dissenting:
This has become a case of the tail wagging the dog.
I cannot join the majority opinion because it wags the tail while emaciating the body of the panel opinion. For the reasons expressed in the panel opinion, 939 F.2d 1207 (5th Cir.1991), I adhere to the view that Judge Herman trespassed upon O’Hair’s constitutional right to freedom of religion when he excluded her from jury service and jailed her for refusing to “affirm” without first proposing that she make a non-religious, conscious-binding declaration of a commitment to tell the truth. And because there is not only a likelihood of recurrence, but a statistical certainty that O’Hair and members of the Society of Separationists will again be summoned for jury duty before Judge Herman, I find no jurisdictional impediment to their bringing this lawsuit to challenge Judge Herman’s practice.
I.
The undercurrent of the standing requirement is the notion that courts should only adjudicate those cases in which the plaintiffs have a “ ‘personal stake in the outcome in order to assure that concrete adverseness which sharpens the presentation of issues’ necessary for the proper resolution of constitutional questions.” City of Los Angeles v. Lyons, 461 U.S. 95, 103 S.Ct. 1660, 1665, 75 L.Ed.2d 675 (1983) (quoting Baker v. Carr, 369 U.S. 186, 204, 82 S.Ct. 691, 703, 7 L.Ed.2d 663 (1962)). The plaintiffs in this “case” have a personal stake in the outcome and the constitutional issues presented are razor sharp: the plaintiffs are atheists who object to the mingling of religion in governmental activities. They brought this lawsuit based upon the practice employed by Judge Herman of the Travis County Court — on more than one occasion1 — requiring that prospective jurors make an “affirmation.” Whatever one might think of the constitutionality of Judge Herman’s practice, compare Society of Separationists, 939 F.2d at 1215-17 (majority opinion) with id. at 1220-24 (Garwood, J., dissenting), no one should doubt that this litigation presents a case and controversy within the meaning of Article III of the Constitution.
A.
The majority’s conclusion that the plaintiffs lack standing rests entirely on its application of the Supreme Court’s decision in Lyons to the facts of this case. Simply put, Lyons restates the proposition, articulated by the Court in O’Shea v. Littleton, 414 U.S. 488, 495-96, 94 S.Ct. 669, 675-76, 38 L.Ed.2d 674 (1974), and Rizzo v. Goode, 423 U.S. 362, 372, 96 S.Ct. 598, 604-05, 46 L.Ed.2d 561 (1976), that past exposure to harm will not, in and of itself, confer standing upon a litigant to obtain equitable relief “[ajbsent a sufficient likelihood that he will again be wronged in a similar way....” Lyons, 103 S.Ct. at 1670. The majority reasons that, like the plaintiff in Lyons, O’Hair cannot show a real and immediate threat that she will again be harmed in a similar way. See maj. op. at 1285.
Lyons involved a challenge to a choke-hold maneuver employed by Los Angeles police officers. The Supreme Court found no standing to obtain prospective relief because the plaintiff, although injured by the chokehold in the past, could not establish a threat of a similar injury in the future. Pivotal to this conclusion was the fact that the plaintiff could not distinguish himself from any other citizen as being a future victim of the unconstitutional act. The past harm suffered by the plaintiff in that case had no bearing on the likelihood that he would again be harmed by the defen*1292dant. In other words, the plaintiff in Lyons was no more likely than the next guy to be injured again.
O’Hair and members of the Society of Separationists do not stand in the shoes of the next guy. Indeed, they are susceptible to injury precisely because they are not like the average Joe: they are not willing to conform to the popular view that an affirmation is not a religious exercise. Thus, they are the plaintiffs to bring this action for prospective relief. True, all citizens can expect to be summoned to serve their duty as jurors. But only these plaintiffs, by virtue of their distinctive views about religious activities, are threatened by Judge Herman’s practice. They are uniquely vulnerable to future injury. This is not a case in which “the asserted injury is a generalized grievance shared in substantially equal measure by all or most citizens.” O’Hair v. White, 675 F.2d 680, 687 (5th Cir.1982) (en banc). Such an injury will not suffice to confer standing upon a plaintiff. Id. (citing Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 220, 94 S.Ct. 2925, 2931-32, 41 L.Ed.2d 706 (1974)). Rather, this is a case in which the threatened injury will be suffered by a limited, identifiable group of citizens — atheists and others whose religious beliefs (or lack of beliefs) cause them to be offended by the demand for an affirmation. See, e.g., Ferguson v. C.I.R., 921 F.2d 588 (5th Cir.1991) (prospective oath-taker refused to “affirm” because she understood two passages from the Bible to prohibit affirmations).
