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    UNITED STATES COURT OF APPEALS

    FOR THE NINTH CIRCUIT

    PATRICIA E. GENTALA and
    ROBERT A. GENTALA,
                                                         Nos. 97-17062
    Plaintiffs-Appellants-
                                                         97-17069
    Cross-Appellees,
                                                         D.C. No.
    v.                                                    CV-97-00327-FRZ
    THE CITY OF TUCSON,
                                                         OPINION
    Defendant-Appellee-
    Cross-Appellant.

    Appeal from the United States District Court
    for the District of Arizona
    Frank R. Zapata, District Judge, Presiding

    Argued and Submitted En Banc
    September 19, 2000--San Francisco, California

    Filed March 30, 2001

    Before: Mary M. Schroeder, Chief Judge,
    Ferdinand F. Fernandez, Thomas G. Nelson,
    Andrew J. Kleinfeld, Barry G. Silverman, Susan P. Graber,
    M. Margaret McKeown, Kim McLane Wardlaw,
    William A. Fletcher, Ronald M. Gould, and
    Marsha S. Berzon, Circuit Judges.

    Opinion by Judge Berzon;
    Dissent by Judge Fernandez;
    Dissent by Judge Kleinfeld

                                   3999

    COUNSEL

    Kevin H. Theriot, Lawrenceville, Georgia, for the plaintiffs-
    appellants-cross-appellees.

    Merle Turchik, Deputy City Attorney, Tucson, Arizona, for
    the defendant-appellee-cross-appellant.

    _________________________________________________________________

    OPINION

    BERZON, Circuit Judge:

    The pivotal question in this case is whether a city may,
    using tax funds and public employees, provide stage lighting,
    sound, and other special-event services for a sectarian reli-
    gious organization's prayer service held in the bandshell of a
    public park. The City of Tucson believed that to do so would
    violate the Establishment Clause of the First Amendment. For
    that reason, although Tucson, through its Civic Events Fund
    ("Fund"), does provide such support to certain events held in
    public parks, Tucson declined the National Day of Prayer
    Committee's request that it provide the equipment and ser-
    vices for its National Day of Prayer gathering. We agree with
    Tucson that although the Establishment Clause remains a
    "blurred, indistinct and variable barrier" to government sup-

                                   4004
    port for religious activity, Lemon v. Kurtzman , 403 U.S. 602,
    614 (1971), "the circumstances of [the] particular relation-
    ship," id., between Tucson and recipients of Civic Events
    Fund support is such that Tucson was correct in concluding
    that the requested funding would have fallen on the Establish-
    ment Clause side of that "serpentine" wall. McCollum v.
    Board of Educ., 333 U.S. 203, 238 (1948) (Jackson, J., con-
    curring). Tucson's decision to refuse Civic Events Fund sup-
    port to the prayer service's organizers therefore did not run
    afoul of another First Amendment proscription, against
    abridging freedom of speech.

    Background

    I. The Tucson National Day of Prayer Gathering

    The Tucson National Day of Prayer Committee ("Prayer
    Committee") is an organization that, according to its funding
    application to the City, requires its members to "pledge [a]
    specific religious belief," namely, Christian, and terminates
    the membership of any member who does not do so. 1 In the
    spring of 1997, the Prayer Committee organized a National
    Day of Prayer gathering described in that application as "an
    _________________________________________________________________
    1 It is worth noting at the outset that this case does not concern the con-
    stitutionality of the Congressionally-established National Day of Prayer.
    Congress first proclaimed such an annual "day " in 1952, as it has issued
    innumerable other resolutions proclaiming national "days." See generally
    36 U.S.C. SS 101-143. It does not appear that there is any federal govern-
    ment funding or support for any National Day of Prayer events; the
    National Day of Prayer Task Force that promotes participation in the event
    is a private, nonprofit organization. Nor is the National Day of Prayer in
    any respect sectarian (although its very point is to favor religion over non-
    religion). The original congressional resolution, Pub. L. No. 82-324
    (1952), the 1988 amendment fixing the first Thursday in May as the
    National Day of Prayer, Pub. L. No. 100-307 (1988), codified at 36 U.S.C.
    S 119, and the Task Force all stress that the Day is meant as an opportu-
    nity for all Americans who wish to do so to pray according to their own
    faith, not to promote any particular religion or form of religious obser-
    vance.

                                   4005
    annual gathering of Tucson Christians." As planned and as
    carried out, the event, open to the public, involved "a time of
    prayer and worship" led by "[p]astors from nine different
    churches," and two choirs. More than 500 area church congre-
    gations were invited to participate in prayers "for local, state
    and national issues." Contributions were collected from
    attendees for the purpose of paying for this event and future
    similar events.

    The Prayer Committee chose to hold its National Day of
    Prayer service in and around a bandshell in Tucson's Reid
    Park. The organizers applied for and received a permit from
    the City to use the bandshell, and the event went forward as
    planned. Tucson in no way prevented the Prayer Committee
    from holding its prayer service in Reid Park nor interfered
    with its doing so, instead allowing the Prayer Committee's
    organizers and members to use the park, as other citizens may
    do, "for purposes of assembly, communicating thoughts
    between citizens, and discussing public questions." Hague v.
    Congress of Indus. Orgs., 307 U.S. 496, 515 (1939).2

    The Prayer Day's organizers, including the appellants here,
    Patricia and Robert Gentala, were not seeking, however, sim-
    ply to use the park for their event. They also wanted the City
    to cover the costs of city-supplied lighting and audio systems.
    The Prayer Committee applied for free use of $340 worth of
    such equipment and related services for which the City ordi-
    narily charges a fee, observing that "without help, we will
    have [an] inadequate stage and sound package, as previous
    years did."
    _________________________________________________________________
    2 From the earliest days of the public forum doctrine, it has been under-
    stood that traditional public forums like the public parks, streets, and side-
    walks are open not only to secular expression but to religious expression
    as well. See, e.g., Schneider v. State , 308 U.S. 147, 160 (1939); Jamison
    v. Texas, 318 U.S. 413 (1943); Martin v. City of Struthers, 319 U.S. 141,
    150 (1943) (Murphy, J., concurring).

                                   4006
    II. The Tucson Civic Events Fund

    The City does fund such equipment and services for some
    private events held in the City's parks, through a fund denom-
    inated the "Civic Events Fund." Tucson, however, refused the
    Prayer Committee's request for support, on the basis of an
    established policy precluding funding of events directly sup-
    porting religious organizations. The reason for the policy, as
    Tucson notified Patricia Gentala in denying her funding
    request and has consistently maintained in this litigation, is to
    avoid Establishment Clause violations.3

    Modern Establishment Clause doctrine is a species of con-
    stitutional inquiry which, as we shall develop as we go on,
    abjures absolutist doctrines and emphasizes contextual analy-
    sis instead, and in which the devil is, consequently, emphati-
    cally in the details. We therefore focus here on the features of
    Tucson's Civic Events Fund program with, perhaps, unusual
    specificity.

    Tucson charges small fees ($75) for use of bandshells in
    city parks, but that general fee is not at issue in this case.
    Additionally, Tucson will provide, for specified fees, certain
    equipment and services for use at public facilities by any
    "civic, social, religious, charitable, commercial or other
    users." The Prayer Committee is therefore eligible to use the
    available equipment as long as it pays the applicable fee.

    The available rental equipment includes, for example, dis-
    play booths, portable stages, bleachers, portable public
    address systems, microphones, speakers, extension cords,
    automated refuse containers, lighting systems and serving
    tables. For audio and lighting equipment used at the bandshell
    in Reid Park, the City requires that its staff operate the equip-
    _________________________________________________________________
    3 For reasons that appear later, the Establishment Clause issue turns out
    to be dispositive, so we concentrate here upon the facts pertinent to that
    issue.

                                   4007
    ment. The rental fees charged for the use of that equipment
    therefore include labor charges, and City employees operate
    the equipment during the event. Ordinarily, an event's orga-
    nizers pay the necessary fees to the pertinent city department,
    which, for lighting and audio equipment, is the Parks and
    Recreation Department.

    The City has determined that, aside from allowing the pub-
    lic to use the parks, facilities such as bandshells, and city-
    owned equipment, the City will "support and encourage" cer-
    tain "Civic Events." The kinds of events that the City wishes
    affirmatively to support include those that: "celebrate and
    commemorate the historical, cultural and ethnic heritage of
    the City and the nation, or increase the community's knowl-
    edge and understanding of critical issues . . .[;] generate
    broad community appeal and participation[;] instill civic pride
    in the City, state, or nation[;] contribute to tourism[;] or are
    identified as unique community events."

    The City will recognize as a Civic Event only events spon-
    sored by non-profit organizations or "individuals conducting
    the events on a non-profit basis," that is, "with fund-raising
    proceeds used for a community benefit." This limitation
    means that, whether or not they meet the substantive criteria
    for Civic Event designation, the City does not "support and
    encourage" corporate picnics, commercial concerts, or private
    birthday or anniversary celebrations in city parks (although
    the City does, as we understand the record, permit organizers
    of such events to use city-owned equipment and personnel if
    they pay the required fees).4 Also excluded from Civic Event
    designation and support are events sponsored by organiza-
    _________________________________________________________________
    4 The record does not contain any information concerning the total num-
    ber of park event permits approved for any relevant year or the total num-
    ber of park events whose organizers paid fees to use city-supplied
    equipment or personnel. It is therefore not possible on this record to deter-
    mine the percentage of all the group events held in the parks that the City
    supported through the Fund.

                                   4008
    tions that already receive city funding, whether directly or
    through rent waivers for use of city property. Finally, and crit-
    ically here, among the events that "may [not ] be considered
    for City support through the Civic Event process " are "events
    held in direct support of religious organizations."

