New Doe Child #1 v. United States, No. 16-4440 (8th Cir. 2018)Annotate this Case
Plaintiffs challenged the inscription of the national motto, "In God We Trust," on United States coins and currency. The Eighth Circuit affirmed the district court's grant of the Government's motion to dismiss based on failure to state a claim. The court joined its sister circuits and held that placing "In God We Trust" on U.S. coins and currency does not violate the Establishment Clause. In light of the Supreme Court's recent precedent in Town of Greece v. Galloway, 134 S. Ct. 1811 (2014), the court held that the long tradition of placing "In God We Trust" on U.S. money comports with the original understanding of the Establishment Clause. The court also held that plaintiffs failed to state a claim under the Free Speech Clause because the Government's inscription did not compel plaintiffs to express any message. Furthermore, plaintiffs' First Amendment rights under the Free Exercise Clause and statutory rights under Religious Freedom Restoration Act were not violated. Finally, plaintiffs' equal protection claim failed because the statutes requiring the inscription did not create any express or implied classifications and was rationally related to the Government's legitimate goal of honoring religion's role in American life and in the protection of American fundamental rights.