freely using the area in and around the park had standing.
In Carpenter v. City & County of San Francisco, 93 F.3d 627, (9th Cir. 1996), local citizens challenged the construction, on public property, of a 103-foot concrete and steel Latin cross. The decision did not address whether the plaintiffs had standing, but it is clear from the opinion that the plaintiffs lived or worked in the San Francisco area.
Similarly, in Ellis v. City of La Mesa, 990 F.2d 1518 (9th Cir. 1993) city residents challenged the constitutionality of displays of Latin crosses in city and county parks and on the city's official insignia.  Two of the individual plaintiffs alleged that they avoided using the parks because of the existence of the crosses.  The third plaintiff, who was "deeply offended" by the presence of the cross on the city's insignia, declined to invite business clients to his home to avoid offending business clients. 2 The district court found, and the Ninth Circuit affirmed, that the two plaintiffs had been injured by not being able to freely use the public parks, and the third plaintiff had curtailed his activities to avoid contact with the insignia displayed in his city.   Jd., at 1523.
The common thread that runs throughout all these cases is that plaintiffs who objected to the religious symbols lived or worked in the community where the symbol was displayed, and would see the symbol while going about their daily activities.  Here, of course, Newdow does not allege that he was a resident of
2    It is not at all clear from the decision how inviting business clients to the third plaintiff's home would expose them to the cross or the insignia.