Divisiveness and the Ten Commandments Cases:

The opinions joined in these cases by Justices Stevens, O'Connor, Souter, Ginsburg, and Breyer routinely stress that Ten Commandments displays and the like often threaten to produce "religious divisiveness," and that the Establishment Clause should be read as making such divisiveness into a reason for invalidating (at least some) government actions. Past Supreme Court cases have made similar claims.

But I wonder: What has caused more religious divisiveness in the last 35 years -- (1) government displays or presentations of the Ten Commandments, creches, graduation prayers, and the like, or (2) the Supreme Court's decisions striking down such actions?

My sense is that it's the latter, and by a lot: All these decisions have caused a tremendous amount of resentment among many (though of course not all) members of the more intensely religious denominations. And the resentment has been aimed not just at the Justices but at what many people see as secular elites defined by their attitudes on religious matter. The resentment is thus a form of religious division, and I've seen more evidence of that than I have of religious division caused simply (i.e., setting aside the litigation-caused division) by the presence of Ten Commandments displays, creches, or even graduation prayers.

Isn't there something strange about a jurisprudence that in seeking to avoid a problem (religious divisveness) causes more of the same problem, repeatedly, foreseeably, and, as best I can tell, with no end in sight?

Now it may well be that the Court's actions are justifiable under some other theory. There may well be some other reason why government use of such religious symbols must be struck down despite the religious divisiveness of such government actions. But it seems mighty odd for the Court to strike the actions down in the name of a goal -- avoidance of religious divisiveness -- that the Court's actions are themselves undermining.

I should stress that I am not trying to take in this post, or other posts, a definitive view on how the Establishment Clause should be read in cases involving government use of religious symbols or statements. Rather, I'm trying to provide what I hope are helpful comments on particular arguments that I've heard -- comments that might be of use to people who are drawn to different bottom lines. I've found somewhat more to criticize in the no-posting-of-the-Ten-Commandments opinions today than in the OK-to-post opinions. But please take my posts for what they are, which is specific comments on specific arguments, not overall judgments on the matter.

Thief (mail) (www):
I've always wondered why the Supreme Court never told the Michael Newdows and Madalyn Murray O'Hairs of the world to just follow the suggestion of Cohen v. California and "avert their gaze..."
6.27.2005 2:33pm
My view of the net result of the 10 Commandments decisions is that they track -- almost perfectly -- the Supreme Court's view of obscenity back in the days before Miller v. California when Justice Potter Stuart said "I know it when I see it." The standard essentially is that the work, taken as a whole, appeal to the improper (prurient) interest in religion, and that it lack redeeming secular value.

My advice to states wishing to erect 10 Commandments or similar monuments would be to hire pornography defense lawyers from the 1960s and 1970s for advice on how it's done, because their ouevre is now the state of the art in this area. All the standard tricks -- double-entendres, making sure that religion scenes are embedded in a secular plot, quantitatively measuring the work to ensure that religious content isn't a majority, coming up with secular themes and purposes to lay over the religion scenes -- all of this would be familar to anyone with any knowledge of obscenity law and the shifting standards the court used in attempting to figure out how to suppress works with improper themes without too greatly restricting expression perceived as legitimate.

I have a personal distate for "I know it when I see it" attitudes. To me, it bespeaks a claravoyant sollopsism fundamentally disrespectful of other people, who are equally capable of 'seeing' how things should be through gut feel and have equally strong if different views. By abandoning principle, precedent, history and textualism, Justice Breyer's opinion leaves only power. Because it abandons all the institutional constraints which protect the Court from naked legislative control, it all but invites Congress to appoint folks solely for their agreeable personal (sorry, "legal") views.

Go ahead and try it! Seriously! Read some of the old obscenity cases, cross out the word 'sex', write in the word 'religion' in crayon, and see if you don't get something astonishingly identical to the Supreme Court's current religious-monument jurisprudence!

