administered according to law.'"  Valley Forge, 454 U.S. at 482-83, 102 S.Ct. at 764. The Supreme Court has similarly rejected the notion that a plaintiff's commitment to the principles of separation of church and state confer standing because "standing is not measured by the intensity of the litigant's interest or the fervor of his advocacy."  Id., at 486, 102 S.Cfc. 766.
Newdow sidesteps the requirement that he have direct contact with the challenged conduct, and instead focuses on the importance of his Establishment Clause claim.  However, the requirement of standing "focuses on the party seeking to get his complaint before the court and not on the issues he wishes to have adjudicated."  Flast v. Cohen, 392 U.S. 83, at 99, 88 S.Ct. 1942, at 1952 (1968).
Newdow may argue that his constitutional claim justifies an exception to the rigid requirement that he show an injury in fact because it may be difficult, if not impossible, for anyone to show an injury in fact.  The Supreme Court rejected this reasoning in Valley Forge when it held that:
Implicit in the foregoing is the philosophy that the business of the federal courts is correcting constitutional error, and that "cases and controversies" are at best merely convenient vehicles for doing so and at worst nuisances that may be dispensed with when they become obstacles to that transcendant endeavor.  This philosophy has no place in our constitutional scheme. . . .But "[t]he assumption that if respondents have no standing to sue, no one would have standing, is no reason to find standing."
454 U.S. at 489, 102 S.Ct. at 767 (internal citations omitted).
Similarly, even though no person may be able to show that they suffered an injury in fact because of the recitation of a
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