Mrs.

Ruhlin Goes to Washington: Louise Ruhlin, School Prayer, and the Possibilities and Limitations of Religious Political Lobbying in Modern America
Aaron L. Haberman One day in the late 1960s, a housewife from Cuyahoga Falls, Ohio, named Louise Ruhlin had what she considered a disturbing conversation with her youngest son after he returned home from school. Her son asked why do we park God outside of school, by which he meant the absence of organized prayer or other forms of religious observance in his school. When she asked him why he felt this way, he responded that he had learned in school that the separation of church and state mandated it. Unnerved by his comments, Ruhlin told her son that she would look into it, but he responded that she would just be like other adults and forget about the matter. His sentiments struck a nerve and Ruhlin decided to launch a campaign to restore voluntary prayer to public schools.1 Over the next few years Ruhlin recruited associates from around the country to pressure U.S. congressmen into supporting a constitutional amendment

AARON L. HABERMAN (BA, Washington and Lee University; MA, PhD, University of South Carolina) is a lecturer of history, University of Northern Colorado. He has published an article in The Historian. Special interests include modern conservatism, role of religion in politics, and constitutional history. This article is part of a larger project on school prayer and the political experience of the Christian Right to be published by the University of Virginia Press. The author gratefully acknowledges the following people for their suggestions, help, and advice during this project: Patrick Maney, Dan Carter, Lawrence Glickman, Laura Woliver, Eric Cheezum, Jacob Blosser, Keri Dunphy, the staffs of the Ohio Historical Society and the University of Akron Archival Service, and finally, Christopher Marsh, Pat Cornett, and the editorial team at the Journal of Church and State. 1. Martinsville Daily (VA), August 18, 1971.
Journal of Church and State vol. 51 no. 2, pages 289 311; doi:10.1093/jcs/csp039 Advance Access publication August 17, 2009 # The Author 2009. Published by Oxford University Press on behalf of the J. M. Dawson Institute of Church-State Studies. All rights reserved. For permissions, please e-mail: journals.permissions@oxfordjournals.org

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Journal of Church and State allowing public school prayer. Because of Ruhlins efforts, in the fall of 1971 the House of Representatives debated and voted on a proposed school prayer amendment. The vote ultimately fell short of the required two-thirds majority needed to pass a constitutional amendment. Nevertheless, Ruhlins efforts signaled the beginning of a much larger conservative grassroots religious movement that would transform the United States during the 1970s. Louise Ruhlins crusade for a school prayer amendment occurred at time of great flux in the American political system. As has been well documented by other scholars, the 1970s witnessed the beginning of a right turn in American politics in which various conservative movements took control of the Republican Party and helped elect Ronald Reagan to the presidency in 1980. One of the key groups in this conservative political ascendance was Americas conservative Christians. Fearing for the moral future of the United States because of the perceived excesses of the 1960s as well as Supreme Court decisions that had banned school prayer and made abortion legal, many previously apolitical evangelical and fundamentalist Christians began in the late 1970s to join newly formed religious political organizations, including, most notably, the Moral Majority led by the Reverend Jerry Falwell. A substantial body of historical, sociological, and political science literature exists on the rise of politically active conservative Christians.2
2. See William Martin, With God on Our Side: The Rise of the Religious Right in America (New York: Broadway Books, 1996); Michael Lienesch, Redeeming America: Piety and Politics in the New Christian Right (Chapel Hill: University of North Carolina Press, 1993); Jerome Himmelstein, To the Right: The Transformation of American Conservatism (Berkeley: University of California Press, 1990); Allen Hertzke, Representing God in Washington: The Role of Religious Lobbies in the American Polity (Knoxville: University of Tennessee Press, 1988); Walter Capps, The New Religious Right: Piety, Patriotism, and Politics (Columbia: University of South Carolina Press, 1990); Justin Watson, The Christian Coalition: The Dreams of Restoration, Demands for Recognition (New York: St. Martins Press, 1997); D. G. Hart, That Old Time Religion in Modern America: Evangelical Protestantism in the Twentieth Century (Chicago: Ivan R. Dee, 2002); Mark J. Rozell and Clyde Wilcox, Second Coming: The New Christian Right in Virginia Politics (Baltimore: Johns Hopkins University Press, 1996); Clyde Wilcox, Onward Christian Soldiers? The Religious Right in American Politics (Boulder: Westview Press, 1996); Steve Bruce, The Rise and Fall of the New Christian Right: Conservative Protestant Politics in America, 1978 1988 (Oxford: Clarendon Press, 1988); Garry Wills, Under God: Religion and American Politics (New York: Simon and Schuster, 1990); Mathew C. Moen, The Transformation of the Christian Right (Tuscaloosa: University of Alabama Press, 1992); Geoffrey Layman, The Great Divide: Religious and Cultural Conflict in American Party Politics (New York: Columbia University Press, 2001); Duane Murray Oldfield, The Right and the Righteous: The Christian Right Confronts the Republican Party (Lanham: Rowman & Littlefield Publishers, Inc., 1996); Matthew Lassiter, Inventing Family Values, Paul Boyer, The Evangelical Resurgence in 1970s

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Mrs. Ruhlin Goes to Washington This scholarship has effectively explored many facets of the so-called Christian Rights political experience from a close analysis of its political beliefs, to its rise to prominence within the Republican Party, to its impact on political campaign rhetoric and electoral results. More recently, scholars have shifted their focus to grassroots conservative Christian organizations with a special emphasis on the role women played in these movements. As historian Donald Critchlow argues, during the 1970s social issues like abortion, school prayer, and the Equal Rights Amendment (ERA) captured the attention of many conservative Christian women like Ruhlin and mobilized them to become involved in politics on a grassroots level, which ultimately activated a disheartened conservative movement and laid the foundation for the election of Ronald Reagan in 1980.3 Louise Ruhlins story, which for the most part has been largely untold by scholars, offers a useful case study of a grassroots religious political organization that sheds light on the rise of conservative Christian women as active political participants in modern America. Significantly, in pursuing a school prayer amendment Ruhlin did not attempt to use her foray into lobbying as a steppingstone for greater personal political power or influence. She seemed to care only about the issue itself and preserving what she believed to be traditional American family values. She showed no interest in increasing her personal public profile. Indeed, whenever she issued press releases, took out ads in various newspapers in support of school prayer, or contributed quotes to articles about her movement, her name always appeared as Mrs. Ben Ruhlin. In this sense, Ruhlin differed significantly from Phyllis Schlafly, the future leader of a national campaign against the ratification of the ERA and the most prominent and successful female conservative activist