I would also invite comedians everywhere to make fun of the Court for making its analysis of obscenity and religion almost identical. Sometimes, the best thing one can possibly do for ones country is to hold up to ridicule that which is truly rediculous.
6.27.2005 2:44pm
carpundit (www):
There are two kinds of division. One, the religious majority (Christian) being upset by hostility to religion in these cases. Because they are many, their upset is loud. Two, the silent upset of the secular (or non-Christian). It is divisive if such displays are not limited. That division is unremarked, but real. It is not in the public eye, because the loudest and largest group approves the displays.
6.27.2005 2:49pm
Greedy Clerk (mail):
GIven that you never lived in this country when religious displays were allowed in any significant way, you are just assuming that were it the other way around, people who are not of the dominant religion would be happy as clams to have to pray to Jesus and see crosses in public schools, etc. THe evidence from what I know is quite to the contrary. From what my father tells me, he and most other jews in his school were very resentful of all that bs.

As for your comment about resentment being aimed at "secular elites" who are trying to destroy religion, this is more a result of a cynical effort by people like Pat Robertson, Jerry Falwell, and George W. Bush to create such feelings so that they can be exploited in elections. Recall the flyer being passed out in Arkansas by the Bush campaign saying that Kerry would ban the Bible --- such a flyer would not be taken seriously at all if people like Robertson, Falwell and Bush did not completel misrepresent the effect of court decisions and create a judicial "bogeyman" ready to destroy religious people.
6.27.2005 2:51pm
no doubt i'm an idiot but wouldn't divisveness be the result no matter which way the decision went and since history demonstrates and the founding fathers framed with referenc e to that history ie that it's more dangerous to be seen promoting religion that to be seen trying to stiffle it - doesn't that make the offending decision the lesser of two evils?
6.27.2005 2:52pm
Devin McCullen (mail):
I suppose the counter-argument would be that the Court isn't taking actions that cause religious divisiveness, but they're responding to the actions of others. The governmental officials are putting up Ten Commandments statues, or making spaces available for prayers, or whatever. I think there's a certain amount of validity to it, and certainly the Court shouldn't be making decisions because they don't want to upset people. (And yes, this might be termed the "He started it!" theory of jurisprudence.) I would be interested in hearing how someone who made the divisiveness argument would respond to this, though.
6.27.2005 2:54pm
A2 Reader:

I think the point is that it is their country, their public space, too.


Interesting point. Your implied criticism is that the justification is inadequate or poorly phrased, and this may well be.

That said, it seems odd to lay blame at the for divisiveness at the Court's feet. Was the Court to be 'blamed' for the chaos that followed Brown? Surely the Court's activity there was a 'but-for' cause, but that is not the whole story. Nor is, I think, the Court 'to blame' here -- if pro-Commandments advocates cannot accept a society in which they do not dominate, then whose fault is the resultant tension when the Court steps in to defend the minority?
6.27.2005 2:54pm
Shanti (mail):
Is there not an assumption in the idea that the Establishment Clause cases have created a greater divisiveness? Specifically, that in the abscence of the rulings there could be less divisiveness, but is it not equally as plausible that the divisiveness could have been greater then what has been characterized if the cases had not been ruled in the fashion they were?
6.27.2005 2:59pm
Craig Oren (mail):
could it be that the decisions *reflect* division in society more than they cause it? As America becomes more pluralistic religiously, it becomes harder to obtain consensus on what constitutes an acceptable expression.
6.27.2005 2:59pm
Bob Flynn (mail):
Isn't there something strange about a jurisprudence that in seeking to avoid a problem (religious divisveness) causes more of the same problem,...

Brilliant insight. Perhaps a narrower corrolary of "The law of unintended consequences," is needed. I propose:

"The law of opposite effect"

Meaning, in essence, by trying to remedy A, you induce more A.

One could argure, in the political arena, that this has happened with McCain-Feingold (seeking to reduce influence of $$ in politics, Mc-F has induced more $$ in politics)
6.27.2005 3:01pm
Peter Sean Bradley (mail) (www):
Your claim that the Supreme Court decision striking down religious displays has created more divisiveness than the displays themselves sounds absolutely correct to me. As a practicing Roman Catholic, I have never had the same level of investment in the need to display the "10 Commandments" as some members of certain Protestant denominations have. Moreover, I understand that the "10 Commandments" displayed would not be in the format used by the Catholic/Lutheran confessions.

But, so what? We don't live in a country where a majority of people are Catholic or Lutheran; we live in one whose historic roots trace back to another tradition and it is useful to remember those roots, inasmuch as we owe so much - freedom, democracy, the rule of law - to that history.

