire for government accommodation of religion, equality of treatment, and absence of coercion into religious beliefs or practices by force of law. For example, numerous government policies supporting, acknowledging, and accommodating religion are considered time-honored practices that are part of the nation’s heritage. Those viewing the Constitution through a Unalienable Worldview lens traditionally support such an interpretative approach.[6] Thus, Professor McConnell credibly posits the “separation of church and state is not a limitation on churches or religion; it is a limit on the role of government with respect to churches and religious life in general.”[7]

Other judges, view the Establishment Clause through a morally relative Secular-Humanist Worldview lens. These judges see the Clause as an evolving organism, the meaning of which they believe their worldview empowers them to actively adjust and manipulate.

Let us pause for a moment and observe the immense impact of what is happening here. One of the founding principles of the United States was that we are nation of laws and not of men. This principle is known as the Rule of Law. Under the Rule of Law no person, not even a king, was above the law. The Rule of Law for the American nation is its Constitution, enumerating powers granted to government by the people and limiting the exercise of such power through provisions like the Establishment Clause.

Judges not wanting to be limited by the Rule of Law of our Constitution resort to a Secular-Humanist Worldview approach. Doing so allows them to re-characterize the Rule of Law to include “rule by judges.” Thus, when used by a politically unaccountable judiciary, the evolving, morally-relative Secular-Humanist Worldview temptingly provides an instrument to diminish unalienable religious liberty of some, while creating new rights to advance political interests of others (whether or not supported by a majority of the people). And all this occurs within a worldview that permits judges to call their judicial politicking the “Rule of Law.”

When a subjective worldview leads to applying a judicially active “living constitution” approach to interpreting the Establishment Clause, Congress shall pass no law respecting an establishment of religion evolves into a morally-relative world where government action must comport with judicially deemed illusions of neutrality. Here, to be constitutionally “neutral,” all laws and other government action must have a secular purpose and not even symbolically endorse religion.[8] The Supreme Court in Lemon v. Kurtzman, and its progeny, judicially codified this test in Establishment Clause cases.[9]

Baby Jesus in the Manger

What if government places a Nativity Scene on government property? Can the Savior’s coming be celebrated in the public square?

For over 40 years the City of Pawtucket included a Nativity Scene as part of a Christmas display. The Nativity included Baby Jesus as well as “Mary and Joseph, angels, shepherds, kings, and animals.”[10] Predictably, the ACLU sued the city to ban the Nativity.

In the 1984 case of Lynch v. Donnelly, a majority of the Supreme Court rejected the ACLU’s contention that the government’s display violated the Establishment Clause. Due to the reasoning the Court used to reach its conclusion, however, the victory was a hollow one for Christians.[11] Despite the Court’s acknowledgment of the profound religious heritage in American governance, the Court held the Establishment Clause requires government action to have a secular purpose. The Court, using a Secular-Humanist Worldview, identified the constitutional issue before it as “whether there is a secular purpose for Pawtucket’s display of the [Nativity]?”[12]

Looking at the facts in the case, the majority of the Supreme Court found the government’s purpose sufficiently secular. The city’s display integrated “among other things, a Santa Claus house, reindeer pulling Santa's sleigh, candy-striped poles, a Christmas tree, carolers, …, a clown, an elephant, a teddy bear, hundreds of colored lights, a large banner that reads “SEASONS GREETINGS,” and the [Nativity] at issue…”[13] Apparently, if you sufficiently hide God behind enough other secular stuff, then the display as a whole becomes secular, especially if you characterize what you are celebrating merely as a secular holiday, which the Court did here. And these were the Justices upholding the government’s placement of the Nativity.

Four of the nine Justices in the Lynch case dissented, opining that the city’s inclusion of the Nativity in its Christmas display violated the Establishment Clause because it lacked a secular purpose. The dissent further opined that inclusion of the Nativity in the display violated the Establishment Clause because it provided “a significant symbolic benefit to religion”, suggesting a lack of “neutrality” since the display conveyed to non-Christians and atheists “that their views are not similarly worthy of public recognition….”[14]

