On May 7, 2010, the US Court of Appeals for the District of Columbia Circuit rejected an attempt to remove the phrase "so help me God" from the presidential oath. The challenge was brought by atheist Michael Newdow and several other groups, who claimed the phrase violates the Establishment Clause of the First Amendment. Newdow had unsuccessfully sought an injunction against use of the phrase and an inaugural prayer during the 2009 inauguration, and he also sought to block their inclusion in the 2013 and 2017 inaugural ceremonies. The court concluded that the "only apparent avenue of redress for plaintiffs' claimed injuries would be injunctive or declaratory relief against all possible President-elects and the President himself. But such relief is unavailable. ... [G]eneral injunctions are outside the judicial power."



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