money to remove the cross — constitutes both governmental support for and maintenance of the cross. These affirmative actions provide a “fairly traceable connection” between the injury in fact and the government’s conduct. See Desert Outdoor Adver. v. City of Moreno Valley, 103 F.3d 814, 818 (9th Cir.1996). Second, a showing of affirmative action by the government is not required to establish the causation element of standing in order to challenge the constitutionality of a religious display on government land when the government has not opened up the area to other religious displays. Numerous courts have held that plaintiffs have standing to challenge the constitutionality of religious symbols neither erected nor maintained by the government. See, e.g., Books, 235 F.3d at 295-301 (<HOLDING>); Gonzales v. N. Township, 4 F.3d 1412, 1414-17
holding where exempt organization was in possession of real property under land contract obligating organization to pay the purchase price and use land for exempt purpose the association was the owner of the land within the meaning of the statute holding that plaintiffs have standing to challenge the constitutionality of monument inscribed with the ten commandments placed on government land by private organization even though government did not maintain the structure 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 the sale of 440 square feet of a city park containing a ten commandments monument to a private organization was valid because there were no unusual circumstances holding the government waived its argument on appeal that the defendant did not have standing to challenge a search when it failed to raise the argument to the district court