In Allegheny County v. Greater Pittsburg ACLU, the Supreme Court again faced the question of whether the government’s placement of the Nativity in the county courthouse violated the Establishment Clause. This time the Supreme Court held the government’s placement of the Nativity violated the Establishment Clause. Unlike the government’s display in Lynch, “[n]o figures of Santa Clause or other decorations” were present.[15] Nothing was hiding God. Thus, a number of Justices concluded the Nativity violated the Establishment Clause because it had “the effect of endorsing a patently Christian message: Glory to God for the birth of Jesus Christ.” Other Justices opined that “display of any object that “retains a specifically Christian…meaning is incompatible [with the Establishment Clause].” In the end, a majority of the Court struck down the government’s placement of the Nativity as violating the Establishment Clause.[16]

Four Justices, using an Unalienable Worldview, dissented. Looking at the original intent of the Establishment Clause these Justices would have held the government’s display of the Nativity constitutional. For these Justices, the original meaning of the Establishment Clause allows for government accommodation of religion and equality of treatment, especially given the absence of any inappropriate government coercion here.

Thus, Justice Kennedy, joined by Justices Rehnquist, Scalia, and White stated:

Government policies of accommodation, acknowledgment, and support for religion are an accepted part of our political and cultural heritage …. Rather than requiring government to avoid any action that acknowledges or aids religion, the Establishment Clause permits government some latitude in recognizing and accommodating the central role religion plays in our society [citation omitted]. Any approach less sensitive to our heritage would border on latent hostility toward religion, as it would require government in all its multifaceted roles to acknowledge only the secular, to the exclusion and so to the detriment of the religious …. When the state encourages religious instruction . . . it follows the best of our traditions. For it then respects the religious nature of our people and accommodates the public service to their spiritual needs. To hold that it may not would be to find in the Constitution a requirement that the government show a callous indifference to religious groups. That would be preferring those who believe in no religion over those who do believe. * * * Neither government nor this Court can or should ignore the significance of the fact that a vast portion of our people believe in and worship God and that many of our legal, political and personal values derive historically from religious teachings. Government must inevitably take cognizance of the existence of religion. * * * If government is to participate in its citizens' celebration of a holiday that contains both a secular and a religious component, enforced recognition of only the secular aspect would signify the callous indifference toward religious faith that our cases and traditions do not require; for by commemorating the holiday only as it is celebrated by non-adherents, the government would be refusing to acknowledge the plain fact, and the historical reality, that many of its citizens celebrate its religious aspects as well. Judicial invalidation of government's attempts to recognize the religious underpinnings of the holiday would signal not neutrality but a pervasive intent to insulate government from all things religious. The Religion Clauses do not require government to acknowledge these holidays or their religious component; but our strong tradition of government accommodation and acknowledgment permits government to do so. There is no suggestion here that the government's power to coerce has been used to further the interests of Christianity or Judaism in any way.[17]

The dissenting Justices recognized that the majority’s “view of the Establishment Clause reflects an unjustified hostility toward religion, a hostility inconsistent with our history and our precedents…”[18]


Implications of Governmental Hostility Toward Followers of Jesus

Requiring that every government action have a secular purpose and not even symbolically endorse religion is not only hostile toward Christianity, it is an attempt to kill it. Proponents of this secular approach favor it because it enables judges, informed by a subjective Secular-Humanist Worldview, to judicially nullify unalienable absolutes. Such judges typically take a moral absolute once in God’s realm (e.g., the origin of the universe or the inherent value of life) and re-characterize it as a policy matter up for discussion. Then, invoking a morally relative kind of neutrality— they hold everyone can participate in the discussion except for those informed by religious viewpoints. Thus, the Court has struck down, for example, laws attempting to accommodate the teaching of creation science and regulating the teaching of evolution.

For example, in the State of Louisiana, Darwin’s theory of evolution was taught in the schools. Louisiana passed a law attempting to also accommodate those with a different theory on the origin of the universe— creation science.[19] On its face, such an effort seems to embody the very essence of neutrality. The Court, however, reached an opposite conclusion in Edwards v Aguillard, holding the law unconstitutional because it lacked a secular purpose and symbolically endorsed religious ideas.[20]

Similarly, in Epperson v. Arkansas, the State of Arkansas passed a law regulating the teaching of evolution.[21] The Court began its analysis by declaring that “[g]overnment in our democracy ... must be neutral ...” The Court nevertheless proceeded to hold that because the law was motivated by a religious purpose, it violated the Establishment Clause.

