United States Court of Appeals - 7th Circuit 1992, in the case of Doe v. Small, 964 F.2d 611, 618 (7th Cir. 1992), stated:

"The Supreme Court has refused to find the Establishment Clause to be a sufficiently compelling interest to exclude private religious speech even from a limited public forum created by the government."

¹ 1992.  Doe v. Small, 964 F.2d 611, 618 (7th Cir. 1992).  Jay Sekulow, Letter to Mayors (Virginia Beach, VA: American Center for Law and Justice, November 17, 1992), p. 1.