Courts Mistakenly Cross-Out Memorials: Why the Establishment Clause Is Not Violated By Roadside Crosses

 In Notes

Mollie Mishoe lost her husband in a fatal car accident on August 3, 2007, a few months before their fiftieth wedding anniversary. For Mollie and her children, the grieving process included erecting two roadside crosses at the site of the accident, to memorialize their beloved husband and father, Bill Mishoe. This location was the last spot Bill was alive, and the cross memorial is a place the family goes to remember and feel close to him again. The Mishoes have become spiritually connected to the site of the accident, and to the cross memorial they have placed there. This is the place where they can still feel Bill’s presence—a place where they can heal. For them, this memorial has become “sacred[,] but not necessarily religiously.”

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