ABSTRACT
The public display of religious symbols is a contentious religious liberty issue. Most religious symbol and display cases turn on whether several justices agree that a display violates the endorsement test, since it incorporates much of the Lemon analysis without limiting the Establishment Clause to a prohibition on government coercion. In Lynch v. Donnelly, 465 US 668, the Supreme Court permitted the display of a religious Christmas scene by the city on private property. The Court held that allowing the display was permissible because it was unlikely that anyone viewing it would infer that the government supported the religious message of the display. Lower federal courts have wrestled with the endorsement theory and the other Establishment Clause theories in resolving the many religious display cases presented to them. Some courts have argued that merely coming into contact with an offensive religious display by a government is an injury that can support a lawsuit.