American Protestantism, and Joseph Crespino, Civil Rights and the Religious Right, all in Rightward Bound: Making America Conservative in the 1970s, ed. Bruce J. Schulman and Julian Zelizer (Cambridge: Harvard University Press, 2008). 3. Donald Critchlow, Mobilizing Women: The Social Issues, in The Reagan Presidency: Pragmatic Conservatism & Its Legacies, ed. W. Elliot Brownlee and Hugh Davis Graham (Lawrence: University Press of Kansas, 2003), 293 94. For other works on grassroots conservatism and the rise of conservative Christian women activists see Lisa McGirr, Suburban Warriors: The Origins of the New American Right (Princeton: Princeton University Press, 2001); Donald Critchlow, Phyllis Schlafly and Grassroots Conservatism: A Womans Crusade (Princeton: Princeton University Press, 2005); Catherine Rymph, Republican Women: Feminism and Conservatism From Suffrage Through the Rise of the New Right (Chapel Hill: University of North Carolina Press, 2006); Marjorie Spruill, Gender and Americas Right Turn, in Rightward Bound, ed. Schulman and Zelizer, 71 89.

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Journal of Church and State of the 1970s. Schlafly, a longtime Republican leader who had achieved a national reputation in the 1960s through a series of bestselling books and her work on behalf of Barry Goldwaters presidential campaign in 1964, had strong connections with GOP leadership. When she began her quest to defeat the ERA she was able to draw on a large national network of support. According to her biographer Donald Critchlow, Schlafly represented a conduit between the intellectual conservative elite and the grassroots. Ruhlin, on the other hand, was the grassroots. She did not have an established network of supporters around the country or any kind of following outside of her local area when she first launched her grassroots campaign. Ruhlins story also raises important questions about the possibilities and limitations of religious-based political lobbying in modern America. She succeeded at forming a large national movement of religious women who saw the barring of prayer in public schools as a telltale sign pointing toward Americas moral decline. Ruhlin and her associates came close to getting the House of Representatives to pass a school prayer amendment while other conservative Christian activists, male and female, helped stop the ratification of the ERA and overturned gay rights legislation in Florida. Most importantly, these policy efforts mobilized conservative Christians politically and made them active members of the Republican Party, contributing to key GOP victories from 1980 through 2004. Despite these successes, however, conservative Christians largely fell short in advancing most of their national public policy agenda, including repeatedly failing to secure federal legislation to ban abortion and pornography, or reinstating school prayer. As will be shown, Ruhlins failure to secure a prayer amendment in 1971 signaled (though neither she nor other conservative Christians at the time were aware of it) an emerging secularization of American politics where overt religious/moral values would have a limited influence on federal public policy.4 Thus, paradoxically, beginning in the
4. The use of the term secular to describe the condition of the modern American political system under which the Christian Right has operated, is not intended to suggestas social theorists like Max Weber once dida total absence of religious ideology from the public sphere or a lack of religious influence within the political arena. Rather, the secularization of modern American politics should be understood as a process in which political values and debate, once shaped directly by interpretations of religious text, are now infused and merged with nonreligious ideas of constitutional interpretation and notions of civil rights. In other words, whereas American lawmakers in the nineteenth century and early-twentieth century often argued for some policies in terms of Gods will, much fewer policy debates todayeven on cultural issues, including school prayer, abortion, pornography, and intelligent designrely on, or revolve around, overt religious ideology. For good studies on the religious

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Mrs. Ruhlin Goes to Washington 1970s and carrying through into the twenty-first century, one element of politics ( public policy) became more secularized and arguably more liberal while key parts of the electorate and broader American political culture moved to the right.5 Controversy surrounding prayer in public schools has been a part of the United States since the founding. During the early-nineteenth century, Protestant denominational leaders argued about whose prayers should be used in schools. The infusion of Irish Catholic immigrants in the mid-1800s provoked local school board clashes over attempts to require the reading of biblical passages from the Protestant King James Bible or the employment of Protestant versions of the Lords Prayer. In the 1840s, for example, reports circulated in Philadelphia of teachers beating Catholic students who refused to read from the King James Bible. At times, even, these conflicts boiled over into riots.6 Eventually these matters moved to the courts, and throughout the late nineteenth and early twentieth centuries local and state courts weighed in on questions of whether public officials could mandate school prayers and which prayers would not violate individual students rights. In general, however, the courts and most Americans accepted or desired the presence of religion in schools, provided that Catholic or other minority faith students could opt out of any religious exercise that offended them.7 This trend changed dramatically with the 1962 case Engel v. Vitale, in which the Supreme Court prohibited state sponsored organized vocal prayer in public schools, arguing that it violated the constitutions First Amendment prohibition on government established religion. The decision, as well as the Courts subsequent ruling a year later in Abington School District v. Schemppwhich banned bible reading in public schoolsshocked conservative Christians and made them fearful for Americas future. Many conservative Christians interpreted the decisions as a direct challenge to Gods symbolic standing in America by a minority of cultural

influence on American politics in the nineteenth and twentieth centuries see for example, Richard Carwardine, Evangelicals and Politics in Antebellum America (New Haven: Yale University Press, 1993); Gaines Foster, Moral Reconstruction: Christian Lobbyists and the Federal Legislation of Morality, 1865 1920 (Chapel Hill: University of North Carolina Press, 2002). 5. Critchlow points out an element of this 1970s paradox in his biography of Phyllis Schlafly, though he deals specifically with the simultaneous rise of feminism and conservative female activists. According to Critchlow, the paradox of the decade was this: If this was the age of liberation, it was equally the age of reaction. See Critchlow, Phyllis Schlafly, 214. 6. Joan DelFattore, The Fourth R: Conflicts Over Religion in Americas Public Schools (New Haven: Yale University Press, 2004), 13 21, 32 46. 7. Ibid., 52 61.

