Creatore v. Trumbull
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Celebrating the Season on the Green
The public green in the town of Trumbull, Connecticut is used year after year to host a wide variety of events, both religious and secular, including an annual art fair, an international food festival, Veteran’s and Memorial Day commemorations involving religious content and the laying of a wreath, and a National Prayer Day. For many years, a Menorah and a Christmas tree have also stood together on the green during the holiday season.
In November 1993, Donald Creatore and the Knights of Columbus, a Catholic fraternal organization, requested permission from town officials to place a nativity display on the public green next to the town hall of Trumbull, Connecticut. Even though there was already a Christmas tree and a Menorah on display, town officials denied their request, claiming that the application was too late.
Wasting no time, Creatore submitted an application to display the nativity scene for the next holiday season in early 1994. This time, he received a letter from town officials granting permission. Creatore and the Knights submitted plans to the Town Building Official for approval, which was approved in August. Creatore and the Knights made eager plans to place the display.
The city censors a Christmas crèche
Three days before the display was set to be placed—and seven months after permission was granted by the town—officials called Creatore to revoke his permission. Creatore was told that he would no longer allow the display because it communicated a religious message, and that he was concerned that other individuals might oppose it.
All the while, the Christmas tree lit up the green.
Becket defends diversity of displays
Becket stepped in and took their case to court. The district court ruled against Creatore and the Knights, and after their appeal, the Second Circuit Court of Appeals also ruled against them. Finally the U.S. Supreme Court protected their right to display a crèche.