Prayer And Invocation At City Council Meetings.

City typically begins each of its city council meetings with a citizen-led prayer or invocation. The city’s policy sets forth a two-step procedure for soliciting volunteers to lead the invocation.  The city clerk compiles and maintains a database of religious congregations with an established presence in the city. Next, the clerk mails all of the listed religious groups an invitation to open a city council meeting with an invitation:  “This opportunity is voluntary, and you are free to offer the invocation according to the dictates of your own conscience. To maintain a spirit of respect and ecumenism, the City Council requests that the prayer opportunity not be exploited as an effort to convert others . . . nor to disparage any faith or belief different from that of the invocational speaker.” The plaintiffs brought an action against the city under 42 U.S.C. § 1983 and Article I, Section 4 of the California Constitution for declaratory and injunctive relief, arguing that the invocations and the policy amounted to an establishment of religion. The Ninth Circuit concluded the prayer policy did not constitute an unconstitutional establishment of religion. Rubin v. City of Lancaster (Ninth Circuit; March 26, 2013) 710 F.3d 1087.