freely using public land. In the case most analogous to the situation at bar, SCSC, the Ninth Circuit made short thrift of defendant City of Eugene’s standing arguments. Ruling on the constitutionality of a latin cross situated in a public park, the Ninth Circuit disposed of a challenge to plaintiffs standing in a footnote: “As a threshold matter, we note that [plaintiff organization] is composed of local citizens who have standing to bring this challenge because they alleged that the cross prevented them from freely using the area.” SCSC, 93 F.2d at 619 n. 2. Here, Buono will not travel on Cima Road and Schwartz cannot enjoy his travels through the Preserve due to the presence of the cross. This is sufficient to constitute injury in fact. Compare City of St. Charles, 794 F.2d at 268 (<HOLDING>). b. Causation The government contends that the
holding that plaintiffs have standing to challenge the constitutionality of the presence of a cross in a city park even though the cross was neither erected nor financially maintained by the government holding that plaintiffs have standing to assert establishment clause violation because in part a cross led plaintiffs to alter their behavior holding that inclusion of cross on government seal violated federal establishment clause holding that the presence of a cross on the city insignia did not violate the establishment clause holding no violation of federal establishment clause