Last week, I spent a couple of days in Indianapolis at a roundtable on law and the Protestant Reformation directed by my friend and sometime co-author, John McGinnis of Northwestern. During a break, I walked over to the Indiana Statehouse where, much to my surprise, I discovered the Indiana Chapel — that’s its official designation, though the sign on the door (right) says “Meditation Room” — on the fourth floor. It is apparently the first statehouse chapel in the United States, and one of only six, the others being in statehouses in Arkansas, Florida, Illinois, Kentucky, and Texas. The chapel is a small room without sectarian symbols; to me, it resembles a Victorian parlor. There is, nonetheless, a Protestant feel to the room, no doubt created by the lectern at the front with a King James Bible, the hymnal on the electric organ, and the bookcase filled with Bibles, presumably for the Bible studies advertised on a bulletin board outside the door (below). According to this website, a private evangelical Christian group called the Capitol Commission of Indiana regularly uses the room, though it doesn’t seem other groups are excluded. I don’t know if anyone has ever thought to bring a lawsuit about the Indiana Chapel, but, assuming the room really is open to everybody on an equal basis, I don’t think an Establishment Clause challenge would succeed, either under the Lemon/endorsement test or Marsh v. Chambers, the legislative chaplain case. In 1988, the Seventh Circuit held that a similar non-sectarian chapel/meditation room in the Illinois state capitol did not violate the Establishment Clause.