I've never been threatened by living in a majority Protestant country. If anything, the cultural differences between my faith tradition and that of the majority have enabled me - and I suspect other members of religious minorities - to keep in mind the significance of those sometimes subtle differences between traditions. For example, when I listened to a Baptist give a baccalaureate address, I listened with bemused appreciation. It didn't appeal to my cultural tastes, but it appealed to people I like and respect, so God bless them all. All of which is suggestive of the fact that Justice Scalia had it right in his dissent in Lee v. Weisman when he said that exposure to other religious traditions cultivates the civic virtue of tolerance.

On the flip side, as a religious person I recognize that these decision express a stigmatizing attitude toward relgion; these decisions imply, or explicitly say, that religion is a virus that can infect and harm if it is not carefully contained. And, on that point my hackles rise because a real divisivion is being made between Believers and Secularists, with the Supreme Court picking the Secularists as the winners.
6.27.2005 3:04pm
Jim Rhoads (mail):
To what extent has the Supreme Court in this area of jurisprudence, in reality, made a "law" or rule respecting the Establishment of Religion in requiring that the now religion of non-religion trumps any governmental display of religious beliefs or symbols.

The First Amendment only prohibits Congress and the 14th only prohibits State Legislatures or their instrumentalities from making such laws, but is the Court free to do what legislatures may not?
6.27.2005 3:04pm
Dave Bundrick:
I appreciate the point that Eugene is trying to make, and I don't think the question lends itself to an easy answer (frankly, I think "divisiveness" is not a helpful touchstone in these inherently divisive cases).

One thing I will point out is that there is at least some distinction to be made between affirmative government acts and negative prohibitions.

A rule that the government should not advance or hinder religion is divisive inasmuch as it displeases some people who would like for the government to do more. That is, government inaction displeases them, and they want the government to actively promote religion (IMO).

Whereas a local government posting the ten commandments is divisive inasmuch as it establishes the government as being actively pro-religion.

Put another way, I see one side that wants government to actively advance religion, and another side that wants government to neither advance nor hinder religion. Both positions are divisive, because they are mutually exclusive and no compromise will please both sides. However, I see an important distinction between divisive government action and divisive government inaction.

Your mileage may vary.
6.27.2005 3:09pm
Dave Bundrick:
Also, what Devin said.
6.27.2005 3:12pm
Craig Oren (mail):
May I suggest to Mr. Bradley that his comfort arises in part from the caselaw on the subject? There was a time when New Jersey required that every public school day begin with the recitation of ten verses from the King James version of the Bible. I think Mr. Bradley would agree that the purposes were to vindicate the Protestant view of the supremacy of the Bible, and to endorse specifically a Protestant translation. I canot speak for Mr. Bradley, but I do not think he would have wanted to be so indoctrinated, nor would he want his children to do so. (Incidentally, the Anti-defamation League, a largely Jewish group, opposed the Ten Commandments display as also involving endorsement of the King James version.) By striking down such practices, the courts have helped to make Catholics comfortable in a Protestant-majority nation; don't we need the same to make non-Christians comfortable in a Christian-majority nation?

I am reminded here of Phillip Roth's Operation Shylock, where the narrator praises Irving Berlin as being more inspired than Moses: Berlin wrote White Christmas and Easter Parade, songs that de-Christed Christmas and "if that is what it takes to make my people comfortable in America, let it snow, let it snow, let it snow!"
6.27.2005 3:21pm
eddie (mail):
I disagree that the divisions have in the main been perpetrated by the decisions of the Court: When a state judge moves a display into the court rotunda, is not that begging for the Court to make a decision that is divisive?

When any particular individual asserts their right to free exercise, does that entitle the person to a comfortable mandate for that exercise to occur on government property. I think the assertion of such entitlement is the divisive act. Or perhaps let's just always blame the non-religious person who feels entitled to not be exposed to (or be required to subsidize or be seen as a supporter of) religious displays. No one has suggested closing down any churches or arresting any prophets or missionaries. Simply, the government should avoid contact. And believers should respect that avoidance.

A. Weren't the words "under God" added to the pledge of allegiance only recently (i.e. in the 50's as some sort of cold war condemnation of those godless commies)?

B. There are a lot of unsubstantiated claims being made about the prevalence of religious displays on government property in the past. Anyone got some actual facts?
6.27.2005 3:30pm
James Kolbert (mail):
Professor Volokh's argument, if I correctly understand it, is that Supreme Court opinions constitute state-action. Thus, much as a state court enforcing a racially-restrictive covenant is a VOID act, a SCOTUS holding could be VOID (of course, for institutional reasons, only a future SCOTUS could overrule the holding).

