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Loudoun County, Virginia, is a lush expanse of fields and rolling hills at the edge of the burgeoning Washington metropolis. Its growing population is heavily white, affluent, and Christian. In 1993, a year after the Supreme Court's decision in Lee v. Weisman, the county not surprisingly became an arena for the resurgence of a familiar prayer in America's public schools.

This Article tells the story of the Loudoun County graduation prayer litigation, and tries to set the case in context. It ponders doctrinal questions from an unabashedly separationist perspective, but it offers words of caution for both sides in the debate. For while the notion of officially promoted group prayer for public school students raises Establishment Clause alarms that are as urgent today as they were a generation ago in Engel v. Vitale, the current wave of school prayer controversy also involves questions of individual free speech that are only now receiving fuller treatment in the courts and the academic literature.