    As part of its support and encouragement of Civic Events,
    Tucson maintains a Civic Events Fund, consisting of moneys
    appropriated from its general coffers and derived from tax
    revenue, among other sources. Organizers of eligible events
    may apply for payment from the Fund of any fees incurred for
    use of city equipment or services. When such financial sup-
    port is approved, however, the City (with limited exceptions)
    does not provide any money directly to the event's sponsors.
    The city department that would ordinarily bill the event's
    sponsors instead bills and receives payment from the Fund. Of
    course, both the Fund account and the departmental account
    are city accounts. To implement its subsidy program, there-
    fore, the City simply transfers on its books the amount of any
    fees from the Fund to the appropriate department, as "a bud-
    getary means of detailing the costs City departments incur
    providing in-kind support to Civic Events."

    Organizations receiving Fund support are required to:
    maintain financial records concerning the event and, on
    request, "provide City staff prompt access to such financial
    records and any additional financial information about the
    sponsoring organization"; obtain liability insurance for the
    event;5 and coordinate the planning of the event with a city
    Civic Event Coordinator. Additionally, to receive Civic Event
    Fund support, event organizers must promise to publicize the
    _________________________________________________________________
    5 The City's risk manager explained that the amount of insurance
    required is preset for each kind of public facility; that, if the sponsor can-
    not obtain the required amount, the risk manager can decrease the required
    coverage one step, but does so no more than twice a year; that the risk
    classifications do not take into account the nature of the event or the iden-
    tity of the sponsors; and that, to his knowledge, no event was ever cancel-
    led for lack of insurance.

                                   4009
    City's contribution of services in their event advertising and
    in an announcement made during the event.

    In the 1996-97 and 1997-98 fiscal years, the City appropri-
    ated $170,760 from its General Fund to the Civic Events
    Fund. A subcommittee of the City Council made decisions on
    applications for support of less of than $1,500; the Mayor and
    the full Council ruled on larger requests.

    The Fund application and a document entitled "Civic Event
    Fund Policy Statement and Evaluation Criteria" spell out the
    criteria for funding in great detail. Among those criteria, in
    addition to the substantive ones summarized above, are: the
    need for support, including whether the sponsoring organiza-
    tion can pay some or all of the fees itself and whether it has
    explored other sources of support; whether the funding
    request is a first-time request or not ("The Mayor and Council
    believe[ ] that events should eventually become self-reliant
    . . . . To encourage events to become self-reliant, City support
    provided in subsequent years may be gradually reduced.");
    and whether the event "generates broad community appeal
    and participation," although "special consideration will . . . be
    given to small first-time events conducted by organizations
    with limited resources."

    Although, as the detailed criteria summarized above indi-
    cate, these funding decisions are discretionary, in the only
    year for which there is complete information in the record
    there were sufficient funds available that most non-profit
    groups sponsoring eligible events received funding if they
    asked for it. In that single fiscal year, 1995, 23 events out of
    26 that met the threshold criteria were funded; the Humane
    Society-sponsored Fun Day in the Park, the Sister Cities Fund
    Raiser, and the Casa Car Show were not funded, for reasons
    that do not appear in the record.

    The City has in the past implemented the exclusion for
    events directly supporting religious organizations by refusing

                                   4010
    to pay fees incurred by fundraisers for area religious schools
    and churches, although the events themselves were not uni-
    formly religious in character.6 At the same time, the Fund sup-
    ported other events sponsored by religiously-affiliated
    organizations when the events did not directly benefit the
    groups themselves,7 and events with religious themes spon-
    sored by secular organizations. For example, in 1993, the
    Fund supported a Las Posadas pageant depicting theatrically
    events surrounding the birth of Jesus. The Las Posadas event
    was sponsored not by a religious group, however, but by the
    Tucson Festival Society and a local public school.

    III. The Litigation

    Two weeks before the Prayer Day event, Patricia Gentala,
    chair of the Prayer Committee, applied for $340 in support
    from the Fund for lighting and sound equipment and services.
    On the required application form, she identified the event as
    coming within the "Historical" category, enclosed a detailed
    description of the event, summarized above, and noted that
    there would be a "[f]ree will offer[ ]ing taken at close of pro-
    gram," with any extra money from that collection to be
    applied to the following year's event.

    The Civic Events subcommittee denied Gentala's applica-
    tion because the event was "in direct support of a religious
    organization." Gentala sought City Council review of the sub-
    committee's denial of the Prayer Committee's application for
    support, and asked the City to reconsider its policy of categor-
    _________________________________________________________________
    6 In fiscal years 1991-92 and 1992-93, the Fund declined to support sev-
    eral fundraisers for Christian schools, including the San Xavier Mission
    School's pageant celebrating "the heritage of the Old Pueblo," the Santa
    Cruz Church and school's "Fiesta de Familia," the St. John the Evangelist
    School's annual Fiesta, and the St. Peter & Paul School's "Fun Days."
    There is no information in the record concerning the City's implementa-
    tion of the religious-organization exclusion in other years.
    7 For example, the City provided Fund support to a fishing clinic for dis-
    abled children sponsored by the Aid Association for Lutherans.

                                   4011
    ically excluding "events in direct support of religious organi-
    zations" from consideration for Fund reimbursement. The
    City Council concluded that the denial was proper, explaining
    that it would violate the separation of church and state for the
    City to sponsor any event directly supporting a religious
    group.

    A few weeks later, Patricia Gentala and her husband Robert
    Gentala, who also was actively involved in the Prayer Com-
    mittee, filed this lawsuit, claiming that the exclusion of
    "events in direct support of religious organizations" from the
    Civic Events Fund violated the Free Speech, Free Exercise,
    and Establishment Clauses of the First Amendment, 8 and
    seeking preliminary and permanent injunctions against
    excluding the National Day of Prayer and other religious
    groups from Civic Events Fund support. The Gentalas styled
    their complaint as both a facial challenge to the policy and a
    challenge to the policy as applied to them.

    On September 30, 1997, the district court denied the Gen-
    talas' motions for an injunction. The district court recognized
    that the First Amendment's speech protection "extends to reli-
    gious speech and expression, including prayer and worship,"
    and that, where the government establishes, by tradition or
    design, a public forum for communicative activity, exclusion
    of religious speech and expression can be justified only if
    necessitated by Establishment Clause considerations. The dis-
    trict court noted that the case on which the Gentalas most
    heavily rely is Rosenberger v. Rector & Visitors of the Uni-
    versity of Virginia, 515 U.S. 819 (1995), in which the
    Supreme Court held unconstitutional the exclusion of a
    _________________________________________________________________
    8 The Gentalas also alleged that the Civic Events Fund's exclusion of
    events in direct support of religious organizations violated the Religious
    Freedom Restoration Act, 42 U.S.C. SS 2000bb-1-4. By the time the dis-
    trict court ruled in this case, however, that statute had been held unconsti-
    tutional, so the district court did not consider this part of the Gentalas'
    complaint. See City of Boerne v. Flores, 521 U.S. 507 (1997).

                                   4012
    religiously-oriented publication from a university program for
    funding the printing costs of student publications from man-
    datory student fees. Rosenberger, the district court recog-
    nized, is similar to this case in some respects but dissimilar in
    others. In particular, the district court stressed, Rosenberger
    involved neither the expenditure of tax-derived funds nor
    funding for a religious organization, while in this case "Plain-
    tiffs represent religious groups seeking tax dollars to support
    a religious event." As a result, the district court concluded,
    Rosenberger is not determinative here, and "the dispositive
    inquiry in this case must be made under the Establishment
    Clause."

    Conducting that inquiry, the district court began by observ-
    ing that, in cases raising issues at the intersection of the Free
    Speech and Establishment Clauses, " `specific features of a
    particular government action,' " not any " `Grand Unified
    Theory that may turn out to be neither grand nor unified,' "
    (quoting Rosenberger, 515 U.S. at 853 (O'Connor, J., concur-
    ring)), are central in deciding whether the government is, on
    the one hand, required to support religiously-oriented speech
    activities or, on the other hand, precluded from doing so by
    the Establishment Clause. Noting that Rosenberger had
    stressed that "if the State pays a church's bills it is subsidizing
    it, and we must guard against this abuse," 515 U.S. at 844, the
    district court held that compelling Establishment Clause con-
    siderations justified the City's denial of the Prayer Commit-
    tee's funding request because: (1) the Prayer Committee was
    seeking access to general tax funds; (2) the Prayer Committee
    is a sectarian religious organization; and (3) if the event were
    "paid for, equipped by, and operated by the City, " there
    would be a distinct likelihood of creating "the impression that
    the City was engaged in a costly joint-enterprise with a reli-
    gious group for religious purposes."

    The district court also rejected the Gentalas' contention that
    the degree of discretion available to the risk manager with
    regard to the implementation of the insurance requirement

                                   4013
    constituted an impermissible prior restraint of the Gentalas'
    speech.

    The Gentalas appealed. We affirm, for reasons in most
    respects similar to those relied upon by the district court.

    Standard of Review

    Observing that the critical facts were undisputed, the dis-
    trict court found that the Gentalas had suffered no harm,
    denied their motions for preliminary and permanent injunctive
    relief, and, granting their motion to consolidate the prelimi-
    nary injunction hearing with the trial on the merits, dismissed
    their suit. Ordinarily, when a district court consolidates a
    hearing on a motion for preliminary injunction with a trial on
    the merits, its findings of fact are reviewed for clear error and
    its legal conclusions de novo. Pinette v. Capitol Square
    Review & Advisory Bd., 30 F.3d 675, 677 (6th Cir. 1994),
    aff'd, 515 U.S. 753 (1995). Because the facts here are undis-
    puted, we review the district court's decision de novo. More-
    over, "[w]hen the district court upholds a restriction on speech
    as constitutional, we conduct a de novo review of the facts."
    Tucker v. California Dep't of Educ., 97 F.3d 1204, 1209 n.2
    (9th Cir. 1996); see also Daily Herald Co. v. Munro, 838 F.2d
    380, 383 (9th Cir. 1988) (explaining that the rule that "[w]e
    review de novo the district court's application of law to facts
    on free speech issues . . . reflects a special solicitude for
    claims that the protections afforded by the First Amendment
    have been abridged") (internal citations omitted).

