In any lawsuit, the plaintiffs have to let the Court and the defendants know who they are and why they should be allowed have their grievances heard in court. Thus, in this case (challenging “In God We Trust” on United States money) each plaintiff needs to provide a personal statement.
The key word here is “personal.” It should start with basic information that identifies you personally, followed by a concise account of ways in which “In God We Trust” on the motto injures you personally (and directly). Prose referring to broad notions of injustice, or that merely says that you feel the government is violating the law, are NOT to be included. Remember, we only want information that applies to you personally and directly.
This is not to say that your personal injury needs to be unique. On the contrary, I expect that many of you will be suffering many of the same harms, which is fine. However, the injuries you are detailing need to be those that are personal and direct to you.
The example I often give is to imagine that Congress decided to mandate that the Treasury use plutonium in manufacturing the nation’s coins, and everyone who handled the money suffered radiation burns. You might make two claims about this: (1) It offends you to know that the United States government is producing radioactive coins that burn people’s hands, and (2) YOUR hands have suffered radiation burns. Although both statements likely apply to almost everyone, only the second is a personal and direct injury. Your merely being offended by governmental conduct does NOT constitute a personal and direct injury, and should NOT be included in your statement.
I bring this up because past plaintiffs have repeatedly provided statements that include matters that are not direct and personal. This requires Julie Woodward (my incredible coworker, who has already invested a huge numbers of hours in moving this case forward) and me to spend a lot of time filtering out those irrelevant (for legal complaint purposes) claims. Yes, it ticks you off that “In God We Trust” is on the money, which is unlawful (and unconstitutional). That is the entire point of the lawsuit, which I will be explaining to the various judges as we proceed. For the purposes of a plaintiff’s statement, however, that annoyance or anger has no relevance because such generalized feelings are not considered direct and personal injuries. You need to show PERSONAL and DIRECT harms.
The following is a template to help guide you. Note that it has the following components:
- A mention of how you are related to the state(s) in your judicial circuit. Most commonly, you will simply note your residency. If not a resident, please note how you come to associate with currency in the involved state(s). For instance, you may own a business in Iowa, visit family in Georgia, shop in Rhode Island, etc.
- Relevant organizational affiliations, especially affiliations with any of the organizations that are plaintiffs in these cases.
- A short description of your religious persuasion.
- A sentence indicating that you are unwillingly confronted with the “In God We Trust” inscriptions (assuming, of course, that this is true). [The courts have generally agreed that being unwillingly confronted by the government with “offensive” religious statements gives rise to standing.]
- The foregoing should be followed by a concise review of the harms you have suffered. If you simply choose from among those listed in the following template, that will be fine. If you wish to add others that are not included, great. But, again, keep in mind that being upset or angry because the government is acting improperly IS NOT A DIRECT AND PERSONAL HARM, and including such prose will only waste time – yours and ours – as we send emails back and forth to develop a mutually-acceptable personal statement. (Please remember there are more than 250 of you!)
Anna Anaxagoras is a resident of North Carolina who also has an apartment in South Carolina. In both locations she frequently handles United States currency. She is a member (and treasurer) of North Carolina Nonbelievers.
Anaxagoras is an Atheist. Accordingly, she definitely does not trust in any God. Thus, when using United States currency, she is unwillingly confronted with the governmentally-mandated “In God We Trust” phrase. This substantially burdens her in the exercise of her religion in a number of ways. First, she is essentially forced to choose between either relinquishing the convenience of carrying the nation’s money, or bearing on her person a religious message that is the complete antithesis of her Atheistic beliefs. Second, exercise of her Atheism requires that she maintain honesty, and it is absolutely dishonest for her to carry the false message that “We” (i.e., Americans, of which she is one) trust in God. Finally, by passing American money to others (at times during foreign travel), she is proselytizing for a religious notion (i.e., Monotheism) that she finds false. Such proselytizing is absolutely forbidden in the exercise of her Atheism.
Anaxagoras is also a numismatist who has collected United States coins. The “In God We Trust” verbiage markedly diminishes the pleasure she would otherwise have engaging in this hobby and investment. Not only does she have to unwillingly confront this phrase when she handles her collection, but she is frequently unwillingly confronted with that religious verbiage when reviewing the mailings, etc., sent by the United States Treasury as it advertises its numismatic offerings.
Anaxagoras is a teacher who has, at times, taught the mathematics of coins and currency to elementary school children. With “In God We Trust” on each monetary instrument, she is personally placed in the uncomfortable position of being complicit in the teaching of a religious statement to her students. Because Defendants’ decisions to inscribe those words on the money essentially force her to carry the message “In God We Trust” (and, at least passively, to convey that message to the students she teaches), Anaxagoras is unable to practice her Atheism free from governmental interference.
Finally, Anaxagoras suffers alienation as she is constantly reminded that – solely on the basis of her sincerely-held religious views – she is an outsider in her own country. She has personally lost job opportunities and been excluded from social events due in no small part to the pervasive governmental message of denigration for Atheists.
Parents may want to add something like the following to their statements:
Plaintiff New Doe #1 is the parent of two minor children. As such, she wishes to raise those children to question the existence of any God. Defendants’ placement of “In God We Trust” on the coins and currency – which uses the power and prestige of the federal government to say, essentially, that Americans do not question God’s existence – interferes with Plaintiff New Doe #1’s parental decisions in this regard and undermines her parental role in rearing her children in a manner consistent with her family’s religious values. In fact, Plaintiff New Doe #1 has felt obligated at times to have her children avoid even discussing this matter in school in order to protect them from the adverse consequences that might result from their voicing Atheistic views. In these ways and others, Defendants’ actions substantially burden Plaintiff New Doe #1’s ability to exercise her religion.
For the children in this case (who have their own religious freedom rights), the following might be included:
Plaintiffs New Doe Child #1a and New Doe Child #1b are minor children being raised by Plaintiff New Doe #1. They have had, continue to have, and will in the future have regular and frequent contacts with the nation’s money. When they are confronted with “In God We Trust” on every coin and currency bill they handle or learn about in school, the power and prestige of the federal government is brought to bear upon them with the message that their mother’s (and their own) Atheism is false. Additionally, they are taught to carry and promote a religious message their mother is teaching them to at least consider denying, and to also make a completely false declaration as to what is likely to be their own religious view on the matter of God’s existence. Moreover, they suffer alienation and other harms as they find that, solely on the basis of sincere religious beliefs, their family exists as a collection of outsiders in their own homeland. In fact, on more than one occasion, Plaintiff New Doe Child #1a has been verbally assaulted in the public schools for voicing his criticisms and noting his discomfort that results from handling money that states “In God We Trust.”
The following should guide Organizational Plaintiffs:
Plaintiff No More IGWT Atheists (NMIA) is an association of Atheists, Agnostics, Freethinkers, Humanists, and Skeptics established as a 501(c)(3) educational group on July 4, 1776. Located in Philadelphia, NMIA works to ensure equality for all religious belief systems by advocating for the separation of church and state. NMIA has members in eight states. As a “person,” NMIA is aggrieved by the presence of the purely religious words “In God We Trust” on the nation’s coins and currency bills.
In addition to the plaintiff members already listed in this Complaint, NMIA has other members who live in and have children in this judicial district. Those individuals also confront the offensive phrase with regularity and frequency when they, too, handle money. Accordingly, those other members suffer the same or similar harms as alleged elsewhere in this Complaint.