Investigated
Can city councils legally exclude Satanic invocations from public meetings?Source
City council invocation rules let officials invite friendly faiths but exclude Satanic speakers, critics say.
Oct 9, 2026
Image: reuters.com
The Story
The strongest judicially reported account is that exclusion is not automatically unlawful, but legality turns on the council’s actual practice and rationale. In Boston, the First Circuit upheld the city’s position because the Temple did not show intentional religious discrimination and the council’s invitations were described as discretionary and relationship-based. That holding is not a blanket authorization for viewpoint-based exclusion everywhere.
- The First Circuit upheld Boston’s refusal to invite the Satanic Temple after finding insufficient evidence that invitations were selected through intentional religious discrimination.
- Boston councilors were described as having full discretion over invitees, with invitations commonly tied to personal relationships or a speaker’s local work.
- The Boston decision does not establish that councils may categorically exclude Satanic speakers; its reasoning turned on the evidentiary record and the city’s described practice.
Deeper Insight
The Satanic Temple’s legal position is that a council’s invocation practice can function as a religious forum that favors approved or familiar faiths while excluding an unpopular non-theistic religion. Its appellate brief argued that Boston’s custom controlled prayer, proselytized, and excluded out-groups. These are litigant arguments rather than findings adopted by the First Circuit, but they identify the central constitutional objection.
- The Satanic Temple argued that Boston’s prayer custom controlled the content and participants in invocations while excluding dissenting or unpopular religious viewpoints.
- The Temple contended that requiring an invocation to be acceptable or palatable burdens unconventional beliefs and enables viewpoint discrimination.
- The Chicago complaint similarly presents refusal to allow a Satanic Temple minister to give an invocation as a First Amendment violation, although the court denied preliminary injunctive relief.
Sources · 8
Featured · Primary source · storage.courtlistener.com
storage.courtlistener.com
1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION THE SATANIC TEMPLE, INC., and ADAM VAVRICK, Plaintiffs, v. THE CITY OF CHICAGO, Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 23 C 2780 Judge Joan H. Lefkow OPINION AND ORDER In this lawsuit, The Satanic Temple, I
Read sourceAnalysis · exa.ai
Satanic Temple v. Scottsdale, City of (trial court document), District Court, D. Arizona, 2020
# Satanic Temple v. Scottsdale, City of (trial court document), District Court, D. Arizona, 2020 Court: District Court, D. Arizona Date: 2020-02-06 Docket number: 2:18-cv-00621 Opinion type: trial court document Precedential status: Unknown --- 1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FO
Read sourcePrimary source · ca1.uscourts.gov
United States Court of Appeals
## United States Court of Appeals ### For the First Circuit No. 23-1642 THE SATANIC TEMPLE, INC., Plaintiff, Appellant, v. CITY OF BOSTON, Defendant, Appellee. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Angel Kelley, U.S. District Judge] Before Barron, Chief
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