If this argument is sound, then what would prevent a men's rights litigant from arguing that the balancing test in Doe v. Bolton (always in favor of the woman) is a denial of Equal Protection? Or that child support laws violate Equal Protection so long as women have a unilateral right to abortion, because a hypothetical woman's female sex partners are not targeted for income redistribution, but her male sex partners are, simply because of the natural and probable consequences of their biological capacities, i.e., inability to generate sperm and fertilize a woman during intercourse. This undue burden, one could argue, on heterosexual male intimate association is not imposed on lesbians, female bisexuals, or homosexual men. Thus the balancing test in abortion rights cases and child support policies (always favoring the mother) singles out male heterosexuals for their ability to produce sperm and the kind of sexual activity in which they choose to engage. If you engage in sexual activity that tends to fertilize, you pay; if you do not, you don't.

I do not mean to be controversial, but this seems the logical conclusion of Professor Volokh's argument.
6.27.2005 3:47pm
Mr. Loudoun (mail):
The parties responsible for the divisiveness are those who choose, quite unnecessarily, to display the Commandments on government property. I can't fathom why that is not clear to Mr. Volokh. I think he is confusing "upset" or "annoyance" in the religious majority with relevant divisiveness wherein one group (non-Christians) is colored *by the state* as less than pious.

When these displays are prohibited, no one could reasonably thereby feel the chill of religious discrimination breathing down their necks, or the necks of their descendants; the proliferation of displays does have that effect.

In the absence of the displays, Christians need not feel any less proud of their religion. They are merely deprived of a redundant symbol of the power of their co-religionists in state government (in Texas and Kentucky, remember). They claim that Court prohibitions discriminate against them. But they do not have standing to make that claim in court. Only the state itself, or its officials in their official capacity, may defend these displays.

Is Breyer really saying that divisiveness around the private water cooler is to be avoided by the Court's First Amendment decisions? No, I think he's talking about divisiveness wherein a faction is colored *by the state* as more or less pious than another.

I think Mr. Volokh misses the point.
6.27.2005 4:16pm
Gil (mail) (www):
I agree with those who make the distinctions between divisiveness caused by positive actions (e.g. introducing a 10 commandments display into a public area) and that caused by undoing such actions. The introducers, it seems to me, are responsible for much of the divisiveness rather than the Court for reverting the situation back to the status quo.

Also, it's not at all clear to me that Eugene can accurately estimate net divisiveness by observing how much public complaining goes on. As carpundit observed, much of the division caused by the displays goes unremarked, but it's real nevertheless.

I'm sure that there were areas where one could find much more easily observable divisiveness caused by the removal of Jim Crow laws than before that removal, but did the total divisiveness increase?

If we remove trade restrictions there are often many more obvious job losses than gains that are directly attributable to the new trade, but I don't think Eugene would argue that this implies that free trade causes more job losses than gains.
6.27.2005 4:17pm
David Chesler (mail) (www):
Divisiveness. Consider the parent who says to two squabbling siblings: "If you two can't stop fighting over what television program to watch, I'm going to shut off the television all together" and the carries out the threat. In the short term the parent has increased divisiveness (since now both siblings are angry at the parent) but the parent has probably cut down on the overt squabbling, and (closer analogy to the Establishment Clause reasoning) has protected the weaker sibling from being bullied into accepting the stronger sibling's television choice.

I haven't read today's decisions yet. I am somewhat religious, I am not Protestant. I don't know what kind of monument I'd feel comfortable with to say "Law is good. Even imperfect laws, and in some societies even laws that lack Establishment and Free Exercise clauses, are better than anarchy. Regardless of how we got the Ten Commandments, their mythos, including the iconic two tablets, are the foundation of the earliest in the chain of bodies of law that got us where are secular law is today."

I suppose I'd be less comfortable with busts of Isaac Newton if there were people today who were actively trying to kill other people for heretically believing that Relativity better describes the Universe than does Newtonian mechanics.
6.27.2005 4:38pm
Jon H (mail):
Peter Sean Bradley writes: "these decisions imply, or explicitly say, that religion is a virus that can infect and harm if it is not carefully contained. And, on that point my hackles rise because a real divisivion is being made between Believers and Secularists, with the Supreme Court picking the Secularists as the winners."