    Discussion

    I. The Free Speech Issues

    The Gentalas' basic submission in this case is that the
    City's categorical exclusion of events "in direct support of
    religious organizations" from Fund support impermissibly
    infringes on the free speech rights of religious organizations

                                   4014
    such as the Prayer Committee, based on their religious point
    of view.9 The parties have therefore, quite understandably,
    argued vigorously about the free speech aspects, drawing
    upon different strains of First Amendment doctrine concern-
    ing the role of government in supporting communicative
    activity.

    The Gentalas, for example, maintain that the Civic Events
    Fund is, under the tripartite forum analysis we use to deter-
    mine the government's obligations when it permits or encour-
    ages the use of its property for communicative activity by
    private speakers, either a limited public forum or a nonpublic
    forum.10 In either case, the Gentalas seek to convince us, dis-
    _________________________________________________________________
    9 Although the Gentalas challenged the City's policy both on its face and
    as applied to them, under the circumstances of this case the two inquiries
    are effectively one. In considering a facial challenge to the policy, we
    study the words themselves and the City's "authoritative constructions" of
    them, through "its own implementation and interpretation" of the policy.
    Forsyth County v. The Nationalist Movement, 505 U.S. 123, 131 (1992).
    Based on the record before us, the City's application of the blanket exclu-
    sion on funding "events in direct support of religious organizations" to the
    Prayer Committee is fully consistent with and illustrative of its implemen-
    tation of the policy in other instances in the record.

    As for the Gentalas' claim that the exclusion is overbroad, they have not
    demonstrated that the exclusion chills the protected expression of any par-
    ties not before the court, City of Los Angeles v. Taxpayers for Vincent, 466
    U.S. 789, 797 (1984), and there is no reason to think that it does. The
    record suggests, instead, that the exclusion effects little, if any, chilling of
    protected speech. The Prayer Committee, for example, held a successful
    prayer service in a city park undeterred by the fact that it did not have the
    use of the City's sound and light equipment. Nor have the Gentalas shown
    any material difference between the Civic Events policy as applied to
    them and as applied to any other speaker affected by the categorical exclu-
    sion of events in direct support of religious organizations. Thus, this case
    is not a candidate for First Amendment overbreadth analysis. Id. at 801-
    02.
    10 See, e.g., Perry Educ. Ass'n v. Perry Local Educators Ass'n, 460U.S.
    37, 46-57 (1983); Cornelius v. NAACP Legal Def. & Educ. Fund, Inc, 473
    U.S. 788, 801 (1985); DiLoreto v. Downey Unified Sch. Dist., 196 F.3d
    958, 966-67 (9th Cir. 1999).

                                   4015
    criminating against groups in the distribution of Fund support
    on the basis that their speech expresses a religious viewpoint
    is unconstitutional. In support of this contention, the Gentalas
    cite, inter alia, Rosenberger, Widmar v. Vincent, 454 U.S.
    263, 271 (1981), and Lamb's Chapel v. Center Moriches Sch.
    Dist., 508 U.S. 384, 394 (1993), cases which hold that the
    government, in administering a limited public forum, may not
    exclude some or all types of religious expression. 11

    Tucson, not surprisingly, is of the view that the cases the
    Gentalas rely upon are not pertinent at all to the speech issues
    in this case. Rather, Tucson argues, the situation here fits into
    an entirely different mode of First Amendment speech analy-
    sis, applicable when the government is in some measure
    engaged in communicative activity, as it was in National
    Endowment for the Arts v. Finley, 524 U.S. 569 (1998) (gov-
    ernment as patron), Arkansas Educ. Television Comm'n v.
    Forbes, 523 U.S. 666 (1998) (government as editor), and Rust
    v. Sullivan, 500 U.S. 173, 193 (1991) (government as policy
    proponent). In all of those cases, some degree of viewpoint or
    qualitative selection criteria were permitted because the gov-
    ernment was engaged not simply in providing a forum for pri-
    vate speech but in forwarding its own program through the
    speech of others. See, e.g., Forbes, 523 U.S. at 673-74 (noting
    that the government sometimes assumes roles, such as public
    broadcaster or curriculum developer, in which its exercise of
    "editorial discretion" in choosing among prospective speakers
    is a speech activity on behalf of the government itself, not
    subject to forum analysis); Downs v. Los Angeles Unified Sch.
    Dist., 228 F.3d 1003, 1016-17 (9th Cir. 2000) (holding that a
    school district could control the content of messages posted
    on high school bulletin boards "without the constraint of
    viewpoint neutrality").
    _________________________________________________________________
    11 The precise reach of the free speech analysis of these cases is cur-
    rently pending before the Supreme Court in Good News Club v. Milford
    Central School, 202 F.3d 502 (2d Cir.), cert. granted, 121 S. Ct. 296
    (2000).

                                   4016
    Each of these opposing characterizations of the City's role
    in developing and expending its Civic Events Fund has some
    considerations in its favor. On the one hand, the City in this
    case, like the university in Rosenberger, is administering a
    fund providing in-kind services for a wide range of speakers.
    A large majority of speakers who meet the applicable Civic
    Events criteria were in fact funded during the period for
    which there is evidence in the record, so the very strong ele-
    ment of qualitative governmental selectivity involved in cases
    such as Finley (concerning the administration of the National
    Endowment for the Arts) or Forbes (concerning the editorial
    discretion necessary in making journalistic decisions) is not
    present here.

    On the other hand, the criteria for funding here are more
    selective than in Rosenberger, albeit not as selective and dis-
    cretionary as in Finley and Forbes. That most projects are
    funded may evidence only self-selectivity by event organizers
    aware of the applicable criteria or, more probably, the avail-
    ability of sufficient funds for the period in question, a circum-
    stance that may not always prevail. Additionally, the City's
    policy goals here are not, one might conclude, similar to those
    of the university in Rosenberger; while the university was
    concerned with assuring a vigorous interchange of ideas
    among students as part of the educational process, the City is
    concerned with providing for its citizens and tourists events
    of certain kinds that the City believes enhance Tucson's ambi-
    ance as an attractive place to live and visit. Because that is the
    goal, the City affirmatively identifies itself as the sponsor of
    funded events, placing its imprimatur on the events in a man-
    ner somewhat like the editor of an anthology does, while the
    university in Rosenberger did quite the opposite. See 515 U.S.
    at 841.

    [1] Were we required to select among the mutually exclu-
    sive Free Speech Clause paradigms the parties propound--
    each leading under currently prevailing First Amendment
    doctrine to a different result concerning the City's authority

                                   4017
    to exclude speakers from a government-provided subsidy
    because they are engaged in a prayer service--the choice
    would be a difficult one. It is a choice we need not make,
    however, in order to resolve this case. For, even assuming that
    the Gentalas have the better of the battle of the paradigms,
    that conclusion would not end the inquiry. Rather, as the
    Supreme Court and this court have indicated repeatedly, the
    government may decline to subsidize private religious speech
    when doing so would violate the Establishment Clause, or,
    put another way, avoiding a violation of the Establishment
    Clause is a sufficiently compelling reason to justify govern-
    ment's exclusion of certain private speech in a forum other-
    wise dedicated to communicative activity.12 See, e.g.,
    Rosenberger, 515 U.S. at 837; Capitol Square Review &

    Advisory Bd. v. Pinette, 515 U.S. 753, 761-62 (1995);13
    Lamb's Chapel, 508 U.S. at 394; Widmar, 454 U.S. at 271;
    Cole v. Oroville Union High Sch. Dist., 228 F.3d 1092, 1101
    (9th Cir. 2000), pet. for cert. filed Jan. 2, 2001; cf. Tucker, 97
    F.3d at 1212. We therefore agree with the district court that
    if the City's Establishment Clause justification for the Civic
    Events Fund's religious exclusion is valid, then the exclusion
    is valid as well.14 It is to the Establishment Clause inquiry,
    therefore, that we now direct our attention.
    _________________________________________________________________
    12 For the same reason, we need not determine whether the Civic Events
    Fund's exclusion for events directly supporting a religious organization is
    in fact viewpoint discriminatory or, instead, is more accurately character-
    ized as a content or identity distinction, because the Establishment Clause
    justification would suffice even if the exclusion is viewpoint discrimina-
    tory.
    13 As the Capitol Square Court explained in analyzing whether a city
    could bar a private group's placement of a cross in a public square: "There
    is no doubt that compliance with the Establishment Clause is a state inter-
    est sufficiently compelling to justify content-based restrictions on speech."
    515 U.S. at 761-62. Given Capitol Square's factual context and the
    Court's citation to Lamb's Chapel and Widmar for the just-stated princi-
    ple, the Capitol Square Court plainly meant that private religious expres-
    sion in a public forum, however defined, see n.11, supra, not only is
    protected by the Free Speech Clause, but also is subject to the constraints
    of the Establishment Clause.
    14 We note that the considerations just canvassed in summarizing the
    competing free speech arguments do become pertinent to our Establish-

                                   4018
    II. The Establishment Clause

    To embark on that inquiry, however, is not necessarily to
    simplify matters greatly, for modern Establishment Clause
    jurisprudence is famously indistinct. As a recent summary of
    the last century's Religion Clause cases put it:

          The Supreme Court is presently split closely on
          almost all important issues of . . . separation of
          church and state . . . . Resolution of difficult issues
          in this area "depends on the hard task of judging--
          sifting through the details . . . . Such judgment
          requires courts to draw lines, sometimes quite fine,
          based on the particular facts of each case."[Rosen-
          berger, 515 U.S. at 847 (O'Connor, J., concurring)].
          As a consequence of these realities, the current
          development of the law provides more themes than
          categorical principles, with little doctrinal stability.

    Jesse H. Choper, A Century of Religious Freedom , 88 Cal. L.
    Rev. 1709, 1741 (2000). The most propitious approach to the
    perplexities of Establishment Clause doctrine, we have con-
    cluded, is to begin by examining three of the Establishment
    Clause "themes" involved both in Rosenberger, the case on
    which the Gentalas most heavily rely and which is indeed
    quite similar to this one in many respects, and in this case as
    well. We then turn to the details of Tucson's Civic Events
    program to see why, as we hold, the Establishment Clause
    considerations play out differently on the facts of this case
    than they did in Rosenberger.
    _________________________________________________________________
    ment Clause analysis, for they are informative in determining the degree
    to which the City's Fund program constitutes an endorsement of the pri-
    vate speech involved, a key Establishment Clause consideration. See Santa
    Fe Indep. Sch. Dist. v. Doe, 120 S. Ct. 2266 (2000); see also pp. 4029-
    4031, infra.