Although no single plaintiff can predict with certainty when exactly he will be summoned to serve, we can rest assured that these plaintiffs will be summoned in due time, particularly under the random jury selection system. This fact assumes special significance because in Lyons the Court found no standing for the following reason:
[I]t is surely no more than speculation to assert either that Lyons himself will again be involved in one of those unfortunate instances, or that he will be arrested in the future and provoke the use of a chokehold by resisting arrest, attempting to escape, or threatening deadly or serious bodily injury.
Lyons, 103 S.Ct. at 1668. In essence, the plaintiff in Lyons was seeking redress based upon a “chain of speculative contingencies: that he would be arrested and provoke the officer to use the chokehold in an unconstitutional manner.” Nelsen v. King County, 895 F.2d 1248, 1252 (9th Cir.1990) (explaining Lyons).
Unlike Lyons, the threat of future of injury in this case does not depend on a “chain of speculative contingencies,” but rather on certain probabilities beyond the plaintiffs’ control. We are dealing here with jury duty, an obligation of citizenship. The plaintiffs can reasonably anticipate similar encounters with Judge Herman in the future when they are summoned to serve as jurors in Travis County. The record reflects that Judge Herman continues to serve on the County Court, and accordingly, there is a quantifiable, mathematical certainty that he will again preside over jury impanelment and encounter O’Hair or some other member the Society of Separationists among the prospective jurors.2 For some, the fact that the probability is quantifiable, and not “contingency riddled,” would independently establish that the likelihood of recurrence is sufficient for standing purposes. “Our analysis cannot be reduced to considering probability merely in terms of quantitative percentages.” Nelsen, 895 F.2d at 1250. Perhaps *1293we should also “describe ‘probability’ [of future injury] qualitatively, as requiring a very significant possibility,” id. (quoting Sample v. Johnson, 771 F.2d 1335, 1343 (9th Cir.1985), cert. denied, 475 U.S. 1019, 106 S.Ct. 1206, 89 L.Ed.2d 319 (1986)), or, as the Supreme Court phrased it in a post-Lyons decision, as requiring a “credible threat” of future injury. Kolender v. Lawson, 461 U.S. 352, 103 S.Ct. 1855, 1857 n. 3, 75 L.Ed.2d 903 (1983). Under this qualitative analysis, the plaintiffs have standing because there is a “significant possibility” and “credible threat” that they will be summoned for jury service.
The fact that Judge Herman alone is accountable for the threat of future injury does not take the legs out from under the plaintiffs’ position. Although Judge Herman was not “acting pursuant to any state or local rule or statute” when he demanded an affirmation from O’Hair, see maj. op. at 1286, there is evidence in the record that he continues to engage in a similar practice: While impaneling a jury following the incident with O’Hair, Judge Herman demanded an “affirmation” from another atheist who was summoned for jury duty and excluded him from service without first proposing that he make a non-religious, conscience-binding declaration as an alternative to an affirmation. See supra note 2. Thus, the record reflects the genesis of a pattern3 or “personal policy”4 of exclusion by Judge Herman based on the juror’s religious beliefs, which cannot be dismissed as merely “contextual” or “episodic.” See maj. op. at 1286. We need not wait until Judge Herman excludes or incarcerates others before we can evaluate the constitutionality of Judge Herman’s practice and award the appropriate declaratory relief.
B.
The majority’s reliance on Lyons and its progeny is misguided for yet another reason. Unlike this case, the plaintiffs’ assertion of standing in those cases cited by the majority was predicated upon the contingency that the plaintiff would commit a crime that would set in motion a chain of events culminating in the defendant’s unconstitutional act. There was absolutely no measure of certainty that the plaintiffs in those cases would suffer the future injury and the likelihood that they would turn in large part on events within their own control.
