Vee Roebuck: I have been damn lucky

Vee Roebuck on her wedding day.

From the time the nurses carried me around the hospital where I was born to show off the red ringlets on my head to my 70s, my hair has been my distinguishing feature.

My first 10 years were spent on the ranch where I had 3,000 acres to run and roam. In Colorado Springs, we lived on the edge of the Garden of the Gods, where I was able to climb in the caves of the gigantic red rocks.

In Inglewood High School, I took four years of Latin and developed a halfway decent game of tennis. I was able to attend the University of Redlands, thanks to my father. While there, I was inducted into the honorary society for sophomore women.

I worked for Pacific Telephone for 30 years when it was only a telephone company.

I met the love of my life when I was in my early 30s. Charlie was well worth the wait.

I had three sons without having to go through the pangs of childbirth. Kenneth, Mark and Gary all grew up to be respectable adults.

For the past 35 years, I have lived in the best unit in my apartment complex, with a view, privacy and quiet.

In my early 60s, I discovered The Center for Inquiry and the Freedom From Religion Foundation, giving me a cause to devote my energy and resources to.

I have had no chronic or long-lasting illnesses and no major injuries until I fractured my hip at age 86.

I have endured no natural disasters or severe accidents of any kind.

I have had sufficient income throughout my life to provide everything I need or want. Luckily, neither Charlie nor I had extravagant tastes.

My friends are my major asset. I have made long-lasting friends in high school and college, at the telephone company and at my apartment complex. 

Vee, 89, a longtime major supporter of FFRF, was born in 1932. Her husband Charlie died in 2019 at age 87. Vee says her father was an agnostic, her mother “vaguely religious,” who went to Sunday school, but didn’t attend church. Before her baptism in her early teens, Vee asked her minister a number of questions, which he did not answer to her satisfaction. “I never went back,” Vee said. 

Sage Miller: That magic moment I found my irreligion

Sage Miller
Image by Shutterstock

By Sage Miller

For most of my wretched life, I’d wandered in a fog, yearning for a guiding light that never dawned. Paleness, wanness, grayness — that was my life. Never any “there” there, at the core of me. I was a spiritual vacuum.

Was something missing? Yes, and it was something crucial. Something at the core of my life. I lacked purpose. What, really, was I living for? There was an emptiness in my heart and soul that couldn’t be filled by things associated with conventional success.

Did I crave wealth and fame? Who doesn’t? In a way, there’s nothing wrong with those. In fact, I’ll take all I can get. But they couldn’t fill the emptiness inside.

Sex, gambling, drink, drugs? Fun for a while, I suppose. Fun for kids. But once you’re out of college, they’re just so immature. I’m ashamed to admit, though, that I wandered into three of those swamps, and, surprise, surprise, none was the Answer, the One True Light. None got me even close to the Answer. And I was nearing the end.

It’s crazy what can trigger U-turns in lives. My awakening came like a bolt of lightning on the 18th green (and I was lifted to even more bliss as I reflected on it at the 19th hole in the clubhouse). This time, I flung my putter into the lake out of exultation instead of rage.

I was hearing a voice — I swear — that I recognized as that of Bertrand Russell. He thundered:

“There is something feeble, and a little contemptible, about a man who cannot face the perils of life without the help of comforting myths. Almost inevitably, some part of him is aware that they are myths and that he believes them only because they are comforting. But he dares not face this thought, and he therefore cannot carry his thought to any logical conclusion.”

And then came another voice that I recognized as that of H.L. Mencken:

To sum up: (1) The cosmos is a gigantic fly-wheel making 10,000 revolutions a minute. (2) Man is a sick fly taking a dizzy ride on it. (3) Religion is the theory that the wheel was designed and set spinning to give him the ride.

And don’t get me started with Nietzsche.

There it was! My Answer! And I wasn’t stopping there. Agnosticism? Not for me! Atheism? Not for me! I was blasting beyond even Russell and Mencken to anti-theism!

I realized not only that religion was ludicrous, but that belief in it, even apart from its preposterous virgin-birth, water-into-wine absurdities, did immense damage by destroying belief in science and independent thinking and instilling the mindset of sheepish obedience. At that magic moment, I became no longer a mere nonbeliever but a warrior for reason, decency and justice, dedicated forevermore to fighting religion’s curses. Turn me loose! With stunning clarity, I realized that religion was not only evil in itself, but the cause of so much more evil.

Of course, I realize loathsome politicians will never stop pandering to theocrats by attacking reproductive freedom and education, trying to use public power and spaces for religious indoctrination, curbing and corrupting scientific research, and maintaining religion’s unconscionable tax exemptions and subsidies (“faith-based initiatives”).

But, at least, I would never let religion warp and oppress me. I could free myself from its chains, indoctrinations, dogmas and delusions forevermore. And maybe I could help the world recover from its curses and become a better place. Maybe you, too, can break its chains, even if you’ve long been pummeled into sheepishness. (“The Lord is my shepherd . . .”). Maybe you, too, now or in the fullness of time, can get yourself free!

FFRF Member Sage Miller, a former columnist for the Dallas Morning News, writes humor and general-interest essays from Manhattan, Kan.

FFRF’s 2021 law student essay contest winners

The Freedom From Religion Foundation is proud to announce the four winners of the Cornelius Vanderbroek Memorial Essay Competition for Law Students.

FFRF paid out a total of $9,500 to the winners of this year’s contest.

Law school students were asked to write on the topic of “Why ‘history’ shouldn’t justify violations of the separation between state and church.”

The topic explores a change in Supreme Court interpretation that has become central to state/church litigation in recent years. In Town of Greece v. Galloway, the Supreme Court wrote that “the Establishment Clause must be interpreted ‘by reference to historical practices and understandings.’” In the wake of that decision, courts have struggled to define the exact contours of the historical considerations at play, with some courts treating Galloway as announcing a broadly applicable “history test,” while others have continued to apply more traditional Establishment Clause tests.

Essayists were to identify the dangers in interpreting Galloway as establishing a broadly applicable “history test” and, with citation to at least two post-Galloway cases, from any courts, define the outer boundaries where a history test should be applied.

For ease of reading, the essays appearing in this issue do not include the footnotes and citations that were included in the authors’ submissions.

Winners are listed below and include the law school they are attending and the award amount.

First Place: Ty Jameson, Wake Forest University School of Law, $4,000.

Second Place: Jimmy Morrissey, University of Wisconsin Law School, $3,000.

Third Place: Jordan Glassman, University of North Carolina Law School, $2,000.

Honorable Mention: Ryan Shaner, Chicago Kent College of Law, $500.

FFRF has offered essay competitions to college students since 1979, high school students since 1994 and grad students since 2010. The law school contest began in 2019.

Law student essay contest

Overheard (August 2021)

Today we have other ways of policing morality, but this evolutionary heritage is still with us. Although statistics show that atheists commit fewer crimes than average, the widespread prejudice against them, as highlighted by our study, reflects intuitions that have been forged through centuries and might be hard to overcome.

Dimitris Xygalatas, associate professor of anthropology and psychological sciences at the University of Connecticut, in his column, “Are religious people more moral?”

Yahoo News, 5-25-21

They didn’t care about the democratic process; they cared only about what they believed. This is what happens when you mix politics with a religion that has decided to go off the rails. You have people who become radicalized.