                                   4019
    A. Establishment Clause Analysis in Rosenberger and
          Thereafter

    In Rosenberger, the Supreme Court examined a Student
    Activities Fund ("Activities Fund") program at the University
    of Virginia to determine whether Wide Awake Productions,
    an evangelical student-written newspaper otherwise eligible
    for an Activities Fund subsidy to cover its printing costs,
    could be denied the subsidy because the publication consti-
    tuted a "religious activity." The Activities Fund was financed
    through mandatory student activity fees; qualified student
    groups were required to submit their bills to the Student
    Council for payment from the Activities Fund. 515 U.S. at
    824. The Court concluded that the Activities Fund was, for
    purposes of Free Speech Clause analysis, a designated public
    forum, albeit "a forum more in a metaphysical than in a spa-
    tial or geographic sense," from which the University could not
    exclude speakers based upon their viewpoint. Id.  at 830-31.
    After determining that the exclusion of Wide Awake Produc-
    tions was based on its Christian viewpoint rather than on its
    content, the Court held that, absent a compelling justification,
    denying Activities Fund support to Wide Awake would be a
    denial of the First Amendment's Free Speech guarantee. Id.
    at 837. The Court then turned, as we have turned here, to the
    question whether the exclusion "is excused by the necessity
    of complying with the Constitution's prohibition against state
    establishment of religion." Id.

    In doing so, the Court discussed three considerations that
    have been of great importance in recent Establishment Clause
    analysis, each of which has been further developed in subse-
    quent cases:

    First, the majority opinion in Rosenberger emphasized that
    the Student Activities Fund program, if revised to include
    religiously-oriented publications, would not single out reli-
    gion for special benefits, but, instead, would be "neutral
    toward religion." 515 U.S. at 840. At the same time, the Court

                                   4020
    in Rosenberger did not rest on the neutrality consideration.
    Instead, the Court observed that Establishment Clause analy-
    sis, as in comparable cases, turned not only on "general prin-
    ciples," id. at 839, namely the Activities Fund's neutrality
    toward religion, but also on other "practical details of the pro-
    gram's operation." Id.

    Moreover, neutrality is merely "one hallmark of the Estab-
    lishment Clause," as Justice O'Connor convincingly
    explained in Rosenberger. 515 U.S. at 846 (O'Connor, J.,
    concurring):

           Our cases have permitted some government fund-
          ing of secular functions performed by sectarian orga-
          nizations. [citations omitted]. These decisions,
          however, provide no precedent for the use of public
          funds to finance religious activities.

           This case lies at the intersection of the principle of
          government neutrality and the prohibition on state
          funding of religious activities. . . . Not to finance
          Wide Awake, according to petitioners, violates the
          principle of neutrality by sending a message of hos-
          tility toward religion. To finance Wide Awake,
          argues the University, violates the prohibition on
          direct state funding of religious activities.

           When two bedrock principles so conflict, under-
          standably neither can provide the definitive answer.
          Reliance on categorical platitudes is unavailing.

    Id. at 847.

    Since Rosenberger, the Supreme Court has continued to
    struggle mightily over the question whether neutrality toward
    religion is sufficient, or nearly sufficient, to justify govern-
    ment subsidies of core religious activity, whatever else may
    be the case. A majority of the Court, however, made quite

                                   4021
    clear last term, if it was not clear before, that, although neu-
    trality is an important consideration in Establishment Clause
    cases, that consideration alone is not determinative where
    government subsidy of religious activity is concerned.

    Thus, Justice Souter, writing for three justices, after first
    reviewing at length the history of the neutrality concept in
    Establishment Clause jurisprudence, Mitchell v. Helms, 120
    S. Ct. 2530, 2578-81 (2000) (Souter, J., dissenting), stated:

          `Neutrality' [meaning] generality or evenhandedness
          of distribution . . . is relevant . . . but this neutrality
          is not alone sufficient to qualify the [government]
          aid as constitutional. It has to be considered only
          along with other characteristics of aid, its administra-
          tion, its recipients, or its potential that have been
          emphasized over the years as indicators of just how
          religious the intent and effect of a given aid scheme
          really is.

    Id. at 2581. Similarly, in her opinion for two justices in Mitch-
    ell, id. at 2557 (O'Connor, J., concurring in the judgment),
    Justice O'Connor decisively reiterated the position she took in
    her Rosenberger concurrence against neutrality as the deter-
    mining factor in Establishment Clause cases, stating:
    "[N]eutrality is important but it is by no means the only
    `axiom in the history and precedent of the Establishment
    Clause.' Rosenberger, [515 U.S. at 846 (O'Connor, J., con-
    curring).] . . . [N]eutrality is not alone sufficient to qualify the
    aid as constitutional."

    We are left, then, with the clear holding by a Supreme
    Court majority that when the government subsidizes religious
    activity, the fact that it is doing so pursuant to a program that
    treats religious speech or association coequally with other
    speech or association is not, standing alone, determinative in
    Establishment Clause analysis. Instead, we are obligated to
    consider other factors in determining whether the connection

                                   4022
    between the government subsidy and the religious activity is
    such as to violate the concerns underlying the Establishment
    Clause (including, most importantly, the two we next discuss).15

    Second, the central concern making Rosenberger a close
    and difficult case was that the subsidy to religious expression
    involved was not simply the use of government space, gener-
    ally open to the public or to some subgroup thereof for
    expressive activity, see Lamb's Chapel, 508 U.S. at 395; Wid-
    mar, 454 U.S. at 271-72 & n.12, but a form of governmental
    financial support for religious activity. The Rosenberger
    Court, far from discounting this consideration, recognized that
    "[t]he Court of Appeals (and the dissent) are correct to extract
    from our decisions the principle that we have recognized spe-
    cial Establishment Clause dangers where the government
    makes direct money payments to sectarian institutions." 515
    U.S. at 842. And indeed, the prohibition on funding religious
    activities has been preeminent among establishment of reli-
    gion concerns, depending upon one's view of history, from
    the nation's infancy, see id. at 868-76 (Souter, J., dissenting);
    see also id. at 846-47 (O'Connor, J., concurring) (agreeing
    that the "axiom" that " `[p]ublic funds may not be used to
    endorse the religious messages' " [citation omitted] has long
    been a "bedrock" of Establishment Clause jurisprudence);
    compare id. at 853-63 (Thomas, J., concurring), or, at least,
    since Everson v. Board of Education, 330 U.S. 1, 17-18
    (1941) ("No tax in any amount, large or small, can be levied
    to support any religious activities or institutions, whatever
    they may be called, or whatever form they may adopt to teach
    or practice religion.").16
    _________________________________________________________________
    15 Judge Fernandez argues in dissent that because the City's Fund policy
    is not neutral toward, but expressly excludes, religious organizations, it
    necessarily goes beyond what the Establishment Clause requires. As just
    discussed, however, while Judge Fernandez' position that neutrality
    toward religion is all that matters has been advocated by a plurality of the
    Court, five justices decisively rejected that position in Mitchell.
    16 It is worth noting, because the distinction becomes lost on occasion,
    that the funding concern and the endorsement concern next discussed,

                                   4023
    Rosenberger explicitly so recognized, noting that "if the
    State pays a church's bills it is subsidizing it, and we must
    guard against this abuse." 515 U.S. at 844. The Rosenberger
    Court nonetheless held, for several reasons, that the funding
    prohibition was not of controlling importance in that case,
    emphasizing that: (1) the mandatory fees comprising the
    Activities Fund were an "exaction upon the students," not "a
    general tax designed to raise revenue for the University,"17 id.
    at 840-41; see also id. at 841 (" `A tax, in the general under-
    standing of the term, and as used in the Constitution, signifies
    an exaction for the support of the Government.'  " (quoting
    United States v. Butler, 297 U.S. 1, 61 (1936)); id. ("Our deci-
    sion, then, cannot be read as addressing an expenditure from
    a general tax fund."); id. at 851-52 (O'Connor, J., concur-
    ring); (2) Wide Awake was a "student publication[,] . . . not
    a religious institution, at least in the usual sense of that term
    as used in our case law," so that, in paying Wide Awake's
    bills, the University was not paying the bills of a church or
    similar organization, id. at 844;18 (3) the activity funded did
    _________________________________________________________________
    while overlapping in some respects, are not one and the same, nor is one
    a subcategory of the other. The funding concern centers in large part on
    the interest of citizens in resisting coercion to subsidize religious ideas in
    which they disbelieve. See, e.g., Flast v. Cohen, 392 U.S. 83, 103-04
    (1968); Everson, 330 U.S. at 15-16. The endorsement concern, in contrast,
    centers upon the disturbance of civic society that occurs when the govern-
    ment appears publicly to favor one religion over another, or religion over
    nonreligion. See, e.g., Santa Fe, 120 S. Ct. at 2278; Capitol Square, 515
    U.S. at 779. The funding factor would have force, for example, even if the
    government kept secret the fact that tax funds were being funneled directly
    to churches to finance their services, while the endorsement "theme"
    would be of concern if the government proclaimed an official religion
    without providing its adherents any funding at all.
    17 In other contexts as well, the Supreme Court has repeatedly empha-
    sized the distinction between general taxes and mandatory fees levied on
    a select group of people to support activities in their common interest. See
    Glickman v. Wileman Bros. & Elliott, 521 U.S. 457, 469-70 (1997); Keller
    v. State Bar of Cal., 496 U.S. 1, 12-13 (1990); Abood v. Detroit Bd. of
    Educ., 431 U.S. 209, 259 n.13 (1977).
    18 The policy at issue in Rosenberger did not permit use of the Activities
    Fund to subsidize "religious organizations," defined as organizations

                                   4024
    not involve "religious exercises," id. at 842; and (4) the bene-
    fit provided did not involve direct funding of religious speech,
    since the University did not provide eligible student groups
    with direct financial assistance but instead paid their printing
    bills. Id. at 842-44.

