Clint W. Harris and the Society of Separationists, Inc. v. City of Zion, Lake County, Illinois, Mayor of Zion and Zion City Council, Theodore M. Kuhn and the Society of Separationists, Inc. v. City of Rolling Meadows, Mayor of Rolling Meadows and Rolling Meadows City Council
927 F.2d 1401 · Court of Appeals for the Seventh Circuit · 1991
Facts
Plaintiffs challenged the city seals of Rolling Meadows and Zion, Illinois, alleging that their inclusion of Christian symbolism, such as Latin crosses and the motto "God Reigns," violated the Establishment Clause of the First Amendment. Residents claimed injury by being required to display these seals on vehicle stickers and garbage bags, and by altering travel routes to avoid public displays. The district court found Rolling Meadows' seal constitutional but Zion's unconstitutional.
Issue
Does a municipality's corporate seal, emblem, or logo that incorporates sectarian religious symbolism, such as a Latin cross or a religious motto, violate the Establishment Clause of the First Amendment?
Holding
The court held that both the City of Rolling Meadows' seal and the City of Zion's seal, emblem, and logo represent unconstitutional endorsements of a particular religious faith. It reversed the district court's judgment regarding Rolling Meadows and affirmed regarding Zion, permanently enjoining both cities from using their current designs.
Rule
Government action violates the Establishment Clause if it lacks a secular purpose, has the principal or primary effect of advancing or inhibiting religion (the endorsement test), or fosters an excessive entanglement with religion. The "effects" test prevents government from conveying a message that religion or a particular religious belief is favored or preferred.
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