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As Douglas Laycock of the University of Texas puts it, the lower court "created the worst of both worlds: the prayer is imposed on people who object and the state is censoring the content of the prayer".
Puritanism ranged from hostility to the content of the Prayer Book and "popish" ceremony, to a desire for church governance to be radically reformed.
The majority affirmed language in a prior 1983 opinion, Marsh v. Chambers, that "the content of the prayer is not of concern to judges" if "there is no indication that the prayer opportunity has been exploited to proselytize or advance any one, or to disparage any other faith or belief".
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The court said in a 5-4 decision that the content of the prayers is not significant as long as they do not denigrate non-Christians or try to win converts.
The contents of the prayer would be contingent upon the results of a vote that each respective school would hold.
The court also ruled on Wednesday that all of the expert testimony used during the initial trial to evaluate the content of the punk prayer will stand, denying the defendants' request to use alternative independent expert analysis.
The detail and content of the grass-roots prayer meetings is new.
At present, the chief priest of a shrine pronounces the norito on behalf of the worshipers, and the contents and wordings of the prayer may vary.
"Absent a pattern of prayers that over time denigrate, proselytize, or betray an impermissible government purpose," Justice Kennedy wrote, "a challenge based solely on the content of a prayer will not likely establish a constitutional violation".
Of course, this liturgy -- harsh, searching, but also cleansing and awe-inspiring -- is said only once per year, no doubt because the rabbis understood that we would be overwhelmed if every day this were the primary content of Jewish prayer.
These weren't complaints about the inappropriateness of Warren being chosen to deliver the invocation, or even about the content of Warren's prayer.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com