    Third, also prominent in Rosenberger was the concern that
    subsidizing Wide Awake's religiously-oriented publication
    could be perceived as a governmental endorsement of the reli-
    gious ideas propounded by its student editors. The Court rec-
    ognized that the Establishment Clause forbids " `government
    speech endorsing religion,' " 515 U.S. at 841 (quoting Board
    of Educ. of Westside Cmty. Schs. (Dist. 66) v. Mergens, 496
    U.S. 226, 250 (1990) (plurality opinion) (emphasis in origi-
    nal)), but concluded that, "[i]n this case,`the government has
    not fostered or encouraged' any mistaken impression that the
    student newspapers speak for the University." 515 U.S. at 841
    (quoting Capitol Square, 515 U.S. at 766). In particular, the
    Court noted that "[t]he University has taken pains to disasso-
    ciate itself from the private speech involved in this case,"
    Rosenberger, 515 U.S. at 841; for example, the University
    required all recognized student organizations to sign an agree-
    ment stating that the recognition does not signal University
    "approval of the organizations' goals or activities," and also
    required each publication to include the statement that it was
    independent of the University, and that the University was not
    responsible for its actions. Id. at 824; id. at 849 (O'Connor,
    J., concurring). Given this agreement and disclaimer, as well
    as the fact that Wide Awake competed with many other
    Activities Fund-supported publications for the University
    community's attention, it was extremely unlikely that observ-
    ers would perceive that the University was endorsing the
    views put forward in Wide Awake.
    _________________________________________________________________
    "whose purpose is to practice a devotion to an acknowledged ultimate
    reality or deity." 515 U.S. at 826. The Court ascribed considerable signifi-
    cance to the fact that the University did not contend that Wide Awake was
    a "religious organization" under its definition. Id. at 844.

                                   4025
    [2] Since Rosenberger, the precise nature of the Establish-
    ment Clause endorsement inquiry, like the role of the neutral-
    ity principle, has been clarified. Santa Fe centered on the
    endorsement question, stressing that the concern underlying
    the endorsement inquiry is that governmental identification
    with religious speech or worship communicates to nonadher-
    ents "that they are outsiders, not full members of the political
    community, and an accompanying message to adherents that
    they are insiders, favored members of the political communi-
    ty." 120 S. Ct. at 2279.19 To determine whether a government
    subsidy to religion constitutes "actual or perceived endorse-
    ment," the Court stressed, requires a highly fact-specific
    inquiry, directed at the question "whether an objective
    observer, acquainted with the text, . . . history, and implemen-
    tation of the [program] would perceive it as a state endorse-
    ment" of religious observance. Id. at 2278.

    Rosenberger and the Court's post-Rosenberger cases, then,
    provide a modicum of theoretical insight into the applicable
    Establishment Clause "themes," and, more usefully perhaps,
    substantial practical insight into the specific factors most
    likely to be informative as we focus our attention on the inter-
    action among these various considerations in the circum-
    stances of this case.

    B. "Sifting Through the Details"

    As the foregoing analysis suggests, cases of this kind--that
    is, those at the intersection of the Free Speech and Establish-
    ment Clauses--are ones in which the admonition that Estab-
    lishment Clause "jurisprudence . . . is of necessity one of line-
    drawing," Lee v. Weisman, 505 U.S. 577, 598 (1992), has par-
    _________________________________________________________________
    19 Santa Fe concerned the offering of pre-game prayers over a high
    school's public address system at school football games. Applying the
    endorsement analysis, the Court determined that, although the prayer was
    delivered by a student selected by other students, in the atmosphere of
    school sponsorship inherent in the setting, "an objective Santa Fe High
    School student [would] unquestionably perceive the inevitable pregame
    prayer as stamped with her school's seal of approval." 120 S. Ct. at 2278.

                                   4026
    ticular force. Turning to the line-drawing task, we conclude
    that this case involves significant factual differences from
    Rosenberger in matters that were deemed important to that
    case's Establishment Clause analysis. There are also some
    contextual matters that we deem to be important but that had
    no counterpart in Rosenberger. The upshot is that, looking at
    these factors as a whole, we conclude that in this case, the
    public funding and government endorsement considerations
    considerably overwhelm the neutrality consideration, and lead
    us to the conclusion that Tucson's Establishment Clause justi-
    fication for its religious organization exclusion is valid.

    (1) Tax-based funding of religious organization

    [3] Considering the governmental funding of religion, there
    are a number of factors that are precisely opposite in this case
    from a factor deemed important in Rosenberger . Here, the
    source of the Civic Events Fund moneys includes general tax
    revenue, not simply fees levied against a discrete group of cit-
    izens. Also, Tucson excludes funding only for events support-
    ing religious organizations, and the Prayer Committee is
    preeminently a religious organization; Wide Awake, in con-
    trast, was a student newspaper with a religious viewpoint, not
    an "organization whose purpose is to practice a devotion to
    an acknowledged ultimate reality or deity." Rosenberger, 515
    U.S. at 840 (quoting the university's definition of "religious
    organization") (emphasis added). Further, the activity funded
    here was a participatory religious service, led by ministers and
    consisting primarily of prayer, not a written document, how-
    ever proselytizing. Unless we are to believe that the Rosen-
    berger Court's explicit reliance on each of these three
    considerations was without significance, we must conclude
    that in this case, unlike in Rosenberger, Civic Events Fund
    subsidies of the Prayer Day and similar events would be tanta-
    mount to "the State pay[ing] a church's bills." Id. at 844.

    [4] Moreover, Tucson's administration of its Civic Events
    Fund involves considerably more discretionary decisionmak-

                                   4027
    ing than did the university's administration of the Activities
    Fund in Rosenberger. Here, the City has retained a good deal
    of subjective discretion concerning which events to fund,
    including establishing fairly general substantive criteria,
    criteria relating to the organization's (and the Fund's) finan-
    cial circumstances, criteria related to whether the event is a
    first-time or ongoing event, and criteria concerning the likely
    appeal of the event to the citizenry. That most nonprofit orga-
    nizations' events are nonetheless funded does not detract from
    the fact that City officials do in fact review each application
    and make a decision using City-established criteria, that some
    applications are denied, and that the very existence of multi-
    ple criteria for funding likely leads to self-selection by other-
    wise eligible organizations. As a result, one cannot escape the
    conclusion, in this case, that it is the City making the choice
    which events to fund, a circumstance that, the Supreme Court
    has suggested, greatly exacerbates the significance of the tax-
    based derivation of the funding. See Mitchell , 120 S. Ct. at
    2541-43 (plurality opinion) (stressing the importance of pri-
    vate, as opposed to governmental, funding choices as to
    whether tax-derived funds will be used by a religious institu-
    tion pursuant to a program neutrally available to secular as
    well as religious institutions); id. at 2558-59 (O'Connor, J.,
    concurring) (agreeing with the plurality's stress on the impor-
    tance of private choice, but maintaining that the private choice
    must be a true, individual choice, not a governmentally-
    prescribed aid formula).

    [5] Finally, we note that Tucson's exclusion for events in
    direct support of religious organizations appears to apply prin-
    cipally where, as here, the event will raise money from
    attendees that could be used to fund the organization in the
    future. The Gentalas, for example, explained their need for
    City funding in part by their desire to generate a surplus from
    the "free will offering." There is therefore the additional con-
    cern, not present in Rosenberger or in any other case concern-
    ing governmental funding of religious activity of which we
    are aware, that although the subsidy provided is in-kind and

                                   4028
    in that sense indirect, it is intended for use effectively as seed
    money to generate other, non-earmarked funds for the reli-
    gious organization. The exclusion for events "in direct sup-
    port of religious organizations" therefore functions similarly
    to a prohibition on cash grants to religious organizations.
    Rosenberger, 515 U.S. at 842.

    (2) City Endorsement of Religion

    Turning to the question "whether an objective observer,
    acquainted with the text, . . . history, and implementation of
    the [program] would perceive it as a state endorsement" of
    any religious observance funded, Santa Fe, 120 S. Ct. at
    2279, we conclude that there are considerably more reasons
    that such an observer would so conclude regarding Tucson's
    Civic Events Fund than there were in Rosenberger.

    [6] Here, the subsidy often includes, as it would have for
    the Prayer Day event, the on-site, observable presence of city
    employees, not simply the behind-the-scenes payment of bills
    from private vendors, as in Rosenberger. Moreover, the
    equipment used--microphones, lighting systems, tables, pub-
    lic address systems--is city-owned and is likely to be quite
    visible to onlookers during the event.

    [7] Additionally, the detailed, subjective funding criteria
    discussed above, as well as the role of the Mayor and Council
    in establishing and applying those criteria, would contribute
    to an informed observer's impression that an event that sur-
    vives the review process is one that the City affirmatively
    endorses. Contributing to that impression would be the fact
    that many, probably most, events in the parks do have to pay
    the prescribed fees because they are not eligible for Civic
    Events Fund designation. In short, the City has retained a role
    for itself something like that of impresario, selecting the
    events that are consistent with the image of Tucson that the
    City wishes to foster and that therefore merit public subsidy.

                                   4029
    [8] Consistent with the impression created by the funding
    process, the City's policy and application form make clear
    that the Civic Events Fund program is meant to endorse some
    events as "Civic Events" worthy of the City's imprimatur. A
    person acquainted with the funding program's text, history,
    and implementation would know, for example, that the gov-
    erning policy statement expressly states that "[t]he Mayor and
    Council encourage and support Civic Events, " (emphasis
    added), which are then described by category; that the phrase
    "Civic Events" is always capitalized in the policy statement
    even when no funding is at issue, indicating a city-conferred
    title or status; and that organizers of funded events are
    directed to deal with a city official denominated the "Civic
    Event Coordinator" in order to "obtain assistance in coordi-
    nating the event." Of a piece with these other indicia of
    endorsement is the additional, significant requirement that, far
    from declaring their independence from the government
    funder as in Rosenberger, organizers of Civic Events Fund-
    subsidized events must call attention to the City's supportive
    role both in pre-event advertising and at the event itself.