Our court found no standing in Adams v. McIlhany, 764 F.2d 294, 299 (5th Cir.1985), cert. denied, 474 U.S. 1101, 106 S.Ct. 883, 88 L.Ed.2d 918 (1986), because the recurrence depended upon the plaintiff’s son committing a crime, being rearrested, charged, and sentenced before the defendant judge in order for the judge to hold the plaintiff in contempt for writing a derogatory letter about the judge. We also found no standing in Brown v. Edwards, 721 F.2d 1442, 1446-47 (5th Cir.1984), because the plaintiff did not allege or prove that he was “in any way likely, or more likely than any other Mississippian, to be again subjected to arrest or charging by any Mississippi constable.” Most recently, this circuit found no standing in Johnson v. Moore, 958 F.2d 92, 94 (5th Cir.1992), because “[i]t would require conjecture or hypothesis to find that Johnson [would] again act in such a way as to be arrested on a misdemeanor charge” and thus subject himself to the unconstitutional act of the defendant-judge.
The Tenth Circuit found no standing in Schepp v. Fremont County, 900 F.2d 1448, 1452-53 (10th Cir.1990), for essentially the same reason: The probability of recurrence was too remote where it depended on the plaintiff violating probation so as to be subjected to probation-revocation proceedings. The Eighth and Ninth Circuits found no standing in cases brought by inmates *1294challenging conditions of confinement in correctional institutions from which they had been transferred because there was no showing that the plaintiffs were likely to return to the institutions. Foster v. Basham, 932 F.2d 732, 734 (8th Cir.1991); Johnson v. Moore, 948 F.2d 517, 519 (9th Cir.1991).
In Nelsen, another Ninth Circuit case, the court found no standing, recognizing that cases like Lyons and O’Shea turned on the fact that the plaintiff had to commit an unlawful act in order to expose himself to repeated injury. Nelsen, 895 F.2d at 1252. In Nelsen the plaintiffs challenged the constitutionality of the conditions in a drug rehabilitation center where they had been confined. Over a dissent, the panel majority concluded that standing was lacking because the plaintiffs “failed to demonstrate any ... systematic pattern or policy that would suggest that their return to the [drug rehabilitation] [cjenter [was] inevitable.” Id. at 1254.5
Even the Supreme Court case underpinning the Lyons decision, O’Shea v. Littleton, 414 U.S. 488, 94 S.Ct. 669, 38 L.Ed.2d 674 (1974), turned on a “chain of speculative contingencies, particularly a chain that include[d] the violation of an unchallenged law.” Nelsen, 895 F.2d at 1252. The Supreme Court found no standing because the plaintiffs would have had to violate the law, be charged and tried before the defendants, in order to be subjected to the unconstitutional conduct. O’Shea, 414 U.S. at 496, 94 S.Ct. at 676; see also Ashcroft v. Mattis, 431 U.S. 171, 172 & n. 2, 97 S.Ct. 1739, 1740 & n. 2, 52 L.Ed.2d 219 (1977) (holding that the plaintiff, whose first son was killed by police while attempting to escape arrest, had no standing to obtain a declaratory judgment on the constitutionality of the state statute authorizing the use of deadly force in apprehending a fleeing felon where complaint merely alleged that plaintiff’s other son might be arrested and attempt to flee).
While these cases, relied upon by the majority, distill a principle of black letter law for standing — that prospective relief is only available if there is a sufficient likelihood of recurrence — they do not govern this case. Unlike Lyons, O’Shea, Ashcroft, Adams, Brown, Johnson (5th Cir.), Schepp, Foster, Johnson (9th Cir.), and Nelsen6 the plaintiffs in this case “do not have to induce a police encounter before the possibility of injury can occur. The [plaintiffs] are subject to constitutional injury based on completely innocent behavior ” LaDuke v. Nelson, 762 F.2d 1318, 1326 (9th Cir.1985) (emphasis added) (holding that the plaintiffs had standing to obtain injunction against the INS for its policy of conducting random searches and seizures of residents of migrant farm dwellings), amended, 796 F.2d 309 (9th Cir.1986).7 Rather, the more apposite precedents, are the ones downplayed by the majority: O’Hair v. White, 675 F.2d 680 (5th Cir.1982) (en banc) and Ciudadanos Unidos de San Juan v. Hidalgo County Grand Jury Comm’r, 622 F.2d 807 (5th Cir.1980), cert. denied, 450 U.S. 964, 101 S.Ct. 1479, 67 L.Ed.2d 613 (1981).