Thus, although often couching its analysis in terms of neutrality, court decisions informed by the Secular-Humanist Worldview require secularly informed purposes while prohibiting religiously informed ones. Descriptive of such an analysis is Justice O’Connor’s concurring opinion in Wallace v. Jaffree: It is not a trivial matter, however, to require that the legislature manifest a secular purpose and omit all sectarian endorsements from its laws ... It reminds government that when it acts it should do so without endorsing a particular religious belief or practice that all citizens do not share.[22] Under the subjective Secular-Humanist Worldview it is acceptable (and sufficiently neutral), though, for government to dictate and endorse a secular belief or practice that all citizens do not share.

The implications of decisions like Aguillard and Epperson are immense. Implying the irrelevance of God and his moral absolutes facilitates judicial extinction of unalienable liberty as viewed by the Framers. As Herb Titus decries in his article The Bible and American Law, “What is there that is self evident, if God does not exist?”[23]

Increasing numbers of judges and other government authorities view the exercise of power through a Secular-Humanist Worldview. By way of example, senior citizens at a nursing home in Georgia were prohibited from praying before they ate their meal. The government said that because the meals were subsidized by the government, praying over the meal would be a violation of the Establishment Clause.[24] Likewise, those whose actions are informed by the sacred rather than the secular have faced Establishment Clause challenges for erecting the Ten Commandments or memorials for the fallen, engaging in a moment of silence prior to starting school,[25] and praying prior to football games.[26]

Additionally, the Secular-Humanist Worldview often reconfigures the political landscape to prevent citizens with viewpoints grounded in the sacred from participating in the political process. For those legislators and judges viewing the world through the Unalienable Worldview lens, God and his Word are real, and therefore really matter. They, understandably therefore, oppose devolutionary social engineering averse to His tenets. Proponents of the subjective Secular-Humanist Worldview presume, however, that God and his self-evident truth do not even exist. They therefore contend that viewpoints, informed by such sacred sources, have no place in their evolving constitutional governance.[27] Because they have no place, participation in public policy debates is precluded if one’s view of the world is informed by sacred principles— since government must only adopt public policy informed by secular dogma, without regard to any sacred conscience or moral considerations.

With God and His objective self-evident truth out of the way, only human/ government determined liberty exists. Having laid this foundation, the threat to unalienable life and liberty from application of a morally relative Secular-Humanist Worldview emerges in other areas as well. Thus, many Americans, and especially those with positions informed by sacred principles, see their unalienable religious liberty being eroded and taken away by those viewing the world through a Secular-Humanist Worldview. Increasingly, secular policy initiatives and judicial decisions strategically assail traditional unalienable truths concerning the origin of the universe, the sacredness of life, marriage, family, freedom of speech, and the free exercise of religious conscience. To Americans adhering to the Framers’ traditional objective Unalienable Worldview, the “evolution” of these values is more aptly characterized as devolutionary social engineering.

We are, therefore, in the midst of a high stakes, winner take all battle over the character of the American nation. In essence, this battle is over which worldview will define the Constitutional questions. The extent that one of the worldviews prevails over the other will, therefore, determine: 1) whether unalienable truth will continue to be relevant as an objective limit on government action, and 2) whether government replaces the God of our nation’s Framers with itself, increasingly exercising government power and dispensing new policy according to the desires of whoever is holding power at the time.


How a High School Football Coach Helped Restore the

True Meaning of the Establishment Clause


As a football coach, Mr. Kennedy’s job included coaching, mentoring, and serving as a role model for the student athletes.[28] In this regard, the foundation for Mr. Kennedy’s personal identity and belief system was his Christian faith.[29] After each game, these sincerely held religious beliefs led him to kneel at midfield and “offer a brief, quiet prayer of thanksgiving for player safety, sportsmanship, and spirited competition.”[30] Sometimes Mr. Kennedy gave short motivational speeches through the lens of his personal identity and belief system.[31]

Players and members of the community sometimes voluntarily joined Mr. Kennedy at midfield.[32] Even though nothing in the record shows that Mr. Kennedy treated anyone on the team more or less favorably if they participated or not, the government objected, ordering that his inspirational talks “must remain entirely secular in nature, so as to avoid alienation of any team member.”[33] Condemning Mr. Kennedy’s expression, as an improper endorsement of religion, it punished him. The government’s actions ultimately resulted in Mr. Kennedy no longer being allowed to coach the football team.[34]

The government acknowledged that it substantially interfered with Mr. Kennedy’s First Amendment liberty. It justified its violation, however, arguing that allowing Mr. Kennedy to express himself through the lens of his belief system would violate the Establishment Clause.[35] The government, therefore, contended its substantial interference with Mr. Kennedy’s First Amendment liberty was justified by a compelling government interest. A federal appellate court wrongly agreed, incorrectly presupposing that not stopping Mr. Kennedy from praying would violate the Establishment Clause. The case then proceeded to the United States Supreme Court.

