court rejected this argument, observing that the school board meetings are an integral part of the public school system; that the meetings are conducted on school grounds by school officials;
and that students regularly attend the meetings for a variety of reasons.  Zd., at 381.  The court then applied the three-part test developed in Lemon v. Kurtzman, 403 U.S. 602, 91 S.Ct. 2105 (1971) 5 and found that the prayers had no secular purpose.  In reaching this conclusion the court considered a variety of factors, including the content of the prayers, some of which called for divine guidance, contained veiled references to the Bible, or mentioned Jesus Christ.  Coles, at 384.  The actual content of the prayers was relevant only to the Court' s analysis of the "secular purpose" prong of the Lemon test.  Nothing in this opinion can be read to suggest that a prayer referring only to God, but not Jesus Christ, would have passed constitutional scrutiny.
Furthermore, the Presidential inauguration is not a public school and thus Coles has no relevance to the instant case.  If the Constitution permits President Bush (or a chaplain invited to the inauguration) to say a prayer, as the Magistrate Judge found, the precise content of the prayer should be irrelevant.  If, as Newdow argues and the Magistrate Judge suggests, a Christian prayer "goes over the line," the political process is best able to address President Bush's and/or Reverend Graham's alleged
5    A government-sponsored activity will not violate the Establishment Clause if (1) it has a secular purpose, (2) its principal or primary effect neither advances nor inhibits religion, and (3) it does not create an excessive entanglement of the government with religion.  Lemon, 403 U.S. at 612-613.