Historian Anthea Butler, regarding how the Jan. 6 insurrection was largely started by conservative Christians talking about how they needed to take back the country and how God ordained Donald Trump to be the president, in the article “Nationalism, American evangelicals and conservatism.” 

Penn Today, 5-19-21

Their pervasive theology shapes policies that cause women untold suffering. . . . It’s also the specter that makes women forgo hysterectomies because, we are told, it’s better to endure suffering than lose the possibility of giving birth. . . . Catholics should ask themselves whether the church’s anti-abortion fight is less about babies and more about controlling women’s fertility and, with that, women’s freedom. . . . Giving pregnant people the legal right to have control and agency over their bodies translates to other aspects of their lives, namely the capacity to claim political, economic and social autonomy.

Jamie Manson, president of Catholics for Choice and a former columnist for The National Catholic Reporter, in her column, “The Catholic Church’s reproductive fight is about controlling women’s freedom.”

The New York Times, 5-27-21

People who profess no religion live in constant fear of their lives and safety. They live in fear of being tortured or disappeared, summarily executed, or taken to a mental hospital for leaving a religion or for holding and expressing blasphemous views and opinions.

Leo Igwe, in his column “Freedom of religion or belief and nonreligious persecution in Nigeria.”, 6-2-21

If a taxpayer-funded religious social services organization can discriminate against individuals based on the assertion their sexual orientations are inconsistent with the organization’s own religious tenets, it can almost certainly discriminate against individuals whose religious beliefs are inconsistent with its religious tenets.

Samuel Brunson, prior to the Supreme Court decision in Fulton vs. Philadelphia, where the court ruled that Catholic Social Services may discriminate against families headed by same-sex couples when providing taxpayer-funded public foster care services.

Religion News Service, 5-28-21

It’s almost like leaving a cult, and you’re about to do something that your religion frowned upon for the first time.

Lydia Greene, on how she was able to get out from under the online conspiracy theories about Covid-19 vaccines., 5-28-21

How can Jews believe in an omnipotent, beneficent God after Auschwitz? Traditional Jewish theology maintains that God is the ultimate, omnipotent actor in the historical drama. It has interpreted every major catastrophe in Jewish history as God’s punishment of a sinful Israel. I fail to see how this position can be maintained without regarding Hitler and the SS as instruments of God’s will. To see any purpose in the death camps, the traditional believer is forced to regard the most demonic, anti-human explosion in all history as a meaningful expression of God’s purposes. The idea is simply too obscene for me to accept.

Richard L. Rubenstein, theologian, in his 1966 book After Auschwitz: Radical Theology and Contemporary Judaism. Rubenstein died May 16. 

The New York Times, 6-5-21

Secularization or rationality has little chance of correcting or convincing QAnon believers. . . . The beliefs of QAnon followers are decidedly irrational, and no rational arguments will address them. 

Rabbi Brad Hirschfield, president of the National Jewish Center for Learning and Leadership, in his column “What nonbelievers don’t get about conspiracy beliefs.”

Religion News Service, 6-7-21

For me, the parallel is that I think a lot of people want to see Jan. 6 as the end of something. I think we have to consider the possibility that this was the beginning of something.

Cynthia Miller-Idriss, director of the Polarization and Extremism Research and Innovation Lab at American University, who notes the rise of Naziism was preceded by a series of attacks, failed coups and other efforts to undermine democracy.

New York Times, 6-10-21

If you doubt that a threat of violence exists, look at the recent poll from the Public Religion Research Institute and the Interfaith Youth Core, which shows that a dangerous QAnon conspiracy theory is believed by 15 percent of our fellow Americans — including almost one in four Republicans, 14 percent of independents and even 8 percent of Democrats. 

Barbara Comstock, a Virginia Republican and lawyer and former member of Congress, calling for an investigation into the Jan. 6 Capitol riot.

New York Times, 6-10-21

Viewed through a contemporary, secular lens, a community built around a charismatic founder and dedicated to the lionization of suffering and the annihilation of female selfhood doesn’t seem blessed and ethereal. It seems sinister.

Columnist Michelle Goldberg, in her column, “Was Mother Teresa a cult leader?”

The New York Times, 5-21-21

First place: Law student essay contest — Ty Jameson

FFRF awarded Ty $4,000.

By Ty Jameson 

The First Amendment to the United States Constitution states that “Congress shall make no law respecting an establishment of religion.” Known as the Establishment Clause, this constitutional provision “mandates governmental neutrality between religion and religion, and between religion and nonreligion.” 

Supreme Court Justice William Douglas once wrote that the Establishment Clause is meant to “promote a viable, pluralistic society.” However, a new method of interpreting the Establishment Clause “by reference to historical practices and understandings” is severely diminishing this constitutional protection and has the potential to effectively erase the Establishment Clause from our nation’s founding document.  

This new “history test” presents several problems as a method of interpreting the Establishment Clause. The history test’s vague direction to refer to “historical practices and understandings” provides little guidance to judges when analyzing an Establishment Clause case. Importantly, the history test “does not make clear what history [judges] should consider.” Thus, the history test allows judges to engage in selective historical analyses, reaching back to any point in our nation’s 240-year-plus history to consider fragmented — and even irrelevant — history when analyzing an Establishment Clause claim.  

Take, for example, a case where the 8th Circuit Court of Appeals used the history test to hold that placing the motto “In God We Trust” on national currency does not violate the Establishment Clause. The “history” the Eighth Circuit referenced included an “unbroken history of official acknowledgement . . . of the role of religion in American life from at least 1789” and that “the Founding Fathers believed devotedly that there was a God.” 

Neither of these two assertions answer whether placing “In God We Trust” on currency violates the Establishment Clause. As to the first assertion, an official acknowledgment of the role of religion in American life is far different from placing a motto that endorses belief of, and trust in, a monotheistic god on national currency — something all citizens regularly see and use. As to the second assertion, assuming, arguendo, that all the Founding Fathers believed in a god, this sheds no light on what the Founding Fathers believed to be the proper relationship between religion and government. 

To be sure, history is not totally irrelevant to interpreting the Constitution. Courts often invoke history to examine how the Founders envisioned a constitutional provision would apply and to identify the overarching purposes a constitutional provision is meant to serve. In engaging in this type of historical analysis with respect to the Establishment Clause, the Supreme Court has previously examined  colonial history that led to the inclusion of the Establishment Clause in the Constitution and has noted how Thomas Jefferson wrote that the Establishment Clause was intended to erect “a wall of separation between church and state.” The Supreme Court has also repeatedly mentioned how James Madison, “the leading architect of the religion clauses,” wrote a memorial and remonstrance opposing a tax to fund preachers and providing several arguments against government support of religions. Highlighting the history test’s potential for selective historical analysis, the 8th Circuit failed to consider any of this history when it upheld the use of “In God We Trust” on national currency. 

Prior tests

To fully appreciate the implications of this new history test, it is important to pause and take note of prior Establishment Clause tests that the history test replaces. For the past several decades, courts have analyzed Establishment Clause cases by examining the purpose and effect of the government conduct at issue and by asking whether the conduct endorses or coerces religion. These prior tests provide far more guidance to judges when deciding Establishment Clause cases than does the history test. These prior tests also help judges reach outcomes that “promote a viable, pluralistic society” and fulfill the clause’s mandate of “government neutrality” with respect to religion. 

