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A short walk up a small hill from the World War II Memorial on the National Mall in Washington, D.C., stands a modest display of the prayer President Franklin Delano Roosevelt gave on the radio late in the evening of June 6, 1944, following the longest day of fierce combat between Allied troops and Nazi forces on Normandy’s beaches. As Americans heard reports of the invasion throughout the day on June 6, the White House prepared for FDR’s radio prayer that night by releasing the text of it for publication in the evening editions of their newspapers, so people could pray along with the president. Historians estimate that 100 million Americans tuned in to his broadcast (the total U.S. population at that time was 138.4 million people). Indeed, this may have been the largest audience for one prayer in history. (You can find the full text of it here.)
Before he prayed, Roosevelt explained that when he had addressed the nation the night before about the Allied victory in reclaiming Rome, he knew that the Allied invasion forces were on their way from England to the Normandy coast. Obviously, he could not speak then about it until after the invasion was well underway. But now, at the end of the first full day of battle, with the outcome very much in doubt, Roosevelt led the nation in prayer.
Roosevelt, an Episcopalian, had written the prayer himself with the help of his daughter Anna and her husband, John Boettiger. FDR opened by asking for God to help the Allied forces liberate the suffering people of Europe from their oppressors:
Almighty God: Our sons, pride of our Nation, this day have set upon a mighty endeavor, a struggle to preserve our Republic, our religion, and our civilization, and to set free a suffering humanity. Lead them straight and true; give strength to their arms, stoutness to their hearts, steadfastness in their faith.
The prayer reveals a president walking through the uncertainty and risk of this massive invasion, which could have ended in cataclysmic failure. Roosevelt appealed to God for victory by pointing to America’s proper motives for the invasion – to free the people of Europe from Nazi oppression, and not for “the lust of conquest.”
FDR also saw it as appropriate for him as president to ask Americans to continue to pray over the upcoming weeks for God’s help to win the war:
Many people have urged that I call the Nation into a single day of special prayer. But because the road is long and the desire is great, I ask that our people devote themselves in a continuance of prayer. As we rise to each new day, and again when each day is spent, let words of prayer be on our lips, invoking Thy help to our efforts.
He ended the prayer asking God for victory against the enemy and to bring peace to the world:
With Thy blessing, we shall prevail over the unholy forces of our enemy. Help us to conquer the apostles of greed and racial arrogancies. Lead us to the saving of our country, and with our sister Nations into a world unity that will spell a sure peace a peace invulnerable to the schemings of unworthy men. And a peace that will let all of men live in freedom, reaping the just rewards of their honest toil. Thy will be done, Almighty God. Amen.
Americans at that time reacted enthusiastically to the president’s radio prayer. Many families pulled the text of the prayer from their evening newspapers, huddled around their radios and recited it along with FDR. Millions of Americans spontaneously flooded their local churches and synagogues to pray for the Allied troops. The mayor of Philadelphia rang the Liberty Bell for the first time in a century. The Washington Post in 2020 quoted D-Day historian Alex Kershaw as writing, “[o]f all FDR’s radio broadcasts, I believe it was the most powerful. It united every American in their will to win, to support the war effort, to sacrifice [and] it beautifully encapsulated the Allied and U.S. mission in WWII.”
When the World War II Memorial opened on the National Mall on Memorial Day weekend, 2004, it did not include FDR’s prayer. Several years later, Senators Rob Portman, a Republican from Ohio, and Mary Landrieu, a Democrat from Louisiana, sponsored a bill to add the text of the prayer to the memorial.
That proposal drew opposition from groups that advocate for a strict separation of church and state. In November 2013, several of those organizations sent a letter to the leaders of the U.S. Senate Committee on Energy and Natural Resources, opposing the bill to add FDR’s prayer to the memorial. The letter argued that the prayer would be divisive and not reflect the views of those who fought but did not agree with it:
Instead of uniting us as we remember the sacrifice of those who served, the inclusion of this prayer on the memorial would be divisive: It would send a strong message to those who do not share the same religious beliefs expressed in this prayer that they are excluded and “not full members of the . . . community.”
Ignoring this criticism, Congress approved the measure, and President Barack Obama signed it into law in 2014. The FDR Prayer Plaque was added to the memorial grounds in December 2022 and formally dedicated as part of the memorial on June 6, 2023.
How did we come to a place where a prayer that united the country around the horrors of oppression became, in many Americans’ eyes, inappropriate to even display? Although there are, of course, many factors that contributed to this, the Supreme Court must bear some of the blame.
In 1971, approximately 27 years after FDR gave his prayer, the court decided the case of Lemon v. Kurtzman. In Lemon, the Supreme Court declared unconstitutional state programs in Pennsylvania and Rhode Island that reimbursed parochial schools, usually Catholic, for the cost of teachers’ salaries who taught non-religious subjects and non-religious items, like textbooks approved by the superintendent. The most enduring part of the Supreme Court’s Lemon decision was its three-part test to determine whether a challenged government action violated the establishment clause. According to this test, the government action (1) “must have a secular legislative purpose,” (2) “its principal or primary effect must be one that neither advances nor inhibits religion,” and (3) “the statute must not foster ‘an excessive government entanglement with religion.’”
