## Facts

- The Town of Great Falls opened every town council meeting with an official prayer delivered by the mayor or council members, all of whom were Christian.
- The prayers frequently invoked explicitly Christian names and themes, including “Jesus,” “Jesus Christ,” “Christ,” or “Savior,” often concluding “in Christ’s name.”
- Attendees customarily stood, bowed their heads, and participated by saying “amen.”
- Darla Kaye Wynne, a Wiccan and non-Christian resident, regularly attended meetings and felt excluded by the repeated Christian invocations.
- Wynne requested that the council use nonsectarian references such as “God” rather than “Jesus” or “Christ,” but the council refused.
- After her objections, Wynne faced community hostility, including petitions favoring “Christian prayer,” derogatory labels, and statements that she was unwelcome.
- The town had no policy restricting prayers to nonsectarian content and did not include or invite representatives of other faiths to offer invocations.

## Issues

1. Whether a town council’s practice of opening meetings with prayers that repeatedly invoke Jesus Christ violates the Establishment Clause, notwithstanding the tradition of legislative prayer recognized in *Marsh v. Chambers*.
2. Whether an injunction barring invocations of names specifically associated with Christianity is an appropriate and properly tailored remedy.

## Decision

- The Fourth Circuit affirmed the district court’s judgment after a bench trial.
- The court held the council’s repeated, explicit Christian invocations in official prayers violated the Establishment Clause by promoting one religion over others.
- The court concluded *Marsh* permits legislative prayer only when it does not advance, proselytize, or affiliate government with a single faith; repeated invocation of “Jesus Christ” crossed that line.
- The court affirmed a permanent injunction prohibiting the council, in its official prayers, from invoking names specifically associated with the Christian faith, while not prohibiting prayer altogether.

## Legal Principles

- The Establishment Clause requires governmental neutrality between religions and between religion and nonreligion.
- Legislative prayer may be constitutionally permissible under historical practice, but it must not advance one faith, disparage others, or identify the government with a particular creed.
- Official prayers that explicitly invoke a specific religion in preference to others constitute unconstitutional governmental endorsement.
- Context matters: when citizens attend meetings to petition local officials, official prayer practices that expect participation can increase perceived coercion and the exclusion of religious minorities.
- Injunctive relief may be limited to removing sectarian identifiers while allowing nonsectarian solemnizing invocations.

## Conclusion

The court held that Great Falls’ practice of opening town council meetings with explicitly Christian prayers violated the Establishment Clause because it aligned the town government with one religion; a narrowly focused injunction barring sectarian Christian names in official invocations was upheld.


Wynne v. Town of Great Falls, 376 F.3d 292 (4th Cir. 2004)