A recent case where FFRF assisted the plaintiff in challenging the constitutionality of a nativity scene outside of a county courthouse demonstrates the difference between the prior Establishment Clause tests and the new history test. The district court ruled that the nativity scene violated the Establishment Clause using the prior tests of examining the purpose of placing a nativity scene outside of the county courthouse and whether it endorses or coerces religion. In so doing, the district court noted that the “evidence in the record indicates that the county’s purpose in displaying the nativity scene was religious” and that the nativity scene “would give a reasonable observer the impression that the government is endorsing a religion.” 

However, on appeal, the 7th Circuit Court of Appeals reversed, using the history test to hold that the nativity scene does not violate the Establishment Clause. Rather than taking a careful look at the purpose and effect of the nativity scene at issue in the present case, the appellate court merely referenced a “long national tradition of using the nativity scene in broader holiday displays.” Like the 8th Circuit’s analysis of “In God We Trust” on national currency, the appellate court here failed to mention any history that led to the inclusion of the Establishment Clause in the Constitution or how Thomas Jefferson and James Madison interpreted the provision. 

Another troubling aspect of the appellate court’s decision is that the court used the history of other nativity scenes on government property to hold that the nativity scene at issue did not violate the Establishment Clause, rather than considering that perhaps all those other nativity scenes violate the Establishment Clause. This notion that we are bound by prior history — rather than examining the constitutionality of such prior history — impedes progress toward the “viable, pluralistic society” mentioned by Justice Douglas and is direct contrast to the use of history in other areas of constitutional law.  

Imagine if a similar history test applied to the interpretation of the 14th Amendment’s guarantee of “equal protection of the laws.” It would be deeply troubling if courts evaluating claims of racial or sexual-orientation discrimination could point to our nation’s history of discrimination, even after the passage of the 14th Amendment, to hold that such discrimination does not violate the Equal Protection Clause. Thankfully, such a history test does not apply to the Fourteenth Amendment.  

History and tradition

Rather, the Supreme Court has noted that history and tradition do not set the outer boundaries of constitutional interpretation and that we must be able to learn from our nation’s history “without allowing the past alone to rule the present.” Constitutional interpretation must recognize “that new insights and societal understandings can reveal unjustified inequality . . . that once passed unnoticed and unchallenged.” Similarly, interpretation of the Establishment Clause must recognize our nation’s history of dominant religious groups using the power of government to promote their faiths and impose them upon others, while allowing us to learn from that history rather than being bound by it. 

If use of this new history continues, the fate of the Establishment Clause is clear — courts will repeatedly use the history test to abandon the Establishment Clause’s principles and protections. In addition to the cases already mentioned, the First Circuit recently used the history test to hold that the inclusion of the phrase “so help me God” at the end of the oath of allegiance administered at naturalization ceremonies does not violate the Establishment Clause because of a “longstanding” history of similar words as a means of completing an oath. 

Additionally, in FFRF’s lawsuit against a Pennsylvania county, the Third Circuit used the history test to hold that a county seal containing a Latin cross did not violate the Establishment Clause because it fit “within a long tradition of state and municipal seals and flags throughout our Republic that include religious symbols or mottos.” After reading these opinions, one wonders whether any government conduct will be held to violate the Establishment Clause under this new history test.  

The emergence of the history test is particularly troublesome considering Christian nationalists’ recent efforts to use the force of government to inject Christianity into society, and in particular, public schools. For example, several states — including Florida, Arkansas, Tennessee, and Utah — have passed laws that require displays of the motto “In God We Trust” in public schools. Religious indoctrination has no place in public schools and challenging these types of laws will be particularly difficult if courts can reference vague, incomplete and irrelevant history to ignore the true purposes of the Establishment Clause. Thankfully, not all courts are using the new history test to analyze Establishment Clause cases, instead using the prior tests. The Supreme Court has so far only used the history test when analyzing cases involving prayers before legislative meetings. The lower courts applying the history test to other contexts have misread those cases as setting forth a broad new test that abandons the prior Establishment Clause tests. For the sake of separation of religion and government, this trend must not continue. If it does, we may soon find that the Establishment Clause, for all intents and purposes, has been erased from the Constitution.

Ty Jameson attends the Wake Forest School of Law. “My interests in advocating for secular causes largely originated while learning about the First Amendment’s religion clauses at college in Utah,” Ty writes. “This interest ultimately led me to spend a summer as a law clerk with American Atheists. At school, I serve on the editorial board of the Wake Forest Journal of Law and Policy. I recently wrote an article on Article III standing to challenge political and religious displays that will be published in a forthcoming edition of the Journal. This summer, I am interning at the U.S. Department of Justice, in an office that enforces various civil rights laws.”

Ty Jameson

Second place: Law student essay contest — Jimmy Morrissey

FFRF awarded Jimmy $3,000.

By Jimmy Morrissey 

Of the many protections offered by the U.S. Constitution, there are few as notable and impactful as those offered by the Establishment Clause of the First Amendment. The importance of a secular state was not lost on the founders when they ensured that “Congress shall make no law respecting an establishment of religion or prohibiting the free exercise thereof.” 

Over 200 years later, the Supreme Court ruled in Town of Greece v. Galloway that the Establishment Clause must be interpreted by analyzing the history and tradition behind a challenged practice. 

Courts have struggled to implement the Town of Greece court’s analysis, and several circuits have begun using a “history test” when reviewing Establishment Clause claims.

Use of such a test is profoundly dangerous in two ways: First, an otherwise unconstitutional practice may pass muster merely because it is rooted in tradition. Second, the test’s lack of specificity gives courts an opportunity to carve out exceptions on an ad hoc basis, thereby undermining the protections offered by the Establishment Clause. These protections are foundational to the rights of an individual in a democratic society and must be upheld. 

Before its 1983 ruling in Marsh v. Chambers, the Supreme Court had relied on a series of tests to determine whether a practice violated the Establishment Clause. These tests typically focused on whether the practice advanced or inhibited a particular religion, made adherence to a religion relevant in any way to a person’s political standing, or directed a formal religious exercise in such a way as to oblige the participation of objectors. However, the court carved out an exception to these tests in Marsh when it ruled that “legislative prayer” — the practice of employing a legislative chaplain and beginning legislative meetings with a prayer — was constitutional under the Establishment Clause. 

In Town of Greece, the Supreme Court attempted to clarify its ruling in Marsh by establishing that legislative prayer had a firm rooting in the country’s political traditions. The court held that a prayer given at a monthly town board meeting comported with the tradition of legislative prayer and was not unconstitutional under the Establishment Clause. Reasoning that legislative prayer involved a limited context where prayer “could coexist with the principles of disestablishment and religious freedom” and that such prayer was properly constrained by its occurrence at the beginning of legislative sessions, the court invoked Marsh to declare the town board invocations constitutional. 

The first danger of the court’s reliance on a practice’s history and tradition has already manifested itself in Fields v. Speaker of the Pennsylvania House of Representatives. In Fields, the 3rd U.S. Circuit Court of Appeals applied a history test that it derived from Town of Greece to rule that an opening prayer before legislative meetings was constitutional. What separates this case from those mentioned above, however, is that the Pennsylvania Legislature had prohibited nontheists from offering the opening prayer. In its bizarre reasoning, the 3rd Circuit found that because the historical practice of legislative prayer involved the necessary element of praying to a higher power, a legislature may insist on having traditional, theistic opening prayers. 