In O’Hair v. White this court concluded that the plaintiffs, Madalyn Murray-O’Hair *1295and the Society of Separationists, had standing to challenge a Texas law that infringed upon their right not to be excluded from jury service on religious grounds. The constitutional challenge was virtually identical to the one pressed here. The plaintiffs alleged that law required that they acknowledge the existence of a supreme being. Over two dissenting opinions, a majority of the en banc court found that the plaintiffs had standing to bring the lawsuit even though the plaintiffs arguably could not demonstrate a high probability that they would be summoned for, and excluded from, jury duty. The majority wrote:
O’Hair’s final asserted basis for standing is that section 4 [of the Texas Constitution] caused her to be excluded from jury duty because she refused to swear to her belief in a supreme being.... O’Hair is ... aggrieved by being excluded from jury duty because of her lack of religious belief.... She clearly has standing to challenge that system.
675 F.2d at 691. Contra id. at 702 (Tjoflat, J., concurring in part and dissenting in part) (“I would hold that O’Hair lacks standing to assert [her] claim [that she is excluded from jury service based on her religious beliefs] because she alleges not that she has been excluded from jury service but only that she would be ”); id. at 703 (Reavley, J., dissenting) (embracing Judge Tjoflat’s dissent).
In Ciudadanos Unidos de San Juan v. Hidalgo County Grand Jury Commissioners this court held that Mexican-Americans had standing to obtain prospective relief from systematic exclusion from grand jury service. Concluding that “O’Shea [did] not control the disposition of these cases,” we explained that:
Under these allegations, the threat of future injury is palpable. Unlike the contingency riddled complaint in O’Shea, the complainants here claim an injury that turns on a single contingency that the jury commissioners will act exactly as they have for the past ten years ... Unlike O’Shea ... [plaintiffs’] injury here depends solely upon the action of the [defendants].
622 F.2d at 820-21; see also Carter v. Jury Commission of Greene County, 396 U.S. 320, 90 S.Ct. 518, 523, 24 L.Ed.2d 549 (1970) (“Surely there is no jurisdictional or procedural bar to an attack upon systematic jury discrimination by way of a civil suit such as the one brought here.”).
Both O’Hair v. White and Ciudadanos compel a conclusion that the plaintiffs in this case have standing.8 O’Hair and members of the Society of Separationists are just as threatened by exclusion from jury service as the plaintiffs in those cases. The majority’s effort to distinguish those cases as involving either a “state law that on its face arguably excluded atheists from serving on juries” or “jury selection systems that [were] consistently administered so as to exclude [minorities] from jury service” is unpersuasive. See maj. op. at 1287. Standing to obtain equitable relief in any case depends on the threat of future injury — in this case, as in O’Hair v. White, the threat that the plaintiffs will be excluded from jury service because of their views on religion. In O’Hair v. White and Ciudadanos this court was necessarily satisfied that this threat of future was sufficient to establish the plaintiffs’ standing to seek prospective relief. Surely the threat of future injury to any one plaintiff in O’Hair v. White and Ciudadanos was no more “credible,” “distinct,” “palpable,” “real,” or “immediate” than the threat of future injury plaguing the plaintiffs in this case. O’Hair and other members of the Society of Separationists have standing to obtain equitable relief.9
*1296II.
From this conclusion, it follows that the Society of Separationists itself has the requisite “associational standing” to bring this lawsuit. See maj. op. at 1288 (applying the three prong test articulated in Hunt v. Washington State Apple Advertising Comm’n, 432 U.S. 333, 343, 97 S.Ct. 2434, 2441, 53 L.Ed.2d 383 (1977)). I need not comment at length to make this point. I have explained why I believe that O’Hair and other members of the association have demonstrated a sufficient threat of future injury to establish that they have standing in their own right to challenge Judge Herman’s practice.10 That satisfies the first prong of the Hunt test. The majority does not dispute that the “interests [that the Society of Separationists] seeks to protect are germane to the organization’s purpose.” Hunt, 432 U.S. at 343, 97 S.Ct. at 2441. So much for the second prong.