I would disagree. Plenty of Christians would consider displays of non-Christian religious symbols or activity to be something that can "infect and harm if not carefully contained."

For example, certain Congressmen have objected to the fact that Wiccan military personnel observe their religious ceremonies on bases. (I think Tom Delay was one.)

There's always going to be people who believe that some or any other faith is error (or downright evil), and should be controlled, lest anyone be led astray.

It isn't really a religious vs. secular issue. It's actually a religous vs. religious issue.
6.27.2005 4:54pm
Goober (mail):
Isn't there something strange about a jurisprudence that in seeking to avoid a problem (religious divisveness) causes more of the same problem, repeatedly, foreseeably, and, as best I can tell, with no end in sight?

Come now, Professor Volokh, it's the American way! Just look at all the attention we give our national miscreants in our outrage over all the things they do for attention.

I always thought the hurt-feelings or religious-divisiveness or informal-coercion arguments were unnecessary. The real basis for these decisions is that part of the First Amendment that says government doesn't get to tell you when or how to pray. If adherence to that principle causes difficulty, it's still worth it for the principle.
6.27.2005 4:59pm
Eric Rasmusen (mail) (www):
The argument that 10 Commandment displays create divisiveness is a great example of the problem of judges basing decisions on questions of fact without using any evidence except personal impressions. The question Prof. Volokh raises is a neutral one, a question of fact like whether most White southerners liked segregation in 1930. You may not like the answer, or think it relevant, but there does exist an objective answer. Volokh's casual impression is that more people are bitter about the public attitude towards religion now than in 1980; Stevens's is the opposite. The most important difference, though, is that Stevens relies on his casual impression to write a judicial opinion. I'd rather trust a jury, or a legislature-- or at least a Brandeis brief giving us polling data, hate crime statistics, or whatever.
6.27.2005 5:18pm
Thief (mail) (www):
Yes, it's their public space too. But sometimes, like in Cohen, things show up in the public space that offend people. (e.g. Karen Finley, Serrano's "Piss Christ," KKK rallies, Confederate flags, American flags, apotheoses of FDR/JFK/Reagan/Clinton/W, the Pledge of Allegiance, Gay Pride Parades, Korans, etc. etc.) If any of these are offensive, the proper response (IMO) is to shrug, and walk away. There will always be things of this nature in a public space; after all, the definition of a public space is one that anyone can use. And make no mistake; they are just things. Seeing a Ten Commandments plaque in a 50-year-old courthouse is not a command or inducement to pray any more than seeing a Confederate flag is a command to start a lynch mob, or seeing Karen Finley is an inducement to smear chocolate all over yourself and perform various unspeakable acts. [Thomas pursued this logic in his concurrence in Van Orden... "In no sense does Texas compel petitioner Van Orden to do anything. The only injury to him is that he takes offense at seeing the monument as he passes it on his way to the Texas Supreme Court Library. He need not stop to read it or even to look at it, let alone to express support for it or adopt the Commandments as guides for his life. The mere presence of the monument along his path involves no coercion and thus does not violate the Establishment Clause.]

I hate to bring up South Park, but this whole debate sounds suspiciously like that episode where the town is trying to put together a Christmas pageant. First, it starts off with the nixing of the nativity scene because it offends non-Christians. The Santa &Reindeer go (offensive to Christians). then Christmas trees (environmentalists), followed by lights (people with epilepsy), followed by pretty much everything else. The result of this is a mishmash of nothing (to the tune of a Phillip Glass minimalist solo). If everyone has the right to see the public square purged of anything they deem controversial or offensive, then eventually the public square will end up barren and hollow, and a vital part of our community will be lost.

I suppose what gets my goat about this whole subject (and why the whole thing is divisive) is that much of the anti-commandments position is based on subjectivity, emotion, and ultimately, pure solipsism. Grievous offense is taken, even though none is offered. Feelings become the sole determinant of constitutional law. I thought the law was made of sterner stuff.