Fields provides an example of a court upholding an otherwise unconstitutional practice merely because it is in line with tradition. Even the court in Town of Greece was clear that Marsh “must not be understood as permitting a practice that would amount to a constitutional violation if not for its historical foundation.” And yet, the 3rd Circuit upheld a policy that on its face discriminates on the basis of one’s religious beliefs and makes adherence to religion plainly relevant to a person’s political standing, citing the history behind the tradition of legislative prayer as a justification. If the court wishes to take history and tradition into account when evaluating an Establishment Clause claim, it must make clear that such considerations should never be dispositive, especially where a challenged practice discriminates so freely and flagrantly. 

The second danger of a widespread history test is more subtle than the first, but no less insidious. Circuit courts have already begun to apply the historical analysis undergone in Town of Greece to other contexts, making broad comparisons between legislative prayer and more novel practices. In American Humanist Association v. McCarty, the 5th Circuit found that invocations given before school board meetings open to the public were constitutional. The court applied a history test that it had derived from Town of Greece, drawing a comparison between prayers given before a legislative session with only lawmakers present and invocations given before a public school board meeting. While acknowledging that there was a difference in the context of each practice, namely through the presence of children, the court ultimately reasoned that the mere presence of children or other members of the public who were not lawmakers themselves did not exclude the school board invocations from the same historical exception given to legislative prayer. 

American Humanist Association provides an example of how a history test can be stretched to allow for any number of practices to be excepted from the Establishment Clause’s requirements. The 5th Circuit acknowledged that prayers at such meetings lacked the exact historical practice of the sort in Town of Greece, and while noting the difference in context between the tradition of legislative prayer and the school board invocations, was still willing to stretch the traditional understanding of legislative prayer to include the practice at issue. It is not hard to see how any number of practices could be given a similar treatment by a sympathetic  court, transforming the tradition and history analysis into mere pretext for carving out more and  more exceptions to constitutional safeguards. A proper analysis of a practice’s tradition and history under the Establishment Clause should focus on the history of the specific practice being challenged; to be more flexible with a history analysis would erode the clause’s meaning over time. 

In Marsh and Town of Greece, the Supreme Court may have intended to provide a pragmatic alternative in Establishment Clause cases where longstanding practices were challenged for their constitutionality. However, the lack of specificity with which this analysis was implemented has led to confusion and the possibility of attacks on the protection offered by the clause. The first danger of a widespread history test in response to this unclear analysis is that practices which are clearly unconstitutional, such as the exclusion of nontheist chaplains in Fields, may pass constitutional muster. Additionally, courts may seize upon the opportunity created by such a vague test to create multiple exceptions to the Establishment Clause, eroding its force over time.

In order to avoid these outcomes, the Supreme Court must firmly address that any such history test cannot be dispositive of a practice’s constitutionality, and that a historical analysis must be focused on the specific practice in question. Surely no tradition in such a test is more important than the tradition of free religious practice in a democratic society. 

Jimmy Morrissey is from St. Paul, Minn., and graduated from DePaul University with a degree in political science. Jimmy attends the University of Wisconsin School of Law and is a member of the Wisconsin Journal of Law, Gender & Society.

Jimmy Morrissey

Third place: Law student essay contest — Jordan Glassman

Jordan Glassman

FFRF awarded Jordan $2,000.

By Jordan Glassman 

In 2014, the Supreme Court drew sufficient analogies between the pro forma prayer at the Nebraska Legislature at issue in Marsh v. Chambers and the invocations preceding the intimate town hall meetings of Town of Greece v. Galloway to extend the 1983 holding and uphold the mostly Christian prayers recited for over a decade in upstate New York. Despite Justice Elena Kagan’s dissent and its unsubtle portrait of alienation, none of the justices questioned the central holding of Marsh. Instead, they debated its fact-sensitive application to the town hall setting. Since then, indications that this history analysis is seeping out of the narrow context of these seminal rulings and morphing into a broadly applicable “history test” have begun to mount. 

The court insisted that these holdings should “not be understood as permitting a practice that would amount to a constitutional violation if not for its historical foundation.” Instead, “the Establishment Clause must be interpreted by reference to historical practices and understandings” and “it is not necessary to define the precise boundary of the Establishment Clause where history shows that the specific practice is permitted.” 

But five years later, the court again expanded the scope of Marsh’s history test in American Legion v. American Humanist Association. This holding went beyond “specific practices” to include a “presumption of constitutionality for longstanding monuments, symbols, and practices.” With the court’s sympathy toward religion near its zenith, it is worth considering the dangers of a still more broadly applicable history test and insisting on “[defining] the precise boundaries” of its application to guard against those dangers. 

Ascertaining history with perfect fidelity is difficult or impossible, especially if it concerns subjective states of mind. In Youngstown Sheet & Tube Co. v. Sawyer, Justice Robert H. Jackson famously lamented the futility of trying to divine what the founders might have had in mind: 

“Just what our forefathers did envision, or would have envisioned had they foreseen modern conditions, must be divined from materials almost as enigmatic as the dreams Joseph was called upon to interpret for pharaoh. A century and a half of partisan debate and scholarly speculation yields no net result but only supplies more or less apt quotations from respected sources on each side of any question. They largely cancel each other.” 

Compounding the literal difficulty of knowing facts about the past is the certainty that historical accuracy will give way to unreliable “law office history” in the adversarial context. The result is dubious historical claims which, unlike facts in a typical decision, attain precedential value. 

In addition to the difficulty of ascertaining the distant past with any confidence, the scope of its application should be quite narrow, if the reasoning of Marsh is to be taken seriously. Scholars at Americans United for Separation of Church and State recently criticized the naively applied history test of Galloway as, at best, only applying to a small sliver of federal actions in the few years following the ratification of the First Amendment. They argue persuasively that expanding the history test of Marsh and Galloway beyond this narrow scope is likely to result in jurisprudence that strays unpredictably from well-established Establishment Clause doctrine. 

Moreover, members of the court have noted for some time that the historical test fails to account for the evolution of American society. For example, throughout Galloway, the court assumes as if uncontroversial that prayer “[lends] gravity to the occasion” and “sets the mind to a higher purpose.” But as Justice William J. Brennan noted in his dissent in Marsh, “practices which may have been objectionable to no one in the time of Jefferson and Madison may today be highly offensive to many persons, the deeply devout and the nonbelievers alike.” Any historical practice, “even if it might look ‘nonsectarian’ to nine justices of the Supreme Court” could induce divisive reactions at any point in the future. “[T]he Constitution is not a static document whose meaning on every detail is fixed for all time by the life experience of the Framers.” 

Perhaps the biggest present danger is how the doctrine seems likely to seep into more and more Establishment Clause jurisprudence given the sympathies of the current court. In his concurrence in American Legion, Justice Brett Kavanaugh posits an informal taxonomy of Establishment Clause cases: 

(1) religious symbols on government property and religious speech at government events; (2) religious accommodations and exemptions from generally applicable laws; (3) government benefits and tax exemptions for religious organizations; (4) religious expression in public schools; and (5) regulation of private religious speech in public forums. 

While insisting that the history test is only applicable to the first category, he also invites its application to the remaining four: “each category of Establishment Clause cases has its own principles based on history, tradition, and precedent. . . . If the challenged government practice is not coercive and . . . is rooted in history and tradition . . . then there ordinarily is no Establishment Clause violation.”

