states that, in order to avoid seeing the Ten Commandments monument, he 'would have to assume the special burden of altering [his] daily routine so as to avoid this direct and unwelcome contact.'
Id., at 297.
In finding that plaintiff Books had standing, the court relied on a long line of cases that granted standing to a plaintiff who demonstrated that he had "undertaken a special burden or has altered his behavior to avoid the offensive object."  Jd., at 299.  Those cases involved situations where the plaintiff had to avoid using a public park to avoid the religious object (Goazales v. North Township, 4 F.3d 1412, 1416-17 (7th Cir. 1993)); or altered his travel route (Harris v. City of Zion, 927 F.2d 1401, 1405 (7th Cir. 1991)). The Books court concluded that
a plaintiff may allege an injury in fact when he is forced to view a religious object that he wishes to avoid but is unable to avoid because of his right or duty to attend the government-owned place where the object is located.
Jd., 301.
The Ninth Circuit cases cited by Newdow have found standing in similar circumstances.  In American Jewish Congress v. City or Beverly Hills, 90 F.3d 379, 382 (9th Cir. 1996) plaintiffs had standing where they alleged that the city's permit process that allowed for the erection of a menorah in a city park interfered with their right to freely use and enjoy the park.
In Separation of Church and States Committee v. City of Eugene of Lane County, State of Oregon, 93 F.3d 617, 619, n. 2 (9th Cir. 1996) local citizens who alleged that the city's construction of a cross in a public park prevented them from
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