David Morris Clayman v. United States Federal Officials

A federal court dismissed a lawsuit challenging the constitutionality of ‘In God We Trust’ on U.S. currency under RFRA and the First Amendment, finding no substantial burden on religious exercise.

ReligiousLiberty.TV
February 26, 2026
2 min read
Cite This Case
David Morris Clayman v. United States Federal Officials (D. 2025).
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David Morris Clayman v. United States Federal Officials (U.S. District Court, 2025). https://religiousliberty.tv/case-library/clayman-2/
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David Morris Clayman v. United States Federal Officials [U.S. District Court, 2025] — A federal court dismissed a lawsuit challenging the constitutionality of 'In God We Trust' on U.S. currency under RFRA and the First Amendment, finding no substantial burden on religious exercise. Source: ReligiousLiberty.TV (https://religiousliberty.tv/case-library/clayman-2/, accessed April 11, 2026).
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.

Year: 2025 Court: U.S. District Court
Holding: A federal court dismissed a lawsuit challenging the constitutionality of 'In God We Trust' on U.S. currency under RFRA and the First Amendment, finding no substantial burden on religious exercise.

Background

David Morris Clayman filed a federal lawsuit challenging the constitutionality of the national motto "In God We Trust" as it appears on U.S. currency. Clayman argued that the mandatory display of this religious phrase on money that citizens are required to use in daily commerce violated his religious liberty rights under both the Religious Freedom Restoration Act (RFRA) and the First Amendment's Free Exercise Clause.

Legal Question

Does the presence of "In God We Trust" on U.S. currency constitute a substantial burden on an individual's free exercise of religion sufficient to violate RFRA or the First Amendment?

Holding

The U.S. District Court dismissed Clayman's lawsuit, finding that the motto on currency does not impose a substantial burden on religious exercise. The court determined that merely encountering or handling money bearing the phrase does not meaningfully interfere with one's ability to practice their religion or compel participation in religious activity contrary to one's beliefs. Without establishing a substantial burden—a threshold requirement under RFRA—the plaintiff's claims could not proceed.

Significance

This decision reinforces the high bar plaintiffs must meet to establish "substantial burden" claims in religious liberty cases involving government religious displays. The ruling confirms that incidental exposure to religious phrases in civic contexts, even on items citizens routinely use, typically does not rise to the level of constitutional violation. This case contributes to the body of precedent protecting ceremonial deism and traditional religious references in American public life, while maintaining that religious liberty protections require more than mere offense or discomfort with government religious symbolism.

Key Statutes & Provisions

  • Religious Freedom Restoration Act (RFRA)
  • First Amendment Free Exercise Clause
  • First Amendment Establishment Clause (likely referenced in analysis)

*Note: Given the limited information provided about this 2025 case, some specific procedural details and nuanced legal reasoning may not be fully captured in this synopsis. The core holding and legal framework, however, reflect the established jurisprudential approach to such challenges.*

Official Documents

Coverage on ReligiousLiberty.TV

📎 Document links found in our articles: 📄 opinion

David Morris Clayman v. United States Federal Officials is a Free Exercise case decided by the U.S. District Court in 2025. The court held that a federal court dismissed a lawsuit challenging the constitutionality of 'In God We Trust' on U.S. currency under RFRA and the First Amendment, finding no substantial burden on religious exercise.

## Background
David Morris Clayman filed a federal lawsuit challenging the constitutionality of the national motto “In God We Trust” as it appears on U.S. currency. Clayman argued that the mandatory display of this religious phrase on money that citizens are required to use in daily commerce violated his religious liberty rights under both the Religious Freedom Restoration Act (RFRA) and the First Amendment’s Free Exercise Clause.

## Legal Question
Does the presence of “In God We Trust” on U.S. currency constitute a substantial burden on an individual’s free exercise of religion sufficient to violate RFRA or the First Amendment?

## Holding
The U.S. District Court dismissed Clayman’s lawsuit, finding that the motto on currency does not impose a substantial burden on religious exercise. The court determined that merely encountering or handling money bearing the phrase does not meaningfully interfere with one’s ability to practice their religion or compel participation in religious activity contrary to one’s beliefs. Without establishing a substantial burden—a threshold requirement under RFRA—the plaintiff’s claims could not proceed.

## Significance
This decision reinforces the high bar plaintiffs must meet to establish “substantial burden” claims in religious liberty cases involving government religious displays. The ruling confirms that incidental exposure to religious phrases in civic contexts, even on items citizens routinely use, typically does not rise to the level of constitutional violation. This case contributes to the body of precedent protecting ceremonial deism and traditional religious references in American public life, while maintaining that religious liberty protections require more than mere offense or discomfort with government religious symbolism.

## Key Statutes & Provisions
– Religious Freedom Restoration Act (RFRA)
– First Amendment Free Exercise Clause
– First Amendment Establishment Clause (likely referenced in analysis)

*Note: Given the limited information provided about this 2025 case, some specific procedural details and nuanced legal reasoning may not be fully captured in this synopsis. The core holding and legal framework, however, reflect the established jurisprudential approach to such challenges.*