The remaining categories are ripe for being brought into the fold of the historical test. For example, in the second category concerning exemptions, Galloway appeared in the plaintiffs’ reply brief in Fulton v. City of Philadelphia, a case involving religious organizations’ right to discriminate. The petitioners argued that “Catholic’s five decades of service to Philadelphia children under city contracts, unchallenged until 2018, easily passes muster under . . . the historical practices test,” apparently reducing the range of the necessary historical reach from 250 years to only 50. 

In Gaylor v. Mnuchin, a lawsuit brought by the venerable Freedom From Religion Foundation challenging tax breaks for ministers, the 7th Circuit upheld the benefit. The court takes note of a “lengthy tradition of tax exemptions for religion” and held that the tax break “does not violate the Establishment Clause under the historical significance test. 

In fact, it is easy to imagine the historical test applied to any of the categories enumerated by Kavanaugh. From the graduation prayers of Lee v.  Weisman to the generally applicable drug laws of Employment Division, Department of Human Resources of Oregon v. Smith, the broadly applicable history test brings to mind Justice Arthur Goldberg’s concession that “great consequences can grow from small beginnings.” 

Since there is no reason to expect the current court will move away from an unsympathetic view toward Establishment Clause challenges, an overinclusive history test will remain the law of the land for some time. Advocates representing plaintiffs seeking to resist the establishment of religion should assist courts in articulating boundaries to prevent overreach. 

To do so, the application of the test must be limited to objective questions about history, to the extent that such questions are even answerable. The test cannot be allowed to expand to include subjective questions about how people thought or felt. Recent post-Galloway cases illustrate judges beginning to push this boundary. 

In Freedom from Religion Foundation, Inc. v. Concord Community Schools, the 7th Circuit affirmed a district court decision allowing the performance of a nativity scene at a public school to continue in an abated form. In a concurrence, one judge cites to Galloway approvingly while opining that “[p]erforming a work of art does not establish [a state religion] . . . The Supreme Court’s decisions permitting legislatures to open their sessions with prayer show this.” While the historical fact of whether certain works of art were exhibited in the past might be ascertainable, inferring therefrom that something has “become part of the fabric of our society” allows the court to invade the conscience of those engaged in the intensely personal consumption of artwork. A court cannot possibly know how people felt about artwork. 

Likewise, in Doe v. United States, the 8th Circuit affirmed the district court’s dismissal of an action to remove a religious motto from the national currency. The court muses that “given that our founding documents protect rights that were thought to derive from God, it is unsurprising that religion has been closely identified with our history and government, a relationship still evidenced today in our public life,” while citing approvingly to Galloway. Once again, the court makes an inference about how people thought on the basis of some historical series of events. But the court cannot possibly know how people thought. 

These are not harmless comments made in dicta. To be applied objectively, the historical test must be applied only to ascertainable facts about the past. Inferences about how or what people thought about those practices cannot be allowed. This approach will cabin the historical test’s application to contexts like the benign legislative prayer of Marsh, where how those in proximity to the practice thought or felt about it is beside the point. For when the door is opened to make post-Galloway decisions on the basis of what people apparently thought or what their art seems to reflect, the test can accommodate any proposition whatsoever. 

Jordan Glassman, who attends the University of North Carolina Law School, has an academic background in astronomy and physics. After serving in the Navy as a submarine officer and then working as a software engineer, Jordan returned to law school to pursue a career in tech-adjacent areas of law. He lives in Durham, N.C., with his partner Beth and son River.

Honorable mention: Law student essay contest — Ryan J. Shaner

Ryan J. Shaner

FFRF awarded Ryan $500.

By Ryan J. Shaner 

Sometime toward the end of his life, James Madison, the father of the Constitution and the principal author of the First Amendment, began to privately second-guess the decisions he made as one of the chief advocates of state/church separation during the formative years of the young American republic. Singularly concerned with state/church separation by his twilight years, Madison wrote in wistful contemplation about many of the decisions he made — and regretted — as a public servant earlier in his life, chief among those regrets being the establishment of the congressional chaplaincy, and his vote in support of that position. As evidenced by his writing in his “Detached Memoranda,” Madison later questioned whether “the appointment of chaplains” by the First Congress “was consistent with the Constitution”; ultimately, Madison acknowledged that the answer “must be in the negative. [For] [t]he Constitution of the U.S. forbids everything like an establishment of a national religion” and the “establishment of the chaplainship to Congress [was] a palpable violation . . . of constitutional principles.” 

It is no coincidence that Madison’s self-reflection of his earlier missteps coincided with an American public that had come to wholly accept the notion that religion was to remain separate from the sphere of civil government. Though under no constitutional obligation to do so, every state in the union had disestablished their state-sponsored church by 1833; less than 20 years later, the National Congress denied statehood to the Provisional State of Deseret, in part because of a “lack of separation of church and state.” 

Madison’s regret over the congressional chaplaincy and the disestablishment of religion on the state level are but two components of a larger history that gives context and meaning to the Establishment Clause of the First Amendment. Indeed, history has always been considered critical when interpreting the Establishment Clause, for, as one Supreme Court justice wrote, “[n]o provision of the Constitution is more closely tied to or given content by its generating history than the religious clause of the First Amendment. It is at once the refined product and the terse summation of that history.”

Until the 1980s, the confines of the history utilized to understand and give meaning to the Establishment Clause was widely understood and virtually uncontested. This “traditional” reading of Establishment Clause history — understood through the writings of James Madison and Thomas Jefferson and the history that preceded ratification of the First Amendment — enabled the courts to have a cohesive frame of reference and bright-line standard of a “wall of separation between church and state.” This standard allowed for a uniform application of law, which routinely rebutted and declared unconstitutional numerous state church violations.

With the rise of the conservative Christian movement in the 1980s, however, the court’s understanding of the Establishment Clause — and, by necessity, the history the Supreme Court had come to rely on when interpreting the clause — had to be challenged to fulfill the movement’s ultimate goal of commingling religion and government. While this movement was successful in muddling Establishment Clause jurisprudence in the 1980s, the movement’s resurgence in the 2010s has been much more successful in producing judicial precedent that not only undermines Jefferson’s wall of separation, but simultaneously exalts Christianity to an exceptional position, allowing what would otherwise be violations of the Establishment Clause to withstand judicial scrutiny. 

Undoubtedly, the first inklings of the so-called “history test” are apparent in Marsh v. Chambers, the 1983 Supreme Court case that dealt with legislative prayer. After the practice was found unconstitutional in both the district and appellate courts, the Marsh majority reversed and upheld the practice of legislative prayer. Marsh marked the end of coherent Establishment Clause jurisprudence.

Electing to abandon precedent and legal tests formulated over the preceding decades, the Marsh majority, instead, elected to rule in favor of legislative prayer based solely on “history and tradition.”

For decades, this new “test” articulated by the Marsh majority seemed but an aberration, and largely remained dormant. In 2014, however, the Supreme Court, in Town of Greece v. Galloway, once again revisited the subject of legislative prayer. Reversing the appellate court who found the practice unconstitutional, the Supreme Court held that sectarian Christian prayers given before legislative board meetings did “not fall outside the [historical] tradition this court has recognized.” Cognizant of the fact that Marsh seemed an irregularity, the Galloway majority took pains to profess that this newly refurbished history test “must not be understood as permitting a practice that would amount to a constitutional violation if not for its historical foundation.”