I'm a Christian, though not aggressively so. (I thought Roy Moore was an ass for trying to keep the rock in the Alabama Supreme Court, introducing the 10 Commandments where they were not present before.) What I object to is this arrogant attitude that every last jot and tittle of religion needs to be scrubbed out of the public square lest the feelings of a tiny, delicate minority be bruised. Those 10 Commandments plaques are there because people purposely put them there as reminders of the ideals they thought the law should aspire to. Agree or disagree, it's history and tradition. (Or as G.K. Chesterton put it, "the democracy of the dead...[that] which refuses to submit itself to the small and arrogant oligarchy of men who simply happen to be walking about.") Just because some of us take offense at them does not mean we would be justified in ripping them out, any more than the Soviets were justified in airbrushing photos and erasing records, or the Spaniards were justified in burning the Aztec Codices, or the Taliban were justified in destroying the Bamiyan Buddhas. Those who forget the past, and all that...

P.S. I thought Scrappleface put it perfectly when they posted the disclaimer that SCOTUS mandated for the 10 Commandments: "Display of this historically-significant collection of laws shall not be construed as an endorsement of the God who may, or may not, have spoken them, nor of the existence of such a God, nor of the legality of the laws. Citizens may observe and obey these commandments at their own risk. Please consult your family attorney before embarking on any law-abiding regimen."
6.27.2005 6:32pm
Hip E. (mail) (www):
I agree with Mr. Volokh that avoiding religious divisiveness is not the job of the SCOTUS when making decisions in these cases. I also agree with everyone above who pointed out that it is the behavior of the governmental bodies that precipitated the divisiveness and not the courts' setting things right. Christians are in the majority in this country. Our founders could have easily made America the explicity Christian country that the Bushes, Falwells, and Roy Moores of the world wish it was. But they didn't. The reasons for this are obvious - that they had escaped from and were in violent opposition to the governments of old Europe and their mandated State Religions. The fact is that most Christians who advocate the "avert your gaze" solution would not be so excited about this advice if Muslims, Buddhists, or (God forbid) Scientologists were in the majority. The law is the law; it is given to us by the people who write it, and its authority derives from the consent of the people who obey it. Christians, Muslims, Jews, and all other citizens must be left alone to practice their religion as they see fit. The government cannot encourage Christians to become Muslims. The government cannot encourage Muslims to become Christian. And, most importantly to me, the government cannot encourage atheists to become religious. That's America.

As for the "remembering history" argument, I would point out that it depends on who gets to write the history. Many on the right want citizens to know that the Founding Fathers were all devout evangelical Christians. However, I don't think this is true.
6.27.2005 8:11pm
A2 Reader:

It is not a question of hurt feelings, it is a question of triumphalism/legitimacy.

The non-Commandments crowd objects substantively to the posting of the Commandments, in part because the very message of their posting is "We own this space", with the implied "You do not."

If I can invoke an example from Northern Ireland (a subject of which I have only newspaper level knowledge, so forgive the specifics, if the contours are accurate), during marching season, royalist socieities wear orange and seek to march through republican neighborhoods to commemorate 17th century victories. Much tumult ensues. Why? Because the republican's rightly interpret the message of the march..."It is our country. We can march down 'your' streets and celebrate a victory against your predecessors. You do not belong."

This is, I believe, a reasonable interpretation of Commandment posting -- an attempt to occupy the public sphere for the God of Christians (and others technically, but let's be real). The division comes not from the Court's response, but from the message behind the action in the first place.
6.27.2005 9:22pm
Michael McCulley:
I think most Americans actually favor the strict separation of church and state -- they just don't know it yet. Wait until a majority-Muslim city council erects a granite monument with passages from the Qu'ran (which could be justified as a tribute to the religious traditions of the local immigrant community), or an Islamic non-profit receives a grant from a faith-based government services program. When that happens, Christian America will acquire a whole new appreciation for the ACLU.
6.27.2005 9:39pm
Jon H (mail):
Thief writes: "Those 10 Commandments plaques are there because people purposely put them there as reminders of the ideals they thought the law should aspire to. "

Actually, the big stone monuments, like the one in the Texas case today, were placed as a publicity stunt to promote the movie "The Ten Commandments".
6.28.2005 12:01am
Jon H (mail):

I'll second "A2 Reader"'s statement.

Much of the time, posting 10 Commandments monuments seems like marking territory.

Note that they never seem to want to post the golden rule, or anything from the New Testament. It's always got to be the 10 Commandments, which includes "thou shalt have no other God before me".
6.28.2005 12:04am