In
Perrier-Bilbo v. United States, (D MA, Sept. 28, 2018), a Massachusetts federal district court rejected a challenge to the inclusion of the phrase "so help me God" at the end of the oath of allegiance taken by those becoming citizens of the United States. Rejecting an Establishment Clause claim, the court said in part:
Like the ceremonial prayer in Town of Greece, the inclusion of "so help me God" in the oath of citizenship "is but a recognition that, since this Nation was founded and until the present day, many Americans deem that their own existence must be understood by precepts far beyond the authority of government to alter or define and that willing participation in civic affairs can be consistent with a brief acknowledgment of their belief in a higher power, always with due respect for those who adhere to other beliefs." ... The regulation providing for the phrase's inclusion in the naturalization oath does not violate the Establishment Clause.
The court also rejected free exercise, RFRA, equal protection and due process challenges. According to the court:
United States Citizenship and Immigration Services ("USCIS") offered her a private induction which would omit the words she finds offensive. Not surprisingly, she wishes to participate in the public ceremony with other new citizens and their families and friends. USCIS welcomed her at such a ceremony, assuring her she need not herself say those four words and her oath of allegiance and United States citizenship would nonetheless be fully valid.
