Washington, D.C. on inauguration day who somehow had to alter his normal routine to avoid hearing speech he found offensive. Newdow has only alleged he watched the inauguration on television.  While he certainly has the right to visit the nation's capital, did he have the right to attend the inaugural ceremonies in person?  Probably not; nevertheless, Newdow's attempt to use the analytical framework applicable to religious displays on public properties simply does not work when the issue involves a speech that occurred months ago, thousands of miles away.
Finally, the requirement that a plaintiff's injury be more than abstract was recently highlighted in Arizona Civil Liberties Union v. Dunham, 112 F. Supp.2d 927 (D.Az.,2000).  There the district court found that town residents who felt unwelcome and excluded by the town's proclamation of "Bible Week" had standing to challenge the proclamation under the Establishment Clause.  At least one of the plaintiffs had received harassing and defamatory mail and phone calls after expressing her opposition to the proclamation.  Jd., at 934.  In finding that the plaintiffs had standing, the district court relied on Valley Forge and its progeny requiring direct contact with the challenged conduct. Jd., at 929.  Of significance to the instant case was the court's language distinguishing plaintiffs who resided in the town who were "directly and personally affected" by the proclamation with the abstract injury that would be suffered by
a person residing hundred miles away who read about the Bible Week Proclamation issued in Gilbert and found it offensive to his or her beliefs about the Constitution's mandate.
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