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Journal of Church and State secularists. Presbyterian minister Edward Elson, for example, declared, [a] secular nation is not what we were at the beginning. Then we said it was God who gave us liberty, God who brought forth the nation, God who hath preserved us a nation. . . . We are a theistic people.8 If God were to be driven from the schools and other public spaces, Elson continued, we must find and soon find ways of involving the whole people in public symbolic acts attesting that we are a theistic people even though not a theocratic state.9 Conservative Christians have continually struggled to carry out Elsons decree. In the immediate years following the Engel and Abington decisions, there were two significant movements by Congress to pass a constitutional amendment restoring school prayer. New York Republican representative Frank Becker led the first movement. In 1964 he proposed an amendment that read: Nothing in this Constitution shall be deemed to prohibit the offering, reading from, or listening to prayers or biblical scriptures, if participation therein is on a voluntary basis, in any governmental or public school, institution or place.10 That same year he forced the House Judiciary Committee (where all proposed constitutional amendments in the House are first considered) to hold hearings on the matter. The hearings lasted eighteen days and included over 2,700 pages of testimony and submitted materials. Advocates on both sides of the issue testified, but in the end the Judiciary Committee never referred the proposed amendment to the full House for a vote.11 Two years later, the Senate took up school prayer. Republican Everett Dirksen of Illinois, the Senate Minority Leader, pushed his own proposed amendment, which read, Nothing contained in this Constitution shall prohibit the authority administering any school, school system, educational institution or other public building supported in whole or in part through the expenditure of public funds from providing for or permitting the voluntary participation by students or others in prayer. Nothing contained in this article shall authorize any such authority to prescribe the form or content of any prayer.12 Under his leadership
8. Bible and Prayer Ruling: A Signal to the Churches, Christianity Today 7:19 (1963), 27. 9. Ibid. 10. U.S. Congress, House of Representatives, Hearings before the Committee on the Judiciary, School Prayers (Washington, DC: U.S. Government Printing Office, 1964), 22. (Hereafter cited as School Prayer Hearings 1964). 11. DelFattore, The Fourth R, 126. 12. U.S. Congress, Senate, Hearings before the Subcommittee on constitutional amendments of the Committee on the Judiciary, School Prayers (Washington, DC: U.S. Government Printing Office, 1966), 1 (Hereafter cited as School Prayer Hearings 1966).

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Mrs. Ruhlin Goes to Washington the Senate Subcommittee on Constitutional Amendments of the Judiciary Committee held hearings, and eventually he brought it to a vote before the entire Senate. The vote, however, did not pass.13 In both the 1964 and 1966 hearings, school prayer advocates were partly undone by the nature of their arguments. In most cases, those in favor of the prayer amendment argued that the United States needed to affirm publicly its faith in God through school prayer, or risk losing its favored status in the world by incurring Gods wrath. School prayer advocates also contended that an overwhelming majority of Americans believed in God and therefore favored the amendment to reinstate majority rule over local school decisions to insure religious freedom. Opponents countered that the best way to protect religious freedom was by keeping government out of religious practice entirely. Many of these opponents included religious leaders from Catholicism, Judaism, and mainline Protestant churches, who worried that children of their faiths would be forced to say or listen to religious prayers that were not of their own denomination. The presence of religious leaders against the prayer amendment at the hearings suggested to many congressmen that conservative Christians who favored school prayer did not necessarily speak for the overwhelming majority of Americans. The continued opposition of religious leaders would stifle conservative Christians during all future debates over school prayer amendments.14 In 1967, a year after Dirksens prayer amendment failed to pass the Senate, the Illinois Senator submitted a new proposal which read: Nothing in this Constitution shall abridge the right of persons lawfully assembled in any public building which is supported in whole or in part through the expenditure of public funds, to participate in non-denominational prayer.15 Dirksen hoped to circumvent objections to earlier versions of the school prayer amendment by confronting the broader issue of religion in public buildings. Though this new amendment of course included public schools, it turned the issue into a debate over the rights of all people to engage in prayer virtually anywhere in the public sphere. The phrase non-denominational prayer, which Dirksen included ostensibly to assuage those who worried that their
13. DelFattore, The Fourth R, 135. 14. For a good summation of the pro prayer position see Reverend Gabriel Abdullah testimony during the 1964 hearings. School Prayer Hearings 1964, 1104. Opposition to the prayer amendment can be seen in the testimonies of C. Emanuel Carlson of the Baptist Joint Committee on Public Affairs and Rabbi Seymour J. Cohen of the Anshe Emet Synagogue in Chicago during the 1966 hearings. School Prayer Hearings 1966, 215 18, 489 94. 15. DelFattore, The Fourth R, 135.

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Journal of Church and State children would be forced to listen to, or partake in, the prayers of other denominations, presented some potential long-term problems. If the amendment passed and schools reinstituted prayers, the courts could still nullify many of these prayers by simply arguing that they were sectarian. Debates over the meaning of nondenominational prayer plagued the school prayer movement for years to come. In the meantime the Senate took no action on the proposal for the remainder of the term. At the start of the next congressional session in 1969 Dirksen teamed with Ohio Republican representative Chalmers Wylie to submit identical prayer amendments in both Houses of Congress. The proposals again went nowhere. In September 1969, Dirksen passed away and it appeared as though this issue would die with him.16 The issue might well have ended if Louise Ruhlin had not taken special interest in the matter following the conversation with her son over the absence of religious expression in public schools. The wife of Ben Ruhlin, the owner of a prominent local aluminum siding company, Louise was an active member of her local Church of Christ. For Ruhlin, like many Americans who favored school prayer, the issue was simple. They wanted their schools to reflect the values they believed lay at the heart of American identity by allowing students to engage in voluntary prayer. Moreover, they never got caught up in the policy debates over broader constitutional issues or the specific composition of school prayers. Ruhlin and her supporters just wanted school prayer. Such a determined and straightforward approach to the issue had both its advantages and disadvantages. On the one hand, this approach allowed Ruhlin to appeal to many everyday women and get them involved in the movement because they understood school prayer in similar terms. This large network of supporters applied enough political pressure to force the House of Representatives to debate a school prayer amendment in 1971. This approach, however, ignored the nature of congressional debate. For those deciding the fate of the bill did have to consider the exact wording of the amendment and its broader constitutional implications. Ruhlin and her supporters inability or unwillingness to accept and adjust to such political realities would ultimately doom any chance they had at securing the amendment. Such concerns, however, were not on Ruhlins mind when she first decided to pursue a school prayer amendment. Indeed, Ruhlins biggest challenge early on was that she was not a national figure
16. Congressional Quarterly Almanac, Volume XXVII, 92nd Congress, 1st Session. . . . 1971 (Washington, DC: Congressional Quarterly, 1971), 626. (Hereafter cited as Congressional Quarterly Almanac 1971).