    It is true, as the district court noted in discounting the sig-
    nificance of the latter point, that the City could simply remove
    this acknowledgment requirement if it chose. That observa-
    tion is not pertinent to our analysis, for two related reasons.

    First, as the other factors summarized above indicate, the
    express acknowledgment requirement simply confirms the
    overall nature of the Civic Events program as one in which
    the City affirmatively supports certain privately-originated
    events. The acknowledgment requirement does not itself
    create that relationship. To require the City to hide its true
    relationship to the event would not alter that relationship, but
    instead, would only mislead the public.

    Second, the courts are not in the business of designing gov-
    ernmental programs but, instead, of taking them as they find
    them and determining their constitutional significance. Thus,

                                   4030
    for example, the Court in Forbes, 523 U.S. 666, did not direct
    the government henceforth to run its broadcasting stations on
    an open microphone basis so as to avoid editorial decisions
    but, instead, viewed the broadcasting program as one in which
    editorial decisions were important and came to its conclusions
    about the Free Speech rights of those seeking access to the
    broadcasting station accordingly. Nor did the Court solve the
    knotty Free Speech issues regarding government funding for
    the arts involved in Finley, 524 U.S. 569, by informing the
    government that it should fund the arts on a first-come-first-
    served basis. See id. at 598 (Scalia, J., concurring in the judg-
    ment) ("It is the very business of government to favor and dis-
    favor points of view on . . . innumerable subjects .. . .
    [Government] further[s] [a] favored point of view by achiev-
    ing it directly, . . . by advocating it officially, . . . or by giving
    money to others who achieve and advocate it."); Downs, 228
    F.3d at 1013-14. To require Tucson to drop its express sup-
    port of preferred community events in favor of an objective,
    hands-off funding system in order that events in direct support
    of religious organizations could be funded would be to require
    the City to abandon its present program and substitute a dif-
    ferent one, a ukase beyond our authority as a court.

    We note, as well, that the nature of Tucson's Civic Events
    Fund program is such that allowing various religious organi-
    zations to compete for funding would lead to some of the very
    dangers the Establishment Clause was intended to prevent.
    For one thing, in order to comply with the City's emphatically
    secular criteria for funding, religious event organizers would
    be likely to "secularize" their events. Lee, 505 U.S. at 608
    (Blackmun, J., concurring). Although the focus on the com-
    munity's "historical, cultural, and ethnic heritage," "critical
    issues," and "civic pride" may be commendable, creating an
    incentive to structure religious events toward such worldly
    objectives would encourage the dilution of spiritual life, not
    enhance it. And while fairly small sums are at issue here, the
    Establishment Clause principles examined above admit no
    distinction between large grants to religion and small ones.

                                   4031
    Further, the necessity of applying subjective substantive
    criteria could result in the City impermissibly promoting some
    faiths over others. Lee, 505 U.S. at 627 (Souter, J., concur-
    ring); Everson, 330 U.S. at 15. Some religions are likely to
    have more "broad community appeal" than others, or to "con-
    tribute to tourism" more readily. Concerns about the dangers
    of such government favoritism to the cohesiveness of civil
    society echo down from the Framers to the Supreme Court's
    most recent jurisprudence. Compare James Madison, Memo-
    rial and Remonstrance Against Religious Assessments , P 9
    (1785) (observing that government favoritism toward certain
    faiths "degrades from the equal rank of Citizens all those
    whose opinions in Religion do not bend to those of the Legis-
    lative authority"), with Santa Fe, 120 S. Ct. at 2279 (noting
    that government sponsorship of a religious message commu-
    nicates to nonadherents " `that they are outsiders, not full
    members of the political community' " (quoting Lynch v.
    Donnelly, 465 U.S. 668, 688 (1984) (O'Connor, J., concur-
    ring)).

    The short of the matter is that, after "sifting through the
    details," we are convinced, first, that this case and Rosenber-
    ger, for all their superficial similarity, are different in most of
    the details that matter for Establishment Clause purposes, and,
    second, that all of the ways in which they differ point toward
    an Establishment Clause violation in this case. 20
    _________________________________________________________________
    20 Judge Kleinfeld suggests, in his dissent, that the record as it stands is
    inadequate to decide the issues before us. We disagree.

    Judge Kleinfeld treats the factual question whether the City was in prac-
    tice selective in expending Civic Events Fund moneys as all-important,
    accuses us of "believ[ing] that the very fact that some applications are
    denied is enough to decide this case," (post , at 4042), and then notes that
    the record contains limited information on the denial-rate question. But we
    do not agree that the actual selectivity question is determinative. Rather,
    as the above analysis indicates, that some applications are denied is perti-
    nent only because that fact tends to confirm that the city is doing what its
    program documents in no uncertain terms state that it is doing, namely,

                                   4032
    C. Relevance of Free Exercise Clause to the
          Establishment Clause

    One final point: We do not agree that, as Judge Fernandez'
    dissenting opinion maintains, Free Exercise Clause consider-
    ations require that we alter our Establishment Clause analysis.

    [9] Denying financial subsidies to religious organizations
    does not, standing alone, substantially burden Free Exercise
    rights. As the Supreme Court observed in Bob Jones Univer-
    sity v. United States, 461 U.S. 574, 603-04 (1983), religious
    schools' ineligibility for a tax exemption due to their racially
    discriminatory practices might impose significant burdens on
    their operations, but any such administrative burdens would
    "not prevent those schools from observing their religious
    tenets." See also Hernandez v. Commissioner , 490 U.S. 680,
    699 (1989) (denial of tax deduction not a Free Exercise
    Clause violation); Swaggart Ministries v. California Dep't of
    Equalization, 493 U.S. 378, 391-92 (1990) (same).

    [10] Here, the claim of denial of Free Exercise rights is par-
    ticularly weak. The Gentalas have made no showing that their
    ability to worship as they choose has been discernibly bur-
    dened by the operation of the Civic Events program. Rather,
    the Prayer Committee staged a well-attended prayer service in
    a City-provided location, the Reid Park bandshell. See Collins
    v. Chandler Unified Sch. Dist., 644 F.2d 759, 763 (9th Cir.
    1981). In Free Exercise terms, then, the government's denial
    of a financial subsidy for microphones and lights to a reli-
    gious group is a far cry from its outright prohibition of the
    group's religious practice. Cf. Church of the Lukumi Babalu
    _________________________________________________________________
    affirmatively promoting certain events as city-endorsed and approved. The
    other indices of endorsement, surveyed in the text, are sufficient to raise
    Establishment Clause concerns even if, in a given year, the City deter-
    mines that all applicants for Civic Events Fund support meet the requisite,
    detailed criteria for funding and that sufficient funding is available for all
    of them.

                                   4033
    Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993) (holding that
    ordinance prohibiting a religious group's ritual violated the
    Free Exercise Clause).

    Moreover, the refusal to fund the Prayer Committee's
    microphones and lighting is also a far cry from denying a reli-
    gious organization or event services essential to survival in
    civil society, such as police and fire protection. Police and fire
    protections are vital public services to which all citizens enjoy
    a basic entitlement. Denying such services to a particular
    group of citizens would both evince government hostility and
    threaten the group's ability to exist. The same simply cannot
    be said of Tucson's program, a subsidy for items such as
    microphones and stage lights for special events, available
    only to a limited set of potential users and in no way neces-
    sary for survival in the modern world. Indeed, if the failure to
    subsidize a religious activity with regard to expenditures that
    are in no way analogous to basic public safety services vio-
    lated the Free Exercise Clause, the Court would have said so
    in Rosenberger and written a very different, and much
    shorter, opinion.

    [11] We therefore conclude that Tucson was correct that it
    could not provide funding to "events in direct support of reli-
    gious organizations" generally, or to the Prayer Day event in
    particular, without violating its constitutional obligations
    regarding the separation of church and state.

    Conclusion

    Because we agree with the City that its policy is mandated
    by the Establishment Clause, we need not reach the question
    that the City raises on cross-appeal: whether the district court
    should have granted the City leave to amend its answer to add
    an affirmative defense derived from the Arizona Constitu-
    tion's religion clauses.21 The federal Constitution provides all
    _________________________________________________________________
    21 We affirm the decision below on the insurance issue for the reasons
    stated by the district court.

                                   4034
    the defense Tucson needed in this lawsuit. We affirm the dis-
    trict court in all respects.

    AFFIRMED.

    _________________________________________________________________

    FERNANDEZ, Circuit Judge, dissenting:

    As I see it, this case is not about speech, or viewpoints of
    speakers, at all. It is solely about outright discrimination
    against religious organizations. As such, it does violate the
    First Amendment, but not the clause which precludes govern-
    ment from "abridging the freedom of speech." Rather, it vio-
    lates the clauses which command that government "shall
    make no law respecting an establishment of religion, or pro-
    hibiting the free exercise thereof." As I shall explain, that
    does not make the law any less malignant.

    Because it is where the City of Tucson (as well as the
    majority) starts, I shall first address the speech issue, and in
    so doing I shall begin with the City's "Civic Event Policy
    Statement and Evaluation Criteria." That is both inclusive and
    exclusive. It provides for City support of civic events which
    either "celebrate and commemorate the historical, cultural and
    ethnic heritage of the City and the nation, or increase the com-
    munity's knowledge and understanding of critical issues," or
    "generate broad appeal and participation," or "instill civic
    pride," or "contribute to tourism," or "are identified as unique
    community events." A large menu of choices of great breadth!
    The support of those events does not come in the form of cash
    paid to the sponsoring organizations; it comes in the form of
    accounting transfers within the City's departments to defray
    such "typical event-related services" as police protection,
    clean up (including street sweeping), use of park event equip-
    ment, and the like.

