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
The Society of Separationists and two members sued the Cities of Rolling Meadows and Zion, alleging their municipal seals, which contained Christian symbolism, violated the Establishment Clause. The Rolling Meadows seal featured a Latin cross, while Zion's seal included a cross, dove, sword, crown, and the motto "God Reigns," all explicitly religious in origin and meaning. Plaintiffs claimed injury from being forced to display these seals and altering their behavior to avoid them.
Issue
The central legal question is whether the Establishment Clause of the First Amendment prohibits the use of sectarian religious symbolism on a municipality's corporate seal. Specifically, the court examined if the seals had a secular purpose, advanced or inhibited religion, or fostered excessive entanglement.
Holding
The court held that both the Rolling Meadows and Zion seals, emblems, and logos constituted unconstitutional endorsements of a particular religious faith. It reversed the district court's judgment regarding Rolling Meadows and affirmed the judgment against Zion, enjoining both cities from continued use of their current designs.
Rule
The court applied the three-prong Lemon test: a government practice must have a secular purpose, its primary effect must neither advance nor inhibit religion, and it must not foster excessive entanglement with religion. The court focused on the "effects" or "endorsement" element, finding that the seals conveyed a message that Christianity was favored or preferred.
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