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Mrs. Ruhlin Goes to Washington with an established grassroots political organization in place. Despite such long odds, Ruhlin began her school prayer crusade in the spring of 1970 by writing a letter to President Richard Nixon. She asked Nixon how could an education geared to make American students well rounded be without God at the center of our lives? She worried about the future generations of Americans if their lives lacked a strong religious foundation.17 Her letter soon appeared in the Cuyahoga Falls City Press with a note urging readers to write to the local superintendent of schools demanding a return of school prayer. Almost immediately letters began pouring into the superintendents office. A typical letter included one from a former schoolteacher who argued that student discipline declined greatly after prayer and Bible study disappeared from schools. She believed that a good strong belief in God, by whatever name he is called, and in His rewards and punishments, is a most necessary element in a childs education.18 In early summer 1970, with substantial local support in hand, Ruhlin sought to expand her movement. After contacting her representative, Republican William Ayres, she started taking out ads in major newspapers across the country, which included a coupon to be sent to the House Judiciary Committee calling for support of the Dirksen and Wylie amendments. Many people sent the coupons directly back to her, which she collected to present to the Judiciary Committee. The venture cost her close to six thousand dollars. Ruhlin claimed later that she personally received over a hundred thousand of these coupons and knew of at least six hundred thousand more which had been clipped and sent in by prayer supporters. Additionally she sent every congressman copies of her letter to Nixon.19 Emboldened by the initial response to her campaign, Ruhlin traveled to Washington and met with both James Eastland and Emanuel Celler, the respective Senate and House Judiciary Committee chairmen. She tried to convince them to report out the still pending Dirksen and Wylie prayer amendments. In Celler, Ruhlin met a formidable foe. He used his position as Judiciary Committee chairman to stymie earlier attempts at a prayer amendment in 1964.20 Any proposed constitutional
17. Cuyahoga Falls City Press, April 8, 1970. 18. Letter, Mrs. Virginia Stahl to Harold Wilson, June 1, 1970, Box 15, Folder 4, Mrs. Ben Ruhlins Prayer Campaign Committee Files, University of Akron Archival Services, Akron, Ohio. (Hereafter cited as MBRF, UAAS). 19. Congressional Quarterly Almanac 1971, 626; Philadelphia Inquirer, July 12, 1971; Chalmers Wylie Papers, Box 116, Folder 27, Ohio Historical Society, Columbus, Ohio (hereafter cited as CWP, OHS). 20. David E. Kyvig, Explicit and Authentic Acts: Amending the U.S. Constitution, 1776 1995 (Lawrence: University Press of Kansas, 1996), 383.

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Journal of Church and State amendment in either House of Congress must be referred to the respective Judiciary Committee where it is debated and voted on. If a majority of the Judiciary Committee votes in favor of the amendment then it is referred to the entire congressional body for debate and vote. As Judiciary chairman, Celler had the ability to keep the bill from ever being debated by his committee. He did this in 1964 when Frank Becker proposed his school prayer amendment. This forced Becker to seek a discharge petition to bypass the Judiciary Committee and have the amendment appear before the entire House. Only after it appeared that Becker might achieve the necessary votes for a discharge petition did Celler agree to the lengthy public hearings on the proposed amendment. Following the hearings the amendment never came to a vote before the Judiciary Committee and Becker failed to get the necessary signatures for discharge. In 1970 Celler repeated these stalling tactics with Wylies proposed amendment by burying the proposal in committee. In September 1970, a frustrated Ruhlin sent Celler a telegram demanding that he report the prayer amendment to the full House. Celler had been a longtime supporter of Israel, and Ruhlin knew this. In her telegram she threatened to start calling on the American people to see that Israel isnt kept free by American support.21 Beyond trying to intimidate Celler, Ruhlin made school prayer an issue in the 1970 congressional elections. A few weeks prior to Election Day, Ruhlin wrote to the Columbus Dispatch (Ohio) supporting Wylies re-election bid (despite the fact that Wylie represented a different district than Ruhlins) on the basis of his commitment to the prayer amendment and the time he personally took to meet with her organization.22 Other school prayer lobbying organizations followed a similar tact for the 1970 election. Similarly, another school prayer advocacy organization, the Maryland-based Citizens for Public Prayer, also used the issue in the 1970 campaign. They issued a press release on October 28, 1970, supporting the reelection of Lawrence Hogan from Marylands fifth district because he strongly supports the civil right of free school prayer. The press release noted how Hogans opponent, Royal Hart, had voted against a school prayer proposal before the Maryland legislature.23 The efforts of Ruhlin and the Citizens for Public Prayer paid off as both Wylie and Hogan won their reelection bids. Unfortunately for Ruhlin, however, her own congressman and
21. Telegram, Louise Ruhlin to Emanuel Celler, September 19, 1970, Box 5, Folder 15, MBRF, UAAS. 22. Letter, Louise Ruhlin to Columbus Dispatch, October 17, 1970, Box 116, Folder 27, CWS, OHS. 23. Press Release, Citizens for Public Prayer, October 28, 1970, Box 115, Folder 8, CWS, OHS.

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Mrs. Ruhlin Goes to Washington an avid supporter of public school prayer, William Ayres, suffered defeat to his Democratic challenger, John Seiberling, who openly opposed a school prayer amendment. Neither Ayress defeat nor the continued intransigence of Emanuel Celler deterred Ruhlin. Following Ayress advice, Ruhlin went to Wylie for help. Presenting him with over a hundred thousand petition signatures, she encouraged the Ohio representative to resubmit his proposed prayer amendment in the new Congress and press Celler to hold committee hearings. If this failed, Ruhlin wanted Wylie to file a discharge petition so that the amendment could bypass Cellers committee and come for a vote before the entire House. Ruhlin promised that she and her associates would work hard to lobby the required 218 congressmen to sign. Wylie approached Celler about the hearings, but the Judiciary Chairmen refused.24 Celler probably assumed that Wylie would never be able to muster the necessary signatures for discharge, and the matter would die. He did not, however, factor in the tenacity of Louise Ruhlin, who along with many other determined grassroots activists would spend countless hours asking, cajoling, and eventually threatening representatives until they agreed to support the amendment. On April 1, 1971, Wylie filed the discharge petition for his prayer amendment igniting Ruhlins campaign. The Ohio representative offered Ruhlin and some of her staff the use of his congressional offices to aid their cause. By this time Ruhlin had established a national movement known as the Prayer Campaign Committee (PCC). Her efforts caught the attention of a number of other organizations around the country that also strongly believed in school prayer. These groups included the American Legion, Veterans of Foreign Wars, the Back to God Movement, Citizens for Public Reverence, and the aforementioned Citizens for Public Prayer. Leaders from these various groups pledged to help Ruhlin by opening offices in Washington, DC, to begin the intense lobbying campaign. Throughout the next several months Ruhlin coordinated efforts with these and other groups. They met frequently, exchanged numerous letters and phone calls, and formulated a strategy to convince wavering congressmen to sign the discharge petition. Ruhlin believed that to win this battle she needed to recruit countless constituents to put relentless pressure on their representatives. The PCC and the other school prayer lobbying organizations had chapters throughout the country, making it possible for Ruhlin to instruct actual constituents on how to contact and lobby their
24. Congressional Quarterly Almanac 1971, 626.