For the first time in a long time the Supreme Court applied the plain meaning of the words in the Establishment Clause in its review of the government action. The Establishment Clause simply prohibits federal laws “respecting an establishment of religion.” U.S. Const. amend. I. Mr. Kennedy praying did not establish a religion. It did not subject the American citizenry to governance under a theocracy. It did not coerce the American citizenry, by force of law and penalty, to practice an official religion. It did not, therefore, violate the plain meaning of the Establishment Clause. The government, therefore, lacked a compelling interest justifying its substantial infringement of Mr. Kelly’s First Amendment liberty.

In a brief before the Court Prof. William Wagner additionally urged the Court to overrule Lemon v. Kurtzman[36] (and its progeny), because it unconstitutionally empowered unelected judges to supplant our politically accountable system of governance with their own protean preferences (thereby wrongly requiring that all government action have a secular purpose and not even symbolically endorse religion). In Kennedy v. Bremerton School District, the Supreme Court finally buried Lemon for good, holding “this Court long ago abandoned Lemon and its endorsement test offshoot.”[37] A unanimous Court agreed Lemon no longer is law.

The Court replaced Lemon’s “… abstract, and ahistorical approach,” with an unalienable jurisprudence that looked to: “original meaning and history,” in holding “the Establishment Clause must be interpreted by reference to historical practices and understandings.”

What does this mean for Baby Jesus on the Court house steps? Just as Coach Kennedy’s praying did not establish a religion, neither does Baby Jesus on the Court house steps. A nativity does not subject the American citizenry to governance under a theocracy. It does not coerce the American citizenry, by force of law and penalty, to practice an official religion. It does not, therefore, violate the plain meaning of the Establishment Clause. The government, therefore, lacks a constitutionally sufficient interest to justify the substantial infringement of First Amendment liberty that banning Baby Jesus causes.

Epilog

In the midst of earthly battles let us not lose sight of the true source of our freedom. Two thousand years ago Jesus humbly came to set us free. Born in Bethlehem, wrapped in swaddling clothes, and laid in a manager. God in human flesh, He came to die in our place, lovingly taking the punishment for us that our sins demand.[38] Nailed to a cross, He suffered and died. Three days later, He triumphantly arose from the grave. All those who believe in Him receive forgiveness for their sins and the gift of eternal life.[39] Alive today, Jesus Christ sits on the throne and will come again. And when does, every knee in heaven and on earth will bow before Him, and every tongue will acknowledge God.[40]


ABOUT THE AUTHOR


William Wagner is a Christian. He currently holds the academic rank of Distinguished Professor Emeritus (Law and Constitutional Governance). Professor Wagner’s writing is published a number of articles, books, and other publications. As lead amicus counsel in a variety of matters before the United States Supreme Court, he authored briefs on behalf of various Christian organizations. He also authored written testimony, evidence, and briefs in such forums as the Swedish Supreme Court, the U.S. Congress, and the U.K. Parliament. He has further addressed many executive, legislative, parliamentary, and judicial audiences throughout the world, and presented at various diplomatic forums including the United Nations Human Rights Council in Geneva.


Professor Wagner previously served in the United States Courts as a federal judge. Prior to his appointment on the federal bench, he served as a legal advisor and the chief American diplomat for the Department of Justice at an American Embassy in Africa. Professor Wagner also served as a senior United States prosecutor, litigating hundreds of federal cases and serving as chief of appellate litigation for the Office of the United States Attorney. Prior to serving in the Justice Department, Professor Wagner served as legal counsel in the United States Senate.


Professor Wagner received the post-doctoral Danforth Fellowship in Law after earning his J.D. in 1986. In 1986, he founded Salt and Light Global.


Soli Deo Gloria.