    A wide array of non-profit organizations, indeed almost all
    of them, can participate. The only types of organizations

                                   4035
    excluded at the threshold are those that are receiving a special
    City benefit already, and religious organizations. As the pol-
    icy puts it, "events held in direct support of religious organi-
    zations" are not eligible for support.

    The parties spill a great deal of ink over whether the fund
    thus created is a forum and, if so, just what type of forum it
    is. The purpose of that liquid flood is to decide just what
    restrictions the City can place upon speech, if any. Of course,
    it is a commonplace that the government can have, and spon-
    sor, a restrictive viewpoint, if it is the speaker. See, e.g., Rust
    v. Sullivan, 500 U.S. 173, 192-200, 111 S. Ct. 1759, 1771-76,
    114 L. Ed. 2d 233 (1991); Downs v. Los Angeles Unified
    School District, 228 F.3d 1003, 1013-16 (9th Cir. 2000); cf.
    Nat'l Endowment for the Arts v. Finley, 524 U.S. 569, 586-88,
    118 S. Ct. 2168, 2178-79, 141 L. Ed. 2d 500 (1998) (grants
    need not be entirely neutral); Regan v. Taxation With Repre-
    sentation, 461 U.S. 540, 544-51, 103 S. Ct. 1997, 2000-04, 76
    L. Ed. 2d 129 (1983) (government can choose not to subsidize
    lobbying with tax exemptions). On the other hand, if some
    sort of forum is created, the government cannot "discriminate
    against speech on the basis of its viewpoint." Rosenberger v.
    Rector & Visitors of the Univ. of Va., 515 U.S. 819, 829, 115
    S. Ct. 2510, 2517, 132 L. Ed. 2d 700 (1995). Rather, the gov-
    ernment's restrictions on speech must remain reasonable and
    viewpoint neutral. See Lamb's Chapel v. Center Moriches
    Union Free Sch. Dist., 508 U.S. 384, 392-93, 113 S. Ct. 2141,
    2147, 124 L. Ed. 2d 352 (1993). Not surprisingly, that
    includes religious speech and viewpoints. Cf. Widmar v. Vin-
    cent, 454 U.S. 263, 269, 277, 102 S. Ct. 269, 274, 278, 70 L.
    Ed. 2d 440 (1981) (content based restrictions on religious
    speech were not reasonable). The tour through the debates in
    this area is, and always has been, an extremely exciting excur-
    sion, but in the context of this case its relevance is equally
    exiguous. In fact, the policy at hand does not key on the view-
    point of the speaker at all.

    A careful reading of the policy makes it clear that what the
    City has decreed is that an event cannot directly benefit a reli-

                                   4036
    gious organization. So, for example, if a religious organiza-
    tion put on a perfectly secular play for the entertainment of
    the public -- say "Pygmalion" -- and derived some benefit
    from that, consideration for support would be precluded at the
    threshold. That would not, one presumes, be because of the
    viewpoint of George Bernard Shaw or of the performers of
    the play. It would be because a religious organization was
    deriving direct support from it. On the other hand, if a secular
    non-profit organization put on a prayer program, even one
    solely and generally Christian, consideration for support
    would not be precluded. Certainly it could not be said that
    something as broad as a general chiliastic prayer would
    directly support any religious organization. Again, the lack of
    a threshold exclusion would not depend on the viewpoint of
    the speakers. In short, I think it is a mistake to fassick in the
    fields of freedom of speech. What we must do, instead, is turn
    our gaze on the hostility to religious organizations which is
    expressed by the policy in question.

    As I have written before, "the Supreme Court[has]
    reminded us that laws of general application do not run afoul
    of the religion clauses; rather, those clauses assume and
    require an evenhanded neutrality both toward and on behalf
    of religious belief." Goehring v. Brophy, 94 F.3d 1294, 1306-
    07 (9th Cir. 1996) (Fernandez, J., concurring); see also
    Walker v. San Francisco Unified Sch. Dist., 46 F.3d 1449,
    1470 (9th Cir. 1995) (Fernandez, J., concurring and dissent-
    ing) ("I . . . applaud the majority's overall analysis, which
    ultimately looks upon the establishment clause as a kind of
    equal protection clause . . . ."). But hostility is obviously
    anathema where neutrality is required. As the Supreme Court
    has cogently put it, "government may not . . . impose special
    disabilities on the basis of religious views or religious status."
    Employment Div., Dept. of Human Resources v. Smith , 494
    U.S. 872, 877, 110 S. Ct. 1595, 1599, 108 L. Ed. 2d 876
    (1990). While government regulations and programs may
    interfere with the particular beliefs of some citizens, the reli-
    gion clauses do not bar "application of a neutral, generally

                                   4037
    applicable law to religiously motivated action." Id. at 881,
    110 S. Ct. at 1601. Of course, it must be admitted that some
    laws which affect religion might be unconstitutional, even
    though they are neutral, but that is simply because they would
    be unconstitutional anyway -- for example, a law restricting
    religious speech may well be unconstitutional because it is
    restricting speech, and it would be just as unconstitutional if
    the speech were not religious. See id. at 881-82, 110 S. Ct. at
    1601-02; see also Board of Educ. v. Barnette, 319 U.S. 624,
    634-642, 63 S. Ct. 1178, 1183, 1187, 87 L. Ed. 1628 (1943)
    (Jehovah's Witnesses children are not required to participate
    in flag salute. That does not "turn on one's possession of par-
    ticular religious views;" it turns on First Amendment limita-
    tions which preclude governmental invasion of "the sphere of
    intellect and spirit."). But I digress. The law at hand is not
    some apparently benign enactment that happens to touch on
    someone's religious beliefs. It is, instead, a law aimed directly
    at religious organizations as such.

    In that respect, the policy in question is more like the law
    that confronted the Supreme Court in Church of the Lukumi
    Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 113 S. Ct.
    2217, 124 L. Ed. 2d 472 (1993). There the target was really
    a single religion, but the government is no more benignant
    when it targets all religions. As Justice Kennedy said:

           In addressing the constitutional protection for free
          exercise of religion, our cases establish the general
          proposition that a law that is neutral and of general
          applicability need not be justified by a compelling
          governmental interest even if the law has the inci-
          dental effect of burdening a particular religious prac-
          tice . . . . A law failing to satisfy these requirements
          must be justified by a compelling governmental
          interest and must be narrowly tailored to advance
          that interest.

    Id. at 531-32, 113 S. Ct. at 2226. And the Court went on to
    point out that:

                                   4038
           A law burdening religious practice that is not neu-
          tral or not of general application must undergo the
          most rigorous of scrutiny. To satisfy the commands
          of the First Amendment, a law restrictive of religious
          practice must advance "interests of the highest
          order" and must be narrowly tailored in pursuit of
          those interests.

    Id. at 546, 113 S. Ct. at 2233 (citation omitted).

    Of course, I recognize that the policy in question here does
    not impose a direct restriction on religious organizations; it
    simply denies a benefit that is available to virtually everyone
    else. To my mind, that is a distinction without a difference. It
    may well be that the government has a great deal of discretion
    when it grants benefits, and also attempts to distance itself
    from religion and the religious traditions of the American
    people. But as the Supreme Court has said, any state interest
    "in achieving greater separation of church and State than is
    already ensured under the Establishment Clause of the Federal
    Constitution . . . is limited by the Free Exercise Clause . . . ."
    Widmar, 454 U.S. at 276, 102 S. Ct. at 277.

    While it has never been called upon to rule directly on the
    question, the Court has often expressed its incredulity at any
    suggestion that the Establishment Clause prohibits the exten-
    sion of general public benefits to religious groups. That feel-
    ing is a recurrent theme. As the Court has often stated in
    varying ways, were it otherwise, "a church could not be pro-
    tected by the police and fire departments, or have its public
    sidewalks kept in repair." Roemer v. Board of Pub. Works,
    426 U.S. 736, 747, 96 S. Ct. 2337, 2345, 49 L. Ed. 2d 179
    (1976); see also Widmar, 454 U.S. at 274-75, 102 S. Ct. at
    277; cf. Walz v. Tax Comm'n, 397 U.S. 664, 672-75, 90 S. Ct.
    1409, 1413-15, 25 L. Ed. 2d 697 (1970) (granting of tax
    exemptions to churches does not violate the Establishment
    Clause any more than granting police and fire protection
    does).

                                   4039
    But the City in its anxiety to avoid establishment problems
    has done just what the neutral demands of the religion clauses
    refuse to allow; it has run afoul of the Free Exercise Clause
    while it was at it. The City has done something very like
    denying police and fire protection to churches. It has allowed
    all other non-profit organizations (except those that it already
    subsidizes) to cross the threshold that gives them the possibil-
    ity of participation in a fund which allows the use of city
    facilities and services at no additional cost, but it has excluded
    religious organizations from those benefits. It is as if the City
    charged religious organizations, and only religious organiza-
    tions, when firemen or policemen came to their facilities, or
    for the repair of sidewalks, or for the use or cleaning of road-
    ways. That cannot be and is not constitutional. As the
    Supreme Court said over 50 years ago:

          [S]uch is obviously not the purpose of the First
          Amendment. That Amendment requires the state to
          be a neutral in its relations with groups of religious
          believers and non-believers; it does not require the
          state to be their adversary. State power is no more to
          be used so as to handicap religions, than it is to favor
          them.