As for the third prong, the majority suggests that “the Society’s claim would require the participation of individual members ... [because] Society members’ views [may] differ as to the religious nature of an affirmance.” Maj. op. at 1288. Even if that bit of speculation were accurate — that members of the Society take differing positions on affirmations — associational standing does not require harmony of member interests. See Contractors Ass ’n. v. Philadelphia, 945 F.2d 1260, 1266 (3d Cir.1991) (finding litigation not contrary to interests of a majority of members); National Maritime Union v. Commander, Military Sealift Command, 824 F.2d 1228, 1231-34 (D.C.Cir.1987); Gillis v. U.S. Dept. of Health & Human Servs., 759 F.2d 565, 572-73 (6th Cir.1985). Contra Associated Gen. Contractors v. Otter Tail Power Co., 611 F.2d 684, 691 (8th Cir.1979) (rejecting associational standing when factual or potential conflicts exist among members). See generally UAW v. Brock, 477 U.S. 274, 106 S.Ct. 2523, 2532-33, 91 L.Ed.2d 228 (1986) (declining to “reject the principles of associational standing,” notwithstanding argument that associations “will not always be able to represent adequately the interests of their injured members.”).
It is also quite plain that in this challenge to Judge Herman’s practice of demanding an affirmation as a condition of jury service, the individual plaintiffs are not “indispensable to proper resolution of the cause_” Warth v. Seldin, 422 U.S. 490, 511, 95 S.Ct. 2197, 2212, 45 L.Ed.2d 343 (1975). The plaintiffs merely seek a declaration that Judge Herman may not exclude or incarcerate a prospective juror for refusing to affirm until he has proposed that the prospective juror make a nonreligious, conscience-binding declaration of a commitment to tell the truth. “[T]he claim asserted and the relief requested affect the membership as a whole” and therefore, “the claim does not require individualized participation.” Church of Scientology v. Cazares, 638 F.2d 1272, 1276-80 (5th Cir.1981) (association had standing to bring free exercise challenge on behalf of its members).
*1297At least twice since Hunt, this court has held that the Society had standing to raise constitutional claims on behalf of its members. See O’Hair v. White, 675 F.2d at 691-92 (holding that the Society satisfied the requirements of Hunt and thus had standing to litigate alleged violations of its members voting rights); Murray v. City of Austin, 947 F.2d 147, 152 (5th Cir.1991) (“because Murray has standing, the Society, of which he is a member, also has standing” to litigate the constitutionality of the inclusion of a religious symbol in a city insignia). As in those two cases, I would find that the three-prong Hunt test poses no obstacle to the Society’s assoeiational standing in this case.
III.
This is a case about the First Amendment, the cornerstone of all other rights and freedoms which we, as citizens of this great Nation, have come to enjoy, and perhaps even take for granted. It is very disturbing to think that we would contort the doctrine of standing and employ it as an evasive device for dodging sensitive constitutional questions, especially when First Amendment rights are at stake. Accord maj. op. at 1286 (“We must not shrink from our duty to decide a controversy_”). Not surprisingly, courts have consistently applied the standing doctrine liberally, not grudgingly, in the context of First Amendment litigation.11
Standing is not a static concept. Rather, it is an evolutionary doctrine that continues to mature. Although the doctrine appropriately restricts the flood of noxious litigation, we must insure that it does not narrow the avenue for raising concrete constitutional claims. I cannot believe that the Framers would say that a federal court lacks jurisdiction to hear a case brought by a citizen who has been jailed for her refusal to participate in a religious exercise in connection with the performance of a civic duty when that citizen can expect to be summoned again. This court has historically opened its ears and hearts to the wailing cries of those deprived of treasured rights. I would hold that these plaintiffs have standing to raise their claims, and in so doing, preserve the reputation of this court as an open, not a closed, circuit.
I respectfully, but fervently, dissent.
. See infra note 2.
. The majority’s assertion that “Judge Herman’s regular duties do not include such matters" as impaneling juries, maj. op. at 1285, finds no support in the record. Indeed, there is evidence in the record that not long after he excluded Ms. O'Hair from jury service, Judge Herman was again called upon to impanel a jury. Among the prospective jurors, he encountered an individual who interposed a similar objection to the affirmation process. As with O’Hair, Judge Herman excluded that individual from jury service on that basis. See maj. op. at 1285 n. 1.
Of course, if there is any question about whether Judge Herman continues to impanel juries, a remand-would be appropriate to allow the district court to make factual findings, rather than speculating on appeal as to the likelihood that these plaintiffs will appear before Judge Herman in the future.
. Cf. Ikuno v. Yip, 912 F.2d 306, 309 (9th Cir.1990) ("two acts is an accepted minimum” for establishing a "pattern” under the RICO statute) (citing H.J., Inc. v. Northwestern Bell tel. Co., 492 U.S. 229, 109 S.Ct. 2893, 2899, 106 L.Ed.2d 195 (1990)).
