The phrase “so help me God” can remain a part of the U.S. naturalization oath that immigrants to the United States recite upon becoming U.S. citizens, the U.S. Court of Appeals for the First Circuit has ruled.

Atheist Olga Paule Perrier-Bilb, an immigrant from France, sued the United States back in 2017 arguing that the four short words “so help me God” at the end of the naturalization oath constituted an unconstitutional infringement of the First Amendment.

The First Amendment states, “Congress shall make no law respecting an establishment of religion.”

The three-judge panel on the First Circuit disagreed with Perrier-Bilb’s argument. “We follow the Supreme Court’s most recent framework and apply American Legion’s presumption of constitutionality to the phrase ‘so help me God’ in the naturalization oath,” the court held. “We consider the inclusion of similar words to be a ceremonial, longstanding practice as an optional means of completing an oath.” 

In other words, because the oath, and the inclusion of the phrase ‘so help me God,’ has been the longstanding practice of the United States, it deserves to be viewed as presumptively constitutional.

The Naturalization Oath of Allegiance to the United States of America is composed as follows:

“I hereby declare, on oath, that I absolutely and entirely renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty, of whom or which I have heretofore been a subject or citizen; that I will support and defend the Constitution and laws of the United States of America against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; that I will bear arms on behalf of the United States when required by the law; that I will perform noncombatant service in the Armed Forces of the United States when required by the law; that I will perform work of national importance under civilian direction when required by the law; and that I take this obligation freely, without any mental reservation or purpose of evasion; so help me God.” 

It seems some people won’t be satisfied until every last vestige of referencing God in the public square is ruled unconstitutional and subsequently removed. Thankfully, for now the First Circuit has stopped that push.

The case is Olga Paule Perrier-Bilb v. United States


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