Despite their assurances to the contrary, however, the increasingly conservative court has done little to dissuade detractors who believe the court’s “history test” does little but warrant would-be violations in the name of “tradition.” Indeed, some of the most conservative justices themselves have articulated opinions that detract from the yearning legitimacy of the history test. 

In likely the most literally visibly jarring Establishment Clause case to ever come before the Supreme Court, American Legion v. American Humanist Association concerned itself over the constitutionality of the Bladensburg Memorial, a 40-foot-tall Christian cross stationed on public land, maintained by the state, and in need of repairs that were to be allotted from public tax dollars. Replete with a majority opinion, a plurality, five concurrences, and a dissent, American Legion did little to legitimize and make intelligible a new Establishment Clause regime under the guise of history of tradition; indeed, the conservative plurality, writing that “longstanding monuments, symbols, and practices” are “presumpt[ively]” constitutional drew ire from their ideologically similar justices, with Justices Neil Gorsuch and Clarence Thomas questioning “where exactly in the Constitution . . . this presumption comes from,” noting that the conservative “plurality does not say, nor do[] [they] even explain what work its presumption does.” Likewise, Justice Stephen Breyer’s concurrence, in which Justice Elena Kagan joined, echoes Gorsuch’s doubts, with Breyer articulating that “if the [Bladensburg] cross had been erected only recently” the “case would be different,” further warning that American Legion did not presumptively sanction or “permit any newly constructed religious memorial[s] on public land.” 

The presumptive constitutionality that long-standing religious monuments, symbols, mottos, displays and ceremonies now seemingly enjoy — by virtue only of their age and not any discernible legal principle — has diminished the dual foundational religious ideals of freedom of religion and freedom from religion, all to enrich one particular religious sect. By allowing county seals affixed with Christian imagery, four-story-tall Christian crosses on state property, Christian nativity scenes on government land, and other long-standing traditions steeped in Christian overtones to remain standing, the ramifications, if not the intent, of the new Establishment Clause test is to allow exclusively Christian practices and imagery to become intertwined with the state. 

Moreover, while the Supreme Court’s new test ensures Christianity’s presence is allowed within the sphere of civil government, the test also necessarily excludes imagery and practices of minority religions from enjoying the same status. Though Jews, Deists and the irreligious have been present in the United States since before America won its independence, the fact that these groups have been denied any meaningful political power until the modern day ensures that there will be no long-standing monuments, imagery or practices associated with any non-Christian group on government property or in government practice. 

From the very first case presented to the Supreme Court on the proper scope of the Establishment Clause, history has always been considered of the utmost importance in explaining and understanding what an “establishment of religion” fully entails. However, the new jurisprudential regime and the traditional Establishment Clause jurisprudence find guidance from two completely different understandings of history. The new history test looks not to the writings of Thomas Jefferson or James Madison, nor any discernible legal principle, nor, seemingly, even the Constitution itself, but, instead, defers to the practices, actions, and decisions of fleeting congressmen, local county board members and activist groups. 

On the other hand, the traditional understanding of Establishment Clause interpretation utilized the historical events that preceded the ratification of the First Amendment, in conjunction with the writings of Jefferson and Madison, to be the controlling history when determining the scope of the Establishment Clause. Until the 1980s, the actions of the First Congress, for instance, paled in historical significance to the struggle for religious freedom the dissenting Christian sects in Virginia fought for; Jefferson’s Virginia Statute for Religious Freedom and Madison’s Memorial and Remonstrance more clearly defined what was acceptable under the First Amendment than an unchallenged long standing government practice or Christian monument on government land. 

If we are to gain any insight from the saga of Madison’s vote on the congressional chaplainship, it is that even the best public servants, even those singularly devoted to a cause, can fail to uphold the demands of state/church separation. That is why it is the ideal of the Establishment Clause, most clearly illuminated in the history that preceded its ratification, and in the written works of Jefferson and Madison, that best represent the proper authoritative history in determining what constitutes an establishment of religion.

Ryan Shaner recently graduated and received his law degree from Chicago Kent College of Law. Previously, Ryan earned a master’s degree in history from Illinois State University. Currently studying for the bar exam, Ryan will resume working for a state prosecutor in the fall. Ryan recently became a father, and in his free time enjoys reading, swimming, and playing board games, card games and video games.

Letterbox (August 2021)

Secular schools allow all to be included

This is an edited version of a letter to the editor of the Canton, Ohio, Repository newspaper by FFRF Member N.D.

I appreciate the April 4 column mentioning the recent Gallup poll that ‘’the number of Americans connected to a house of worship has fallen to 47 percent for the first time in 100 years,’’ which I see as good news. People are beginning to realize that you can be moral without attending church, because you don’t need religion to tell you that getting along with others and not hurting them is the right thing to do. 

As for the letter complaining about the Repository’s Easter page, I thought it was just fine, but it does bring up the question of the paper recognizing no other holidays at all, or holidays from other cultures, which would include: Ramadan, Eid al-Fitr,  Juneteenth, Diwali, Indigenous People’s Day (replacing Columbus Day), Hanukkah, and Kwanzaa, to name just a few. I would also add that religion and secular beliefs should be about compassion for all, and tolerance, tolerance for the LGBTQ+ community, reproductive rights, and supporting the separation of church and state, and that if you use religion to justify sexism, homophobia, and anti-choice rhetoric, then your beliefs are hurtful, wrong and immoral.

Keeping religion out of public schools and the government is the right thing to do, because, by being secular, we’re including everyone, and that’s what compassion without religious discrimination is really about.

N. D.

FFRF’s Markert really helped us understand 

Thank you so much for FFRF Legal Director Rebecca Markert’s participation in our conference in late May. Even though I am a member of FFRF, I learned so much more with her presentation. It is scary out there, that’s for sure.

I am mailing an official letter along with a check as an expression of our gratitude for the presentation.

Hope to see you in November in Boston at your conference.

Cultural and Secular Jewish Organization

Freethinkers should be aware of logical fallacies

We freethinkers have a reputation as critical thinkers to uphold. Being conversant with logical fallacies should be a part of the Atheist Life Skill set, and not just to avoid their use, but to detect their use by others.  

In addition to Tom Shipka’s key logical fallacies, as presented in the May issue, there are more than 100 others. is a good trainer. You can also search how to stop a logically fallacious argument dead in its tracks, or at least gain time to organize your high-information atheist position.

Atheists in small mean-spirited Christian towns can benefit from a fallacy recognition strategy. It is useful to deflect admonitions to join a church, when our polite “No, thank you” triggers their “Why not? We do so much good for the community.” Ha! Did they just use Appeal to the Bandwagon, Appeal to Emotion/Duty, and Appeal to Patriotism/Localism?  You might recognize this as the False Cause of equating religion with good citizenship.

Whenever you perceive a surface logic and a simultaneous sense of skeezy mental residue that prompts a conclusion of, “I just don’t buy it,” check for logical fallacy.

S. P.

Rape/incest excuses for abortion aren’t needed

As always, your coverage of the right for women’s bodily autonomy is greatly appreciated. However, in the May issue, you maligned one of the anti-abortion states when stating there were not “exceptions for rape or incest.” That phrase made me cringe! I request that you please not use it anymore. It distracts and detracts from your point and insinuates that a person needs an excuse in order for an abortion to be permissible. 

It also, importantly, gives a stamp of approval for the use of TRAP (Targeted restrictions on abortion providers) laws, since, hey, in many places you can get an abortion if there’s rape or incest, so, see, abortion must still be legal then! There are two excuses to get it! Using that phrase also distracts from the fact that abortion is being chipped away at. Focus on what we’re losing. 