    Everson v. Board of Educ., 330 U.S. 1, 18, 67 S. Ct. 504, 513,
    91 L. Ed. 711 (1947). The City's policy does handicap reli-
    gious organizations by refusing to treat them in the way that
    it treats all other non-profit organizations.1
    _________________________________________________________________
    1 I recognize that for us in the lower courts Lemon v. Kurtzman, 403 U.S.
    602, 91 S. Ct. 2105, 29 L. Ed. 2d 745 (1971), still walks, or stalks, the
    land. See Bollard v. California Province of the Soc'ty of Jesus, 196 F.3d
    940, 948 (9th Cir. 1999); cf. Lamb's Chapel, 508 U.S. at 398 400, 113
    S. Ct. at 2149-50 (Scalia, J., concurring). But the Lemon test surely does
    not save this ordinance, for, if anything, the ordinance does inhibit religion
    by discriminating against religious organizations. See Lemon, 403 U.S. at
    612, 91 S. Ct. at 2111. And if we ask, instead, if the Establishment Clause
    would be violated were it not for the threshold discrimination provision,
    the answer is no. The policy, in general, has a secular purpose, would not

                                   4040
    Religious organizations are not cankers on an otherwise
    healthy body politic. On the contrary, they tend to infuse us
    with all that is best in human nature and history, and they help
    prevent our democracy from becoming a kakistocracy. They
    should not be treated with hostility out of bigotry, 2 or out of
    misguided constitutional affection, or out of fear of offending
    someone. They should be treated with neutrality. The
    Supreme Court has said that government can sometimes act
    with a "benevolent neutrality." Walz, 397 U.S. at 676, 90
    S. Ct. at 1415. It has never suggested that government can act
    with a malevolent one. The blessings of our Constitution do
    not stop short of religion.

    Thus, I respectfully dissent.

    _________________________________________________________________

    KLEINFELD, Circuit Judge, with whom WARDLAW, Cir-
    cuit Judge, joins, Dissenting:

    I respectfully dissent. Before denying a permanent injunc-
    tion, the district court should have obtained additional evi-
    dence and made findings of fact.
    _________________________________________________________________
    primarily advance or inhibit religion, and would not entangle government
    with religion. Id. at 612-13, 91 S. Ct. at 2111. Nor, by the way, is there
    any "realistic danger that the community would think that the [City] was
    endorsing religion." See Lamb's Chapel, 508 U.S. at 395, 113 S. Ct. at
    2148. Finally, the statement in the application for benefits form that
    requires an applicant to acknowledge the City's contribution of services
    makes no difference because every recipient of those services must so
    acknowledge. If the statement did present a problem, I hardly think that
    the City can place a tarnkappe over the policy's reification of hostility at
    the threshold by adding that requirement. The concrete fact of improper
    discrimination against religious organizations remains quite visible.
    2 See Mitchell v. Helms, 530 U.S. 793, _______, 120 S. Ct. 2530, 2551-52,
    147 L. Ed. 2d 660 (2000).

                                   4041
    Tucson has a city park and band shell, generally available
    to all organizations, including religious organizations, for
    their events. For most non-profit organizations, if the event
    serves any of a broad range of civic goals, the city waives
    charges that it would otherwise impose for in-kind services.
    The charges are for such municipal services as "refuse con-
    tainers, street sweeping, . . . police services . . ." and use of
    the sound system at the band shell. The city does not write
    checks to the organizations; what is at issue is whether it
    demands checks from them. The city's written policy denotes
    three situations where the charges are not waived: (1) events
    hosted by organizations the city otherwise funds; (2) events
    put on by organizations allowed to occupy city property with-
    out paying rent; and (3) "events held in direct support of reli-
    gious organizations."

    The record includes results of applications to waive charges
    for only one of the preceding years, 1995-96. The funding
    record shows that requests were made for 26 events, and
    granted for 23. The ones turned down were the "Casa Car
    Show," the "Sister Cities Fund Raiser," and the "Fun Day In
    the Park." Nothing in the record says why any of these were
    rejected. It may be that the car show was commercial, and that
    the sister cities and fun day events were sponsored by organi-
    zations otherwise funded by the city or using city offices rent-
    free. We simply do not know. Nor do we know what the city
    means by its exclusion of funding for "events in direct support
    of religious organizations" or how the exclusion applies here.
    The majority believes that the very fact that some applications
    are denied is enough to decide this case.1  But this is not
    enough.

    What we do not know matters to the outcome. For that rea-
    son, we should vacate the judgment and remand for an evi-
    dentiary hearing prior to issuance or denial of a permanent
    injunction. This record allows for either of two possibilities
    _________________________________________________________________
    1 Maj. Op. at 4028.

                                   4042
    requiring opposite results. The first possibility is that the city
    is selective in what events it waives fees for, assuring that the
    events advance a viewpoint which the city endorses. If so, the
    city is entitled,2 and probably required, to deny the waivers for
    religious events. Or it may be that everyone gets a waiver for
    these routine municipal expenses except for events that pro-
    mote religion. If so, that violates the core principal of neutral-
    ity required by the First Amendment,3 and the plaintiffs are
    entitled to prevail.

    The majority opinion says we must "draw lines, sometimes
    quite fine, based on the particular facts of [this] case" to con-
    clude that "this case involves significant factual differences
    from Rosenberger."4 How would we know enough to draw
    fine lines based on the facts? We do not know the facts. There
    are no findings of fact. For all we know, the city is entirely
    unselective in practice. If so, the fund takes on a character
    similar to that of the quasi-public forum in Rosenberger. The
    government cannot restrict access to a public forum on
    account of the speaker's religious message.5 It makes no dif-
    ference that municipal expenses and personnel are involved in
    maintaining the space. Government disbursements to organi-
    zations supporting a particular sectarian religious viewpoint
    are required by neutrality rather than barred by the Establish-
    ment Clause under Rosenberger,6  and held not to violate the
    Establishment Clause in Mitchell v. Helms. 7 Discriminating
    _________________________________________________________________
    2 See Nat'l Endowment for the Arts v. Finley, 524 U.S. 569, 586-88
    (1998).
    3 See Mitchell v. Helms, 120 S. Ct. 2530, 2541-42 (2000); Rosenberger
    v. Rector & Visitors of the Univ. of Va., 515 U.S. 819, 839 (1995); see
    also, Rosenberger, 515 U.S. at 846 (O'Connor, J. concurring) (summariz-
    ing principle of neutrality toward religion).
    4 Maj. Op. at 4027.
    5 See Rosenberger, 515 U.S. at 829-30.
    6 See id.
    7 See 120 S.Ct. 2530, 2541 (2000) ("If the religious, irreligious, and
    areligious are all alike eligible for governmental aid, no one would con-
    clude that any indoctrination that any particular recipient conducts has
    been done at the behest of the government.").

                                   4043
    against religious institutions by denying them a non-
    discretionary benefit available to a broad class that otherwise
    includes them violates the Free Exercise and Equal Protection
    Clauses.8 Our Constitution no more permits a government
    policy of anti-clericalism than favoritism.9 The Free Exercise
    Clause is not mere surplusage. Making religious groups pay
    for what everyone else gets for free is like charging the
    churches but no one else when they call for police or fire
    department assistance.10 Such interference with the free exer-
    cise of religion, by imposing a discriminatory burden, would
    be as plainly unconstitutional as government selection of pre-
    ferred churches to whose treasuries it would contribute.

    If the government makes a public forum available without
    discriminating against religious speech there could also not be
    any appearance of endorsement. A non-discretionary govern-
    ment benefit that goes to all non-profits does not violate the
    Establishment Clause if it includes religious institutions.11
    Neutrality eliminates the potential establishment clause issue.12
    Nor would there be any endorsement inference. The informed
    observer would know that all non-profits receive the fee
    waiver and that there is nothing special about the fact that the
    Gentalas' organization received the waiver. Passersby who
    see municipal employees at the municipal band shell during
    the prayer event would no more infer a theological endorse-
    _________________________________________________________________
    8 See id.; see also,Widmar v. Vincent, 454 U.S. 263, 274-75 (1981).
    9 See, e.g., Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah,
    508 U.S. 520, 531-32 (1993); Employment Div., Dept. of Human
    Resources v. Smith, 494 U.S. 872, 877 (1990); Everson v. Bd. of Educ.,
    330 U.S. 1, 18 (1947).
    10 Cf. Roemer v. Board of Pub. Works, 426 U.S. 736, 747 (1976).
    11 See Mitchell, 120 S.Ct. at 2541; Rosenberger, 515 U.S. at 829-30;
    Walz v. Tax Comm'n, 397 U.S. 664, 672-75 (1970) (finding constitutional
    statute exempting from taxation real property used exclusively for reli-
    gious purposes).
    12 See id.

                                   4044
    ment than they would if they were to see municipal firemen
    pointing hoses at a church fire.13

    On the other hand, it may be that the city is selective, rou-
    tinely denying the waiver to events or groups it feels do not
    "celebrate and commemorate the historical, cultural and eth-
    nic heritage of the City" or do not "instill civic pride." If so,
    the waiver program would not be a public forum at all.
    Instead, it would be like the grant program in Finley -- dis-
    cretionary government funding subject to selective criteria.14
    In that case the city could properly exclude religious organi-
    zations from the waiver program, regardless of whether the
    waivers would violate the Establishment Clause, simply
    because the religious nature of the events did not promote the
    city's message of inclusion. And granting a waiver to the
    Gentalas under these facts would likely violate the Establish-
    ment Clause.15

    Because the record does not enable us to base a decision on
    the necessary factual predicate, we should vacate and remand
    for an evidentiary hearing and findings of fact. Therefore I
    dissent.
    _________________________________________________________________
    13 The majority notes that "the Fund supported other events sponsored
    by religiously-affiliated organizations when the events did not directly
    benefit the groups themselves, and events with religious themes sponsored
    by secular organizations" Maj. Op. at 4011 (footnote omitted). How is the
    passerby or even the "informed observer" to know the fine distinction
    apparently made (or at least attributed by the majority) between Gentala's
    request for funding and the city's funding of a fishing clinic sponsored by
    the Aid Association for Lutherans (not "in direct support") or a depiction
    of the birth of Christ (not "sponsored by a religious group")?
    14 See Finley, 524 U.S. at 586-88.
    15 See Santa Fe Indep. Sch. Dist. v. Doe, 120 S. Ct. 2266, 2278 (2000);
    Lamb's Chapel v. Center Moriches Sch. Dist., 508 U.S. 384, 395 (1993);
    see also, Capitol Square Review & Advisory Bd. v. Pinette, 515 U.S. 753,
    773-74 (1995) (O'Connor, J., concurring in part and concurring in the
    judgment) (discussing endorsement inquiry in Establishment Clause
    cases).

                                   4045

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