This court’s test, which applied to any invocation of the establishment clause, reshaped Americans’ understanding of what was, and was not, permissible in the public square. Many found it arbitrary, especially given it was not rooted in any historical understanding of what government-established churches did and did not do. And to certain government officials, the Lemon test became a directive to search for religious expression in public life and root it out. Let us take FDR’s D-Day prayer. It fails the first prong of the Lemon test because there was no secular purpose for the president to pray for God’s blessing on the Allies’ military action. FDR’s prayer also failed Lemon’s second prong, because its primary effect obviously advanced religion. Two strikes, so FDR’s prayer is out under Lemon.
The Supreme Court tried to soften the harsh impact of Lemon in the 1980s by morphing it into an “endorsement test.” Under this analysis, if the government action endorses a particular religion, then it violates the establishment clause. The American Civil Liberties Union’s letter objecting to the inclusion of FDR’s prayer based its argument on this endorsement premise, contending that because there are people who do not agree with the religious sentiments of the prayer, its inclusion at the memorial would make them feel excluded as members of the American community.
But that argument proves too much. There are pacifists who object to the WWII Memorial because it celebrates war, even if it did not include FDR’s prayer. They could make the same argument, that the mere existence of a war-honoring memorial will make them feel excluded and not part of the American community. Why would it be acceptable for our government to alienate some Americans from our national community as long as it does not use religion to do so? The flip side of the endorsement test also makes people feel like they don’t belong. If we were to eliminate FDR’s prayer from the WWII Memorial because it endorses religion, that would alienate Americans of faith who support what FDR did.
So what is the correct constitutional test the courts should use in such cases? What strikes the balance between allowing something like FDR’s prayer in the public sphere while respecting America’s tradition of tolerance towards and inclusion of all faiths?
I believe the court struck the correct balance in the “praying coach case,” 2022’s Kennedy v. Bremerton School District (disclosure: the organization for which I work, First Liberty Institute, won this case before the Supreme Court). There, the majority ruled that it did not violate the establishment clause for a football coach with the Bremerton, Washington High School football team to go to midfield after a game to take a knee and pray.
The majority opinion, written by Justice Neil Gorsuch, found both the Lemon test and its “endorsement” update to be inadequate. Instead, the justices ruled that courts should evaluate a challenged governmental action based on our nation’s “historical practices and understandings”; in other words, whether the state was attempting to impose a particular religious view through the coercive legal mechanisms used by an established church. Based on this, government actions are unconstitutional which force people to attend services of an established church, deny government jobs to those not belonging to such a church, require all clergy to be licensed by the state church or lose their right to preach, and so forth. This test, which the lower courts are now applying, “distinguishes between real threat and mere shadow,” as Justice Arthur Goldberg wrote in 1963’s Abington School District v. Schempp.
Contrary to Lemon, such a test would not have barred FDR from praying for success on D-Day given that no government edict required people to tune in to his broadcast, people did not lose their government jobs for not listening to him pray, and no one needed to seek any sort of government permit to advocate an alternative message, regardless of how unpopular such a message might have been.
And this is for good reason: as the court would likely be aware, FDR followed a long tradition of Congress and presidents calling the nation to prayer in times of war. The Continental Congress issued at least 16 such proclamations between 1775 and 1783. For example, on May 15, 1776, George Washington issued an order, reminding his troops that
The Continental Congress having ordered, Friday, [May] 17 Instant to be observed as a day of “fasting, humiliation and prayer, humbly to supplicate the mercy of Almighty God, that it would please him to pardon all our manifold sins and transgressions, and to prosper the Arms of the United Colonies, and finally, establish the peace and freedom of America, upon a solid and lasting foundation”–The General commands all officers, and soldiers, to pay strict obedience to the Orders of the Continental Congress, and by their unfeigned, and pious observance of their religious duties, incline the Lord, and Giver of Victory, to prosper our arms.
During the Civil War, on March 30, 1863, President Abraham Lincoln responded to a Senate resolution and issued a proclamation calling for “a day of National prayer and humiliation,” to confess the nation’s collective sins, so that God would “pardon our national sins,” end the punishment of the civil war, and “restor[e] our now divided and suffering Country, to its former happy condition of unity and peace.”
On D-Day, Roosevelt, and millions of Americans instinctively felt that they needed divine help for victory. FDR could have urged Americans to simply send positive thoughts to the troops storming the beaches of Normandy. But most people realize how flimsy and inadequate that would have been. To many, appealing to the eternal God for help was the only natural thing to do.
So Roosevelt did just that, offering prayer, rooted in the historical practices of our nation, which asked Americans to join together absent any government coercion, punishment or penalties, to seek God’s help to liberate the millions suffering in Europe who could not free themselves. FDR’s actions did not violate the establishment clause.