Also, do you really think a bunch of hardcore Christian neocons are going to even believe a woman when she claims to be raped? (Just ask Betsy DeVos.)  

B. K.
Washington, D.C. 

FFRF should make room for non-atheist voices

My husband and I are members of FFRF, yet I have noticed a sentiment which permeates almost all of your literature that I am uncomfortable with: There doesn’t seem to be any space at FFRF between flat-out atheism and a God-fearing religious crackpot.

Most who speak for your publication seem to be persons who have escaped some abusive religious upbringing, which colors every transaction regarding their ideas of separation of church and state. To me, one is not a prerequisite for the other. In fact, a person could be extremely religious and still agree with your agency’s bottom line on church/state separation.

I would definitely not call myself an atheist because I do believe there is an order to the universe and in nature (e.g. how the planets stay aligned around the sun, etc.), but I do not need to attach that to any positive or negative outcomes, or creator sky-God myth, but neither do I credit science with explaining all of it, ultimately.

I don’t think it’s necessary, nor emotionally healthy, to take an “all or nothing” stance about spirituality or the mysterious order of the universe, because then we start to imagine that we meek humans and our little brains are powerful enough to understand and control it all. I’d definitely like to hear from more people in between atheism and ex-religious victim in your organization’s collective voice. Remember, atheism is a powerful, but not necessarily correct, religion, too!

M. E.
New York

Editor’s Note: Thank you for your support of FFRF. FFRF is not an “atheist organization,” it is an umbrella organization for freethinkers of any ilk. We wanted to create an organization that Thomas Paine, a deist in the classic Enlightenment sense, would have joined. Although the majority of our members is atheist, we welcome agnostics, skeptics, humanists, etc. FFRF was founded by Anne and Annie Laurie Gaylor, respectively second-generation and third-generation freethinkers who did not come from a religious background.

Day of Reason should be NYC holiday if others are

The New York City public schools were closed on May 13 for the Muslim holiday of Eid-al Fitr and the Catholic holiday of “the Ascension.” The public schools were never closed for religious holidays back in the 1950s and 1960s when I attended them, except for the winter and spring recesses, which conveniently overlapped with Christmas and Easter. These holidays, however, are still not official public school holidays.

Under our wretched, faith-pandering mayor, Bill de Blasio, various religious holidays (Jewish, Muslim and Chinese) have been added to the school calendar. 

It seems that the public schools are closed more often than they are open. The Day of Reason, however, is not a public school holiday here in the so-called “liberal” Big Apple. So much for the separation of church and state in New York City!

D. M.
New York

Unfortunately, religion will always be with us

Ann L. Lorac’s column (“All of our gods come from within ourselves” in June/July issue) offered a thought-provoking distinction between faith and religion. But her hope for eliminating religion is unattainable. Faith, i.e., belief in some supernatural existence, will always develop into religion. 

The human mind is sufficiently conscious to be able to ask, “why?” And when a conscious mind asks a question, it must be relieved with an acceptable answer. But to solve the unanswerable, man creates god(s) to conduct all unexplainable phenomena. 

Humans also recognize that they are mortal. Demand for an afterlife is an obvious reaction to salve the pain of this finality and has brought comfort to most of humanity.

Finally, life is simply not fair. Thus, there should be a Final Judgement Day to rectify this malevolence of existence and of our fellow man. 

These three foundations for creating religion are found in all societies and their various religions, each believing they are the one true religion, of course. Therefore, the goals of our FFRF are best kept to our efforts to keep religious controls out of governmental systems with no expectation or energy expended to try to eliminate religion or disabuse its followers of their faith/religion. Any hope of eliminating religion will fail because of human psychological needs, but keeping the various perversities of various religions from impinging on the lives of non-members must be absolute if truly free, democratic societies with equality for all are to exist. 

The more we can grow FFRF, and other similarly inspired organizations, the closer to a truly free and equal society we can become.

G. H.

Capital punishment needed for Christianity

While reading Brian Bolton’s essay on how the bible supports several execution methods in the June/July issue, I was reminded of St. Paul’s contention (1 Cor. 15: 3, 14, 17) that capital punishment was a foundational component of the Christian religion, i.e., that in order for Jesus to expiate original sin he had to be crucified by the Romans, which would then allow him to “rise from the dead.” So, without capital punishment, there would be no Christianity.

T. D.

Prison system in U.S. uses religion to coerce

As a military inmate for more than a decade, I can attest that religion, especially Christianity, is used as a pervasive tool of coercion. Minor examples include recreational opportunities available only to members of preferred religions and priority access to voluntary treatment programs. More extreme examples can be found when inmates seek parole or clemency, with parole boards praising religious activity or condemning lack of faith. 

I am not persecuted for my humanism, just quietly denied opportunity. Yet, I face the choice of professing a religion I have no faith in, or possibly serving more years in confinement than I would with a simple betrayal of self.

I refuse to claim a religion that minimizes the human cost of my crimes and claims I am forgiven because I ask. 

If rehabilitation is to be possible in America’s prisons, we must stop treating them as warehouses for the undesirable, and look deeply into their reform. If the task falls not to the freethinker, then who will it be taken up by?

E. M.

Why do some religions object to vaccinations? 

When I read Connecticut Gov. Ned Lamont’s statement in the June/July “Overheard,” my first thought was, “Good for you, guv.” My second thought was “Wait a minute. Just what is the religious objection to vaccinations, exactly?” I’m embarrassed to admit that I don’t know. I’m fairly certain that none of the traditional religious texts mentions vaccine. So, what is the religious exemption based on?

D. F.

After seeing religion up close, I became an atheist

I have enclosed a contribution to become a Lifetime Member. I appreciate your support of independent thinkers.

When I was in fourth grade, I loved dinosaurs and evolution sounded right to me. When I asked my public school science teacher why he did not teach evolution, he dodged the question. He had 10 kids and was Catholic.

My parents sent my older sister and me to Spokane Valley Episcopal Church, led by a charismatic minister. My sister found out he was abusing altar boys and my mom confronted the minister and others in the congregation. This was in the 1960s and no one believed her. The minister kicked us out of the church about a week before my confirmation. I never got to wear that new white dress.

As an adult, I worked as a graphic designer for a children’s hospital. It would take an evil God to invent so much disease and suffering for children and teens. Science, doctors and nurses were the true helpers.

Weighing evolution and science against the corruption of the church made becoming an atheist an easy choice for me.

G. K.

Rabblerouser lifted my mood after bad day

June 22 was a bad day for the secular voters of Arizona who support public education. In the dead of night, this state’s marginally Republican Legislature had passed a nakedly partisan budget negating our repeated rejection of school vouchers and our popular demand — via the passage of Proposition 208 — that fat-cat Arizonians pay higher taxes to support teachers and students. 

The next day, in a deep funk while shopping for books, I suddenly began laughing and immediately cheered up. So, I give a big “thank you” to the unknown monkey-wrenching Arizona freethinker who lifted the New American Standard bibles from the “Religion” rack at Barnes & Noble and stuffed them on the “Fiction” shelf and the “Horror” display where they belong!