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Journal of Church and State representative. The prayer groups generally drew these volunteers from, and coordinated their efforts through, local churches.25 Church bulletins kept congregations abreast of prayer amendment activities and generally encouraged members to take part in the effort.26 With numerous volunteers in place, Ruhlin and her staff made contact with every congressional office. In a form letter sent to each representative, Ruhlin presented the issue succinctly by describing how the secular forces of our society prohibit our public school children from acknowledging in prayer In God We Trust. She reminded the congressmen that both Houses of Congress opened their respective session with prayer and how the proposed amendment sought merely to protect that same right for school children.27 A number of congressmen had pledged to Ruhlin the previous year to sign the petition, which they did shortly after Wylie filed it. Those who appeared reluctant or outright refused to cooperate received phone calls or angry letters from their constituents. Between April and September 1971, Ruhlin worked feverishly on the prayer lobbying, dividing her time between visiting congressional offices herself and writing volunteers to ask them to pressure specific representatives. In a letter to a volunteer from Oklahoma, for example, Ruhlin listed five Oklahoma representatives who had not yet signed the discharge petition. She provided the addresses of the representatives Washington offices and urged the volunteer to get her friends and relatives to write their respective representative in support of the discharge petition. Ruhlin said that if these Representatives realize that their constituents know they have not signed this Discharge Petition, favoring prayer in the schools, they might get busy and sign it. She also sent along copies of the proposed amendment and a letter to the editor that Ruhlin had sent out to newspapers across the country, and suggested that they be used in the mailings to the congressmen.28 Ruhlin sent similar letters to volunteers throughout the country. Throughout the summer of 1971, the PCC came closer to the required 218 signatures, but the movement ran into several
25. For example, Celeste Osterle of Citizens for Public Reverence told Ruhlin that she had 947 women in her group that came from her local parish in Pittsburgh, Pennsylvania. See letter, Celeste Osterle to Louise Ruhlin, April 12, 1971, Box 3, Folder 6, MBRF, UAAS. 26. See, for example, The Bethany Letter, April 21, 1970, Box 4, Folder 2, MBRF, UAAS. 27. Prayer Campaign Congressional form letter, Box 16, Folder 4, MBRF, UAAS. 28. Letter, Louise Ruhlin to Reba (no last name included), May 24, 1971, Box 4, Folder 14, MBRF, UAAS.

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Mrs. Ruhlin Goes to Washington problems. The first concerned Celler, who by now saw the rising number of signatures and feared the discharge petition might succeed. To halt Ruhlins momentum, Celler sent every representative a copy of the transcripts from the prayer hearings in 1964 along with a note urging them not to sign the discharge petition. He argued that the House had given full weight to all the evidence and arguments regarding the prayer issue and could not find any way to restore school prayer without violating First Amendment rights to freedom of religion.29 Ruhlin objected to Cellers maneuvers and told the press that he was using taxpayers money to oppose us.30 Besides Celler, Ruhlin faced another problem. In her visits to the various congressional offices, several representatives expressed interest in the prayer amendment, but they did not like the idea of a discharge petition because they believed in the normal procedures of the House where bills had to go through the appropriate committees before coming to a full vote. The PCC had to be cautious in pressuring these traditional-minded representatives for fear they would lose their potential votes on the amendment should the discharge petition work. In the cases of reluctant representatives, all the prayer committee could do was thank them for their promised support but point out that if we wait for the two committees in the House and the Senate to take action, we may not be around.31 Ruhlin concentrated instead on the still undecided representatives, employing more aggressive tactics. Her associate, Mary Jane Sertel, for example, wrote to Florida Representative Dante Fascell trying to win over his support for the discharge petition by undermining Celler. Sertel made a veiled reference to a letter from
29. Letter, Emanuel Celler to Colleagues of the House of Representatives, July 20, 1971, Box 355, Prayer Amendment #2 Folder, The Papers of Emanuel Celler (hereafter cited as PEC), Library of Congress, Washington, DC (hereafter cited as LOC). Several congressmen responded to Cellers letter and the included copies of the 1964 committee hearings. William Hathaway, a representative from Maine, said that the hearings transcripts confirmed his continued opposition to the prayer amendment. See letter, William Hathaway to Emanuel Celler, July 20, 1971, Box 355, Prayer Amendment #2 Folder, PEC, LOC. David Dennis of Indiana, on the other hand, argued that there still needed to be additional hearings because there were few members of Congress still around from 1964 and that there was wide public support for the amendment. See letter, David Dennis to Emanuel Celler, July 21, 1971, Box 355, Prayer Amendment #1 Folder, PEC, LOC. Celler responded to Dennis arguing that many of the objections of religious leaders toward the prayer amendment remained unchanged since 1964 and that Celler himself worried about stirring up religious issues in these discordant times. See letter, Emanuel Celler to David Dennis, July 29, 1971, Box 355, Prayer Amendment #1 Folder, PEC, LOC. 30. Philadelphia Inquirer, July 12, 1971. 31. Letter, Celeste Osterle to Louise Ruhlin, June 25, 1971, Box 3, Folder 6, MBRF, UAAS.

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Journal of Church and State religious leaders circulating to congressmen in mid-September urging them to come out against the prayer amendment. Baptist, Episcopal, Lutheran, and Jewish leaders signed the letter.32 Sertel told Fascell that there [s]eems as if many are wondering how the Baptist vote could have been secured so quickly; there are mumblings of Zionismand other speculation which Im sure you must have heard, too.33 In other cases, the prayer campaign threatened the representative themselves. Robert Mauro, who headed the New Jersey Chapter of Citizens for Prayer, offered a veiled threat when he sarcastically told Cornelius Gallagher, a Democrat representing New Jerseys thirteenth district, that he was reluctant to write letters to the newspapers in the cities of the Thirteenth District attacking your failure to sign [the discharge petition], and to the church groups within said district favoring the prayer amendment. Mauro continued that he was also reluctant to seek primary candidates to run against you in the Thirteenth District until I hear from you as to whether you are going to sign.34 Ruhlin also engaged in hardball tactics. She recalled years later a confrontation with Fred Schwengel, a Republican representative from Iowa who came out strongly against the prayer amendment. He claimed that nobody in his district wanted prayer. Not believing him, Ruhlin tracked down a banker in Schwengels district who had donated to the PCC. The contributor turned out to be Schwengels banker, who was very upset and called the representative a liar.35 This confrontational tactic did not persuade Schwengel to support the prayer amendment, but it showed the lengths to which Ruhlin would go to get her way. Along these lines, Ruhlin began taking out advertisements in the home district newspapers of several congressmen, including John Rhodes of Arizona and Joe Evins of Tennessee indicating that they had not yet signed the discharge petition.36 Despite Schwengels and other representatives resistance, on September 21, 1971, the discharge petition received its 218th signature. The petition reflected true bi-partisanship with 111 Republicans and 107 Democrats signing on.37 Ruhlin had pulled off an improbable victory. It demonstrated that with enough determination and hard work, grassroots religious
32. For more on the religious leaders statement against the prayer amendment see Congressional Quarterly Almanac 1971, 627. 33. Letter, Mary Jane Sertel to Dante Fascell, September 18, 1971, Box 3, Folder 9, MBRF, UAAS. 34. Letter, Robert Mauro to Cornelius Gallagher, September 11, 1971, Box 3, Folder 5, MBRF, UAAS. 35. Akron Beacon Journal, February 1, 1976. 36. Phoenix Gazette, August 25, 1971; The Tennessean, August 21, 1971. 37. Congressional Quarterly Almanac 1971, 627.

