The 2014 Supreme Court case Town of Greece v. Galloway is being used to permit Satanists to give invocations at public events. As this article explains, the case stands broadly for the proposition that invocations at public events such as town council meetings must be open to all faiths within the community, and the municipality cannot discriminate among them.
This being America, one person founded a “First Pompano Beach Church of Satan” and petitioned a number of towns to be included in the invocation list. Some have done away with invocation entirely to avoid having the Satanists there. Some have put him on a (long) waiting list but at least one is permitting him to speak. A self-described “minion of Satan,” the article describes his project as:
“Part political commentary, part performance art, Stevens’ “Satan or Silence Project” has presented 11 South Florida municipalities with some stark choices: Either drop the invocation that opens city commission meetings, or allow him, a self-described ‘minion of Satan,’ to lead a prayer to the prince of darkness.”
As a threshold matter, this may not even pass muster under Galloway, which was concerned about religious communities that actually existed within a political boundary being excluded. Here the lack of a congregation or physical presence in some of the towns targeted might be enough to justify an exclusion. But as silly as it may seem, this controversy raises some interesting questions about the connections between religion and society. From the article, the “church” seems more of a stunt than an actual belief system, and seems designed to criticize the notion of public prayer at all (the “minion” notes his invocations might “include beer, nachos and a mariachi band.”) But the case law is somewhat consistent that the sincerity of beliefs cannot be questioned by a court, though the evidence here seems pretty clear. But let’s assume he is a sincere believer in the Tempter.
Should the invocation nevertheless be allowed? That depends on what we want to get out of such an invocation. Christian invocations of this type typically ask for strength and wisdom in public deliberation, and guidance for judgment to do what is in the common good. But not all invocations would be appropriate – for example, an explicit call for unbelievers to convert. As the deputy mayor of Boca Raton says in the article, such invocations set “the proper tone” for deliberations. A mariachi band and an invocation to a being typically associated with deception and cruelty, would seem to be inappropriate.
An invocation then, is not merely ceremonial or rhetorical window dressing. An invocation, therefore, does have a civic purpose and municipalities may have a basis for distinguishing among the kinds of invocations they seek.