The late Justice Antonin Scalia once described the infamous Lemon v. Kurtzman test for analyzing Establishment Clause matters as a “ghoul” from a “late-night horror movie” that simply will not die. Felix v. City of Bloomfield, the US Court of Appeals for the Tenth Circuit’s most recent application of the Establishment Clause, shows that the monster is alive and well. 
 |
|
|