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Mrs. Ruhlin Goes to Washington activists could directly influence congressional politics. Nevertheless, Ruhlin and her supporters had not yet achieved their goal. The full House still had to vote on the amendment. A discharge petition requires only a majority of the House to pass, while a constitutional amendment needs two-thirds. This supermajority requirement for constitutional amendments reflected the titanic challenge faced by prayer supporters because of the Engel and Schempp decisions. Whereas other interest groups needed general legislation to advance their interests, which required majorities of both Houses of Congress and a presidential signature, prayer advocates required a constitutional amendment to advance their policy goals. On several occasions from the 1960s to the 1980s, a school prayer amendment might have been achieved if only a simple majority was needed. Ruhlin, despite this weighty challenge, did not give up. She had already overcome the odds once, and she knew that several congressmen had pledged to support the amendment even though they had not signed the discharge petition. Moreover, with the issue now scheduled to come to a vote, congressmen could not avoid the issue and would have to cast a vote and face the potential consequences during election time a year later. The House of Representatives rules concerning discharged petitions slightly curbed the prayer movements momentum. A discharged petition had to wait a minimum of seven days before being presented to the entire House and it could only be considered on the second or fourth Monday of a month. The House holiday schedule negated any opportunity for it to be heard in October, pushing the date for its consideration back to November 8. This gave the opportunity for amendment opponents to rally support against the amendment. Celler understood that the key to the public relations battle on school prayer would involve marshalling religious leaders to oppose the amendment. Indeed, the presence of numerous Protestant, Catholic, and Jewish officials in the 1964 House prayer hearings had helped blunt the public demand for a school prayer amendment to reverse the Engel and Schempp decisions. As such, on October 4, Celler gathered numerous congressmen and religious clergy who opposed public school prayer for a press conference where they labeled Wylies amendment a very real threat to religious freedom.38 Cellers group also issued a press release arguing that the First Amendment already protected religious liberties that Wylies amendment suggested were under attack. Moreover, school prayer opponents expressed worry about Wylies call for non-denominational prayer which they felt was neither
38. Ibid.

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Journal of Church and State possible nor desirable for it would ultimately dilute the power of prayer. Ultimately, Cellers group asserted that they wanted to protect religious liberty, whereas to them Wylies amendment threatened it.39 Not to be outdone, Ruhlin and her allies did everything they could to exert maximum grassroots pressure on wavering congressmen. Wylie himself taped an interview for WEEI radio in Boston, Massachusetts making his case for the school prayer amendment. The congressman maintained that America needed the amendment because the Supreme Court had failed to clarify what sort of religious activities could be permitted in public facilities. In response to one caller, Wylie expanded his argument to include his belief that religion had a place in schools. He remarked: I think we should be guided throughout the day. This indicates to the young people that we are a democracy, which is founded on recognition of a Supreme Deity.40 The organization, Restore School Voluntary Prayer (RSVP), which had been active in the prayer battles of the 1960s, sent out a letter calling on its members to flood Washington with letters, urging our U.S. Congressmen to support VOLUNTARY, NON-DENOMINATIONAL SCHOOL PRAYER. The letter went on to blame the rise in crime, violence, and drug use in schools to the absence of prayer and advised supporters to work quietly (avoiding publicity which invariably brings out the opposition full force) and to put our trust in God who moves not only mountains but Senators and Representatives too!41 Ruhlin, for her part, directly challenged the religious leaders who had appeared with Celler on October 4. In a letter sent to every congressmen, she asserted that the majority of the people of the United States favor what we are proposing including the church members of the denominational leaders who have spoken in opposition to the non-denominational prayer amendment. She continued that the denominational leaders were only speaking for themselves and as such Congress needed to end the influence of the church associations that are tax free and imposing their will on government. America is only Great when we, the tax payers voices, are heard!42 Beyond writing to Congress, Ruhlin organized groups of constituents from fourteen different states to come to
39. Press Release, Congressmen and Clergy against Prayer Amendment, October 4, 1971, Box 355, Prayer Amendment #1 Folder, PEC, LOC. 40. Notes from Taped Interview, September 22, 1971, WEEI Radio, October 5, 1971, Box 117, Folder 3, CWP, OHS. 41. RSVP Newsletter, October 7, 1971, Box 2, Folder 5, MBRF, UAAS (emphasis in the original). 42. Letter, Louise Ruhlin to Congress, November 1, 1971, Box 116, Folder 27, CWP, OHS.

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Mrs. Ruhlin Goes to Washington Washington for concentrated lobbying of uncommitted target congressmen. She also made clear her intention of erecting billboards in congressmens home districts informing his/her constituents that they voted against the prayer amendment.43 With both sides determined and well organized, it appeared that the vote might go either way. A week before the House of Representatives met to debate the prayer amendment, Wylie agreed to answer a series of questions posed to him by Florida Democratic Congressman Sam Gibbons clarifying some aspects of the proposed amendment. One of Wylies answers would come back to haunt him during the House debate for it opened up the amendment to the charge of too much church-state interaction. In response to a question about who would have the power to compose school prayers, Wylie argued that local school authorities would be granted that authority. Local school authorities, of course, meant state employees, which could be interpreted by some as a form of state establishment of religion. Rather than allaying any fears that his amendment was a covert means of establishing religion, Wylie unwittingly further fueled his opposition.44 On November 8, both sides geared up for a long days debate and eventual vote. Emanuel Celler led the attack against the proposed amendment. He reminded his colleagues of the exhaustive treatment his Judiciary Committee gave the issue back in 1964 and its inability to craft suitable language that would allow for school prayer without infringing upon the rights of religious minorities. Celler asked, If 35 distinguished lawyers, after hundreds of hours of testimony could not write acceptable language, how can this House, in a scant 1 hour of debate do so?45 Hale Boggs, a Democrat from Louisiana, agreed with Celler. He pointed out the strong opposition offered by religious leaders and wondered how the Congress could vote against their clear desires. If the Protestant congregations, the Jewish congregations, and the Catholic congregations are opposed, Boggs stated, I do not believe, in the matter of prayer, which involves the most sacred thing in all these congregations, that we should presume to put our will ahead of all these expressions that we have had.46 Strong opposition also came from across the aisle. Fred Schwengel resisted Ruhlins heavyhanded tactics and attacked the amendments notion of voluntary prayer. Schwengel made reference to Wylies answer to the question
43. Wall Street Journal, November 8, 1971. 44. Letter, Chalmers Wylie to Sam Gibbons, November 1, 1971, Box 355, Prayer Amendment #1 Folder, PEC, LOC. 45. Congressional Record (November 8, 1971), 39886. 46. Ibid., 39888.

