The Supreme Court’s recent decision in Town
of Greece v. Galloway addressed the constitutionality, under the Establishment
Clause of the First Amendment, of prayers offered before town meetings. The
split was 5-4 upholding the practice, with the dissenters arguing that the
practice effectively established Christianity as the town’s religion. The
dissent indirectly touched upon a curious question: Is “Christianity” a single
According to the dissents of Justices Breyer and Kagan, all
Christians, including Catholics and all stripes of Protestants, are in fact a single religion. See
Breyer op. at 4 (“a single denomination”), 4 (“a single religion”), 6 (“a
single faith”); Kagan op. at 2 (“only one faith”), 6, 9 n.2 (“a single
religion”), 18 (“a single creed”), 19 (“one (and only one) faith”); cf.
Kagan op. at 14 (acknowledging clergy came from both “Protestant and Catholic
churches”). I don’t know if this reflects theological ignorance or laziness, or
if it’s just easier to argue that there’s an “establishment” if you treat a
potpourri of distinct religious professions as monolithic rather than diverse.
In any event, I’m sure it would be news to the various figures behind the
historic doctrinal and ecclesial struggles between Orthodox and Catholic, between Catholic and Protestant, and
among various Protestant denominations, that in fact they were all “a single denomination”.