believe strongly that Marsh was wrongly decided. But harm to plaintiffs ideological interests and personal beliefs, no matter how "grievous," cannot meet Article Ills injury-in-fact requirement. See Richardson. 418 U.S. at 177; Simon v. Eastern Kentucky Welfare Rights Ore.. 426 U.S. 26, 40 (1976).
C.     Plaintiffs Allegations of Stigmatic Injury are Insufficient to Establish Standing
Finally, plaintiff claims injury based on the "personal reproach" he allegedly suffered when the Senate chaplain offered a prayer declaring the Senate's "convictions in the Pledge [of Allegiance]." See Compl. at ^[ 91-93 (citing the prayer at issue). As noted above, plaintiff has filed a different lawsuit challenging the inclusion of the words "under God" in the pledge as unconstitutional under the Establishment Clause. See Compl. at ^ 90-91.
The United States does not read the chaplain's prayer - nor, we submit, can the prayer fairly be read - as an attempt to "demean" plaintiffs religious beliefs. But taking as true plaintiffs assertion that he felt "reproach" from the chaplain's words, such allegations of "stigmatic injury," the D.C. Circuit held in Kurtz. cannot, standing alone, establish injury-in-fact. See Kurtz. 829 F.2d at 1141 (in rejecting claim of stigmatic injury to atheists as a basis for standing, noting that "allegations of stigmatic injury will not suffice to link a plaintiff personally to the conduct he challenges unless ... the plaintiff personally has been denied a benefit"). Moreover, any "injury" resulting from the chaplain's prayer is neither "traceable" to, nor redressable through, any action of the named defendants (none of whom is the Senate chaplain). See Lujan. 504 U.S. at 560-61. Accordingly, for all of these reasons, plaintiffs claims should be dismissed for lack of standing.
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