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Journal of Church and State about who would actually compose the prayer. Echoing prayer opponents from the 1960s debates, Schwengel rejected that any prayer imposed by officials representing the state could possibly be voluntary. He said, [h]istory records that people do not respond to compassion for religion by the State. The whole question must be left to the power of the Holy Spirit, the persuasion of love, and the dynamics of personal responsibility.47 Wylie and his allies, who included both Democrats and Republicans, drew on many of the previously used arguments advanced by prayer advocates in the 1960s. Wylie attacked the Engel decision for, among other things, placing the atheist and believer in a supreme deity in the same category in applying the first amendment. The result had been a wholesale violation of rights for religious Americans who could not even engage in voluntary group prayer.48 Robert Sikes, a Democrat from Florida, blamed atheists for creating this issue over school prayer in the first place. He wondered how his colleagues could answer to their constituencies after casting a vote against this amendment. To him, the rank and file of Americans know the importance of, appreciate, and want religion in their lives and in the schools.49 Others expressed concern about the countrys morality without foundational prayer as well as the belief that the American people demanded the amendment. William Scott, a Republican from Virginia, wondered if the lack of school prayer contributed to rise of disorder and permissiveness among young people.50 Prayer advocates would advance Scotts line of argument for many years to come. G. V. Montgomery, a Democrat from Mississippi, best captured the sentiments of Ruhlin and her supporters. After citing public opinion polls that showed 80 85 percent of Americans favored a school prayer amendment, he told his colleagues that [m]ost Americans are not interested in the arguments about whether or not the prayer amendment will change the bill of Rights or weaken the Constitution. What the American people are interested in is that the Supreme Court has restricted prayer in public schools and they do not like it one bit. Like Sikes before him, he cautioned his fellow representatives from going against the will of their constituents. A vote for the proposed amendment is going to be a lot easier to explain back home than a vote against it.51 Though Montgomery articulated the grassroots prayer advocates position well, neither he nor the other congressmen who favored the
47. 48. 49. 50. 51. Ibid., Ibid., Ibid., Ibid., Ibid., 39896. 39886. 39887. 39891. 39890.

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Mrs. Ruhlin Goes to Washington amendment could get around the general arguments regarding the clause calling for non-denominational prayer. This clause left the potential for the courts to nullify virtually any prayer by simply declaring it sectarian. Moreover, prayer opponents argued that a nondenominational prayer could not be composed. Sensing that his amendment might fail, Wylie allowed John Buchanan, a Republican from Alabama, to introduce a proposed amendment to H. J. Res 191, which would substitute voluntary prayer and meditation, for non-denominational.52 Interestingly, this made the language of the amendment similar to Dirksens proposal from 1966 (with the exception that it referred to public buildings supported by tax-payer dollars) that the Senate had failed to pass. Dirksen and subsequently Wylie had gone to nondenominational prayer to avoid the objections raised before; prayer advocates thus were right back where they started. Regardless of the language, prayer opponents still raised questions over who could compose these prayers and just how voluntary they really were. Buchanans amendment passed by a voice vote but it could not provide enough momentum to overcome the supermajority requirement for constitutional amendment passage. The final vote on Wylies amendment, 240168, fell twenty-eight votes short. Republicans cast 138 votes for the amendment with the Democrats contributing the other 102.53 The defeat did not stop Louise Ruhlin and her allies from continuing their pursuit of a school prayer amendment. In addition to trying to introduce another prayer amendment in Congress the next year, the PCC attempted to get enough state legislatures to pass resolutions calling for a constitutional convention to consider a prayer amendment (the other way dictated in Article V of the constitution for an amendment to be considered). Ruhlin also felt it necessary to purge those congressmen that had helped defeat Wylies amendment. Emanuel Celler topped her list. Ruhlin had heard rumors that Celler had hired a lobbyist named Stuart Johnson and placed him on the staff of California representative Don Edwards to lobby against the prayer amendment. She believed that Johnson was illegally employed at taxpayers expense.54 In April 1972, she wrote to Melvin Price, the chairman of the Committee on Standards of Official Conduct to present evidence against Celler and others about Johnsons employment.55 Nothing, however, came of the matter. Celler eventually suffered a surprising
52. Ibid., 39945. 53. Congress and the Nation 3:487, 29a. 54. Letter, Louise Ruhlin to Wayne Hays, December 21, 1971, Box 4, Folder 21, MBRF, UAAS. 55. Letter Louise Ruhlin to Melvin Price, April 12, 1971, Box 5, Folder 4, MBRF, UAAS.