. Contra maj. op. at 1286 ("It is clear that the judge was not acting pursuant to any ... personal policy, when he failed to ask O’Hair if there were alternative ways in which she would be willing to commit herself to tell the truth.”).
. The dissenting judge believed that standing did exist because plaintiffs had tendered unre-butted evidence proving that was a 35% to 75% probability that the plaintiffs themselves would return to the facility. The dissent concluded that "appellants have established there is credible threat they will again suffer the harm they have alleged." Id. at 1255 (Pregerson, J., dissenting).
. Foster and Johnson (9th Cir.) are different because they involved inmates transferred to different penal institutions, thus mooting out any claim for prospective relief. It appears that there was no threat that they would be transferred back to the original facility. Perhaps if the plaintiffs committed an offense some time later, they might serve time in that institution. Such speculation, of course, cannot establish a "credible threat" of future injury.
.Moreover, this case is different because, as one legal scholar has observed, "Lyons must be understood in large part as a decision of substantive law. In particular, the case seems to represent a further extension and reification of the Court’s general, sweeping respect and deference for men in uniform that has overridden a wide range of substantive law claims.” Laurence H. Tribe, American Constitutional Law 122 (2d ed. 1988).
. Lyons represented an application, not an extension, of O'Shea. Lyons, 103 S.Ct. at 1667 ("No extension of O’Shea ... is necessary to hold that respondent Lyons has failed to demonstrate a case or controversy with the City that would justify the equitable relief sought.”). Thus, Ciudadanos and O’Hair v. White, both of which found that the plaintiffs had standing, were not undercut by the Supreme Court’s subsequent decision in Lyons.
. The majority’s citation (maj. op. at 1287) to Powers v. Ohio, 111 S.Ct. 1364, 1373, 113 L.Ed.2d 411 (1991), is misplaced. The Powers Court merely observed that a juror could not "easily obtain declaratory or injunctive relief *1296when discrimination occurs through an individual prosecutor’s exercise of peremptory challenges." Such would be the case because the use of a peremptory strike depends so much on the subject matter of the underlying prosecution. The threat of future injury would be particularly remote and turn on a “chain of speculative contingencies."
. Because the Society represents the interests of similarly situated plaintiffs, it would be fitting, in my view, to aggregate the probabilities of future injury to determine whether the Society has standing to bring suit on behalf of its members. Contrast ASARCO Inc. v. Kadish, 490 U.S. 605, 109 S.Ct. 2037, 2044, 104 L.Ed.2d 696 (1989) (“[T]he doctrine of standing to sue is not a kind of gaming device that can be surmounted merely by aggregating the allegations of different kinds of plaintiffs, each of whom may have claims that are remote or speculative taken by themselves.”). By this I mean that under the first prong of Hunt — which asks whether the association's “members would otherwise have standing to sue in their own right,” 432 U.S. at 343, 97 S.Ct. at 2441 — the likelihood of future injury should be measured by the probability that any one member of the associational plaintiff would be injured, rather than the probability that a particular member of the associational plaintiff might be injured. I believe that aggregating the probabilities is appropriate in a case like this one, which does not involve a generalized grievance and implicates both Lyons and Hunt, because it more accurately reflects the reality, immediacy, and palpability of the threatened injury to the associational plaintiff and its membership.
. Cf. Grand Rapids School Dist. v. Ball, 473 U.S. 373, 380 n. 5, 105 S.Ct. 3216, 3220 n. 5, 87 L.Ed.2d 267 (1985) (citing "the numerous cases in which [the Supreme Court has] adjudicated Establishment Clause challenges by state taxpayers to programs for aiding nonpublic schools’’); Blast v. Cohen, 392 U.S. 83, 88 S.Ct. 1942, 20 L.Ed.2d 947 (1968) (Establishment Clause challenge to federal aid-to-education program based upon federal taxpayer standing); Everson v. Board of Education, 330 U.S. 1, 67 S.Ct. 504, 91 L.Ed. 711 (1947) (local taxpayer standing to raise Establishment Clause challenge to school district expenditures); Murray v. City of Austin, 947 F.2d 147, 152 (5th Cir.1991) (concluding that the Society of Separationists and its member had standing to raise Establishment Clause challenge to inclusion of religious symbol in city insignia); see generally Tribe, supra note 3, at 116 ("The Court has been particularly generous in entertaining challenges under the establishment clause of the first amendment to state or local aid to church-related schools.”).