[1] US Constitution, Amendment 1 [2] To illustrate, compare two Establishment Clause cases handed down by the Supreme Court on the same day: Van Orden v Perry (2005) 545 US 677 (upholding government action placing Ten Commandments on Government property as Constitutional) and McCreary County v ACLU (2005) 545 US 844 (striking down government action placing Ten Commandments on government property as unconstitutional). Four justices would have upheld both, viewing the issue through the Unalienable Worldview lens. Four justices would have struck down both, viewing the issue through the Secular-Humanist Worldview lens. One justice upheld one and struck down the other viewing the issue through the Secular-Humanist Worldview lens—but applying subjective, morally-relative principles, found one symbolically endorsed religion and one did not. [3] Marsh v Chambers 463 US 783 (1983) [4] Greece v. Galloway, 134 S. Ct. 1811, 1819 (2014) (internal citations deleted) [5] Lee v Weisman (1992) 505 US 577 [6] See e.g., Allegheny Co. v Greater Pittsburgh ACLU, (1989) 492 US 573 (Justice Kennedy, joined by Justices Rehnquist, Scalia, and White, dissenting). [7] M W McConnell, “Religion and its Relation to Limited Government” (2010) 34 Harvard Journal of Law and Public Policy 943, p 944 (emphasis added). [8] In Lemon v. Kurtzman (1971) 403 US 602, the Supreme Court stated that the government must meet all three prongs of the following test to survive an Establishment Clause challenge: “First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion; finally, the statute must not foster an excessive government entanglement with religion.” A number of justices address the second prong of the Lemon test by asking whether the government action symbolically endorses religion. For a scholarly discussion of how the neutrality principles demean religion in the United States, see, G Moens, “The Menace of Neutrality in Religion” (2004) (Summer) Brigham Young U. L. Rev 535, 566–572. [9] Id. [10] Lynch v. Donnelly, 465 U.S. 668 (1984). [11] Id. [12] Id. [13] Id. [14] Id. (dissenting opinion) [15] Allegheny County v. Greater Pittsburg ACLU, 492 U.S. 573 (1989) [16] Id. [17] Id. [18] Id. (dissenting opinion) [19] The law prohibited the teaching of the theory of evolution in public schools unless accompanied by the instruction in creation science. [20] Edwards v Aguillard (1987) 482 US 578 at 583, 592 [21] Epperson v. Arkansas (1968) 393 US 97 The law at issue in Epperson prohibited teaching “the theory…that mankind ascended or descended from a lower order of animals.” [22] Wallace v Jaffree (1985) 472 US 38 [23] H Titus, 2008, note 30 above, p 317; And see generally, N Geisler, Systematic Theology, VOL 2 at 17, Bethany House, Minneapolis, MN 2003 (discussing how “all basic theological truth depends upon God’s attributes”) . [24] Associated Press (Editorial), “Ga. Seniors Told They Can't Pray Before Meals”, Associated Press, 10 May 2010. [25] Wallace v Jaffree (1985) 472 US 38. [26] Santa Fe Independent School District v Doe (2000) 530 US 290 [27] See, for example, A Zimmermann, note 6 above (discussing how Justice Olivier Wendell Holmes saw natural rights as a “conceptual mistake” and how evolutionary concepts make any analysis involving God pointless). [28] Kennedy v Bremerton Sch. Dist. No. 20-35222 (March 18, 2021) Pet. App. 3. [29] Id. [30] Pet. App. 3-4. [31] Id. at 4. [32] Id. at 4, 8-9. [33] Id. at 6. [34] Id. at 10-11. [35]Id. at 17, 23. [36] Lemon v. Kurtzman, 403 U.S. 602 (1971) Overruling Lemon was long overdue. As Justice Scalia previously lamented, “Like some ghoul in a late-night horror movie that repeatedly sits up in its grave and shuffles abroad, after being repeatedly killed and buried, Lemon stalks our Establishment Clause jurisprudence.” Lamb’s Chapel v. Ctr. Moriches Union Free Sch. Dist., 508 U.S. 384, 398 (1993) (Scalia, J., concurring). [37] 142 S. Ct. 2407, 2427 (2022); and see id. at 2449 (Sotomayor, J., dissenting) (“The Court now goes much further, overruling Lemon entirely and in all contexts.”) [38] But God demonstrates His own love toward us, in that while we were still sinners, Christ died for us. Rom 5:8 (NKJV) [39] See e.g., John 3:16 [40] See e.g., Rom 14:11

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