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Journal of Church and State defeat in the primaries later that year ending his fifty-year reign in the House.56 Besides Celler, Ruhlin went after many of the other congressmen who had voted against the amendment by making good on her promise to lease billboards in particular congressional districts stating that the respective representative had voted against the prayer amendment. In all, she erected nearly seventy billboards, which she later claimed contributed to the defeat of at least ten congressmen in the 1972 election. Fred Schwengel was one of Ruhlins targets who lost his reelection bid. To her great dismay, John Seiberling, Ruhlins representative who had opposed the prayer amendment, triumphed in his election.57 Ruhlin continued to lobby Congress and state legislators over the next five years, but she could never generate the same kind of momentum for a prayer amendment as she had in 1971. Most congressmen who favored the bill had no desire to pursue another prayer amendment when it had already gone down to defeat after they had expended considerable effort on its behalf. The old issues of the exact wording of the amendment, as well as opposition from religious leaders still remained and looked to upend any future attempts to secure the amendment. Finally, after 1971 for the next several years school prayer did not represent the same kind of priority for many conservative Christians because new issues like abortion and the ERA soon emerged that took their full attention. Why did Ruhlin ultimately fail in her bid to secure a school prayer amendment, whereas a decade later Phyllis Schlafly and her STOP ERA organization denied final ratification of the ERA? There are several explanations. First, Ruhlin faced a much more difficult task than Schlafly because she was trying to get an amendment passed and thus had to secure supermajority support from Congress and the states. It took all of Ruhlins efforts to get a majority of the House of Representatives to vote for the discharge petition, which did not even guarantee that those congressmen would support the amendment when it came to a vote before the entire House. Indeed, twenty-nine congressmen (enough to have helped the amendment pass) who had signed the discharge petition either voted no or abstained. Some like Democrat Frank Brasco of New York claimed they had signed the discharge petition because they believed the bill deserved an up-and-down vote before the entire House, but that ultimately they did not believe in its merits.58
56. New York Times, June 21, 1972. 57. Iowa City Press Citizen, November 8, 1972; Akron Beacon Journal, February 1, 1976. 58. Congressional Record (November 8, 1971), 39940.

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Mrs. Ruhlin Goes to Washington Schlafly, on the other hand, merely had to prevent the requisite number of state legislatures from ratifying the ERA. In a sense she just needed to convince a simple majority of state legislators in a handful of states to vote against the ERA. This is not to understate the challenges that Schlafly had to overcome. By the time she began her quest against the ERA, the amendment had not only passed Congress but had almost been ratified by nearly three-fourths of the states. On the surface, ERA supporters had all the momentum and many considered it a done deal. As historian David Kyvig points out, however, most of the states that would have been expected to ratify the ERA had done so by the time Schlafly entered the fray. As such, she mostly had to convince more conservative state legislators who were probably already inclined to vote against it.59 Ruhlins aggressive tactics also account somewhat for her failure. To be sure, her dogged pursuit of congressional support secured many votes for the discharge petition, but her tenacity may also have lost her substantial support. As her congressmen, William Ayres, explained in a later interview, while Ruhlin was dedicated to her cause she was somewhat politically na ve as to how she could get members to jump at her every wish. He went on to explain that she probably alienated a lot of members of Congress who sort of felt she was wearing out her welcome. She thought each one should really get out and thats all he should be doing, just pushing her amendment. As we all know, they had a lot of other things to do as well.60 Here again we see substantial difference between Ruhlin and Schlafly. In lobbying state legislators to oppose the ERA, Schlafly instructed her followers to always act as polite and lady like as possible. These women often greeted legislators in modest dress and bearing baked goods. This demure approach reinforced the larger arguments of ERA opponents that they sought to preserve traditional values and gender roles against what they saw as a radical feminist agenda.61 Ruhlins hardball tactics, on the other hand, stood in stark relief to what she saw as a seemingly innocuous goal of reinstating the right of children to practice religious observances in schools. Finally, Ruhlin failed because the overtly religious nature of the arguments put forth by school prayer supporters went contrary to the emerging secular tide that was engulfing modern American politics. A critical dimension of this secularism was the continuing
59. Kyvig, Explicit and Authentic Acts, 408 09. 60. Oral History, William Ayres, September 13 and 21, 1978, Former Members of Congress, Oral History Project, LOC. 61. Critchlow, Phyllis Schlafly, 224 25.

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Journal of Church and State argument by religious leaders that the best way to protect religious liberty was by keeping it out of the hands of public officials. Indeed, Ruhlins ally in the amendment fight, Celeste Osterle, believed that the presence of religious leaders who came out against the amendment helped sway some votes from those who had signed the discharge petition.62 In arguing that secularism shaped political debate and policy outcomes not only in the 1971 prayer amendment battle, but throughout recent American history, it is not to say that the political system became devoid of religiosity. Indeed, the Republican Party came to dominate the presidency and the Congress from 1980 through 2004 in no small part because of the support they received from conservative Christians whose religious ideology had led them to align with the GOP. Nevertheless, when conservative Christians in the 1980s through the early 2000s pushed for their national policy agenda of ending abortion and pornography, and restoring school prayer, their overtly religious arguments (and even some of their secular arguments) carried little weight in the policy arena and their proposals mostly went down to defeat. But would not the example of the ERA suggest the success of conservative religious arguments in the policy arena? To be sure, Schlafly generated substantial grassroots support by making dire predictions about the future of morality in the country should the ERA pass, arguing that it would eradicate all legal distinctions between the sexes. But she also employed largely secular arguments to tap into a growing anti-statist sentiment that was sweeping the nation during the 1970s. Schlafly repeatedly argued that the ERA represented a huge power-grab on part of the federal government. This convinced many people who might otherwise have had no objection to the ERA on moral grounds, to come out against it. Conservative Christians had a more difficult time of framing school prayer and other important social issues their arguments in convincing secular terms that could move the strong majority of the American public and ultimately Congress.63 The question remains, however, whether the public policy side of American politics will ever include religious ideas like it did for most of American history prior to the 1960s. This has an important bearing on the Christian Rights chances to fulfill some of its original agenda of returning prayer to schools and overturning Roe v. Wade. If Louise Ruhlins struggle for a school prayer amendment serves as an indication, any future success on the issue will require
62. Letter, Celeste Osterle to Louise Ruhlin, December 5, 1971, Box 3, Folder 6, MBRF, UAAS. 63. For an example of this argument see, Phyllis Schlafly, Section 2 of the Equal Rights Amendment, Phyllis Schlafly Report, May 1973.

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Mrs. Ruhlin Goes to Washington either a dramatic reversal in church-state jurisprudence by the Supreme Court or a significant change in the nature of the American populace. Of the two possibilities, a reversal by the Supreme Court is more likely because of the ascendance of conservatives John Roberts and Samuel Alito to the Court in previous years. It remains to be seen the extent to which their conservatism is of a religious nature and whether they can tip the balance of the Court toward greater church-state interaction. Far less likely is a dramatic shift in the American polity away from secularism. As early as the 1960s, religious groups differed on school prayer as well as the broader issues of church-state separation. In the years since the passage of the 1965 Immigration Act, Americas religious diversity has grown substantially, making the chances of a consensus among these groups highly remote.64 It might well be that conservative Christians, like other political interest groups, will have to choose their battles carefully, biding time on some issues until the right political environment emerges. For school prayer, conservative Christians may have a long wait.

64. Diana L. Eck, The Multireligious Public Square, in One Nation Under God?, ed. Marjorie Garber and Rebecca L. Walkowitz (New York: Routledge, 1999), 1 5.

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