the law.  At issue here is a religious speech delivered by a guest invited to President Bush's inauguration.
A Presidential proclamation has no force of law and thus cannot form the basis of an Establishment Clause claim. In Zwerliag v. Reagan, 576 F. Supp. 1373 (C.D. Ca. 1983) a group of Christian clergymen, two Buddhist laymen, an atheist, and an agnostic filed suit challenging President Reagan's proclamation of 1983 as the year of the Bible. The court granted the President's Motion for Judgment on the Pleadings on the ground that such a proclamation is not a law within the meaning of the Establishment Clause.  Like Congressional Resolutions honoring a specific person for heroic deeds or for contributions to science or world leadership. Presidential proclamations do not
exact particular behavior from any individual.  Nor does it authorize the President to exact any particular behavior from any individual.  It certainly imposes no penalties or sanctions of any kind.  It is not a "law."
Jd., at 1378.
In concluding that a Presidential proclamation is not a "law" the court emphasized the distinction between speaking on a subject that involves a religious text and legislating on religious matters.  Jd., at 1378.  Similarly, speech about religious matters, whether given by the President or by Rev. Graham at the President's inauguration, is not a "law" within the meaning of the Establishment Clause.
If plaintiff's sweeping view of the Establishment Clause is correct, then certainly every time the President asks God to bless America in a State of the Union address, he is violating
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