J. B.

Southern Baptists focused on schisms, not love 

Fascinating! In a recent newspaper column, “Tensions high with Southern Baptists,” which filled almost the entire page, I counted 78 words of schism relationships — fights, contentious, takeovers, battles, wars, allegations, cutting ties, etc. — and never once saw the one word that I thought was the purpose of Jesus’ mission here on Earth: love! Is it no wonder why, for the first time in Gallup’s 80-year history of asking this question, that formal church membership has dropped below 50 percent in 2020.

L. F.

Thanks to Steve Neubauer for his years of PP work

I just want to thank Steven Neubauer (“Religion haunts a women’s health clinic” in June/July issue) for his years of service as security officer at Planned Parenthood. That’s a tough job, and it shouldn’t be. Those so-called Christians can be so mean.

M. A. C.

Everyone should watch the Scientology series

I recently watched the “Leah Remini: Scientology and the Aftermath” series on Netflix. I would strongly recommend it to all FFRF members.

The most important things I learned from the series are:

• That Scientology’s 501(c)(3) status was allowed in 1993 only after aggressive harassment of IRS individuals. 

• That members are routinely abused with no recourse except to lose all connections with one’s family. 

• That the church systematically violates requirements for nonprofits, notably that an organization not be involved in anything illegal and not stockpile revenue, but must engage in activities of a charitable, religious or educational manner.  

As an FFRF Life Member, and more importantly, as a taxpayer, I think FFRF should officially recognize this injustice and join others’ efforts to oppose this “church.” 

D.M. S.

When ‘God’ talks, it’s listening to yourself

I’d like to comment on two items from Freethought Today. I always read it cover to cover.

First, the article in the June/July issue by Ann L. Lorac (“All of our gods come from within ourselves”) has some good and varied points to make. I have found that when people relate to a god — for instance, how the god talks to them, shows them the solution to a problem, etc. — that they are really listening to their own brain. In effect, they are worshipping their own brain.   

Also, the letter from Phyllis Murphey about the term “passing away” made me think of something I read: The only one passing away is an errant throw by a quarterback on a football team.

Keep up your wonderful, always fair and honest, work.

P. H.

What to say in search of the lost Jesus

Suppose someone appears at your front door and asks, “Have you found Jesus?”

You might respond earnestly, “I didn’t know he was lost.”

They might say, “He isn’t really lost.”

You could respond, “Well, there you are.” [SLAM]

L. L.

Donation made in loving memory of Gigi Gillis

I have enclosed a check for $500, donated in loving memory of “Gigi” Gwendolyn Gillis, a Lifetime Member of FFRF. Gigi so enjoyed attending your conventions and reading your newspaper.



Can we all live to be as old as Noah?

In David Brooks’ June 3 New York Times column “You may live a lot longer,” he noted that “People are living longer, staying healthier longer and accomplishing things late in life that once seemed possible only at younger ages.”

Brooks, it appears, isn’t aware, that according to the bible (which is from the supposedly inerrant word of God), people (such as Noah) lived for about 900 years, when the Earth’s human population was about 12 million or so.

Now, the human population is closing in on 8 billion.

So, if the human population can return to what it was, during the time of Noah, maybe we’d all have the potential to live for a thousand years. But, to do that, we’d need to use birth control — which we won’t, because both today’s GOP and the Roman Catholic Church oppose the use of birth control.

W. D.

Convention 2021 information

Hotel reservations

The convention hotel is the Boston Park Plaza, 50 Park Plaza at Arlington St., Boston. The convention rate is $189 single, double, triple or quad. Suites are $389 and up. Attendees should call the Central Reservations Office (617-379-7129). Please ask for “Freedom From Religion Annual Convention.” The hotel will discount self-parking to $30 per day at Motor Mart Garage.

The cut-off date for reserving rooms is 5 p.m. Eastern on Oct. 18, 2021. FFRF urges you to plan ahead and reserve early to avoid disappointment.


In addition to offering several complimentary food or dessert receptions, the convention will include four optional group meals. FFRF does not mark up meal prices, which include 17 percent gratuity, 10 percent taxable administrative fee and 7 percent sales tax.

A robust and tasty box lunch, $60, will be offered at Friday noon for participant convenience, concurrent with Andrew Seidel’s Christian nationalism workshop.

Choices include:

• Grilled Chicken Caesar Wrap

• Turkey BLT Wrap

• Grilled Vegetable Wrap

Wraps will be served with roasted vegetable penne salad, Cape Cod potato chips, a piece of whole fruit, a freshly baked cookie and choice of assorted soft drinks or bottled water.

A Southern barbeque buffet, $65, with vegetable chili and cornbread muffin, rotisserie chicken with BBQ sauce and greens, carved brisket with mac and cheese and fruit kabobs will take place from 5–7 p.m. Friday.

FFRF’s Non-Prayer Breakfast, $45, includes scrambled eggs, bacon and breakfast potatoes, assorted pastries, juice, coffee and tea, with vegetarian/vegan options.

The Saturday banquet dinner of $95 will include Maple Glazed Statler Breast of Chicken with buttermilk mashed potatoes, seasonable autumn baby green salad with roasted beets, quinoa, goat cheese, apple cider vinaigrette, and Boston Cream Pie. The vegetarian option is Butternut Squash Ravioli.

A two-hour lunch on your own is scheduled for Saturday to permit some fresh air, sightseeing or relaxation between events.

The Boston Park Plaza itself offers a variety of dining options: Kozy Korner for drinks, lunch or dinner in Off the Common, the uber-modern steakhouse Strega Italiano just off the lobby, and classic Irish pub J.J. O’Connor’s, just outside the entrance. The Back Bay Boston neighborhood offers a variety of restaurants.

Plan time to sightsee

The Boston Park Plaza is in the officially recognized neighborhood of Back Bay Boston, built on reclaimed land in the Charles River basin. It’s home to a number of restaurants, glitzy stores, skyscrapers, the commercial strips of Newbury Street and Boylston Street, the residential brownstones of Marlborough Street and Copley Square, a grassy plaza within walking distance. The hotel is about a mile from the Charles River Esplanade, a waterfront haven for runners.

You may wish to take a self-guided Freedom Trail tour of historic Boston sites, or sign up on your own for a guided tour on Thursday or Sunday at or choose any number of other tour options.

Covid-19 rules – vaccinations required

The Boston Park Plaza is site of FFRF’s 2021 national convention, Nov. 19-21.

The event is limited to FFRF members and their guests who are fully vaccinated* for Covid-19. Please be sure to indicate on the registration form whether you have been vaccinated. FFRF reserves the right to request proof of vaccination. *Only exception: If you are under a physician’s explicit instructions not to be vaccinated for Covid-19 due to health/immunity issues.

The great news is that atheists as a group in the United States are the most likely and willing to be vaccinated. We fully expect the event to reach “herd immunity.” FFRF staff members are fully vaccinated.

Please note that the Boston Plaza Hotel is adhering to all federal, state and local guidelines and does not at this time require its staff to be vaccinated.

It currently does require them to be masked. The hotel has indicated it will follow whatever protocol, as yet unknown, is required by the government at the time of FFRF’s convention.

Although FFRF will not require masking for vaccinated individuals, unless CDC, Massachusetts or Boston rules change and require them, convention participants of course are free to wear masks. FFRF will be offering its popular masks, with the slogans “FFRF,” “Science is Golden” and “In Science I Trust,” at no cost during the convention.

The conference room will be set up for about 800 seats in the usual theater format, which does not allow for social distancing. However, FFRF will inform participants of any requirements requested by authors during book signings, such as masking or social distancing.