The chairman of the local Baha'i congregation concluded his prayer with "Allah-u-Abha," which loosely translates to "God the All-Glorious." A Jew offered a prayer speaking of "the songs of David, your servant." And a Wiccan priestess, mindful of her venue in the town of Greece, New York, thought that Athena and Apollo were apt deities to call upon.

But they were the exceptions. Almost every other "chaplain of the month" during a decade of town board meetings in this Rochester suburb was a Christian, and more often than not called on Jesus Christ or the Holy Spirit to guide the council's deliberations.

A federal appeals court said last year that such a "steady drumbeat" of Christian invocations violates the Constitution's prohibition against government endorsement of religion.