The Reindeer Rule: Why You'll See Rudolph in Any Public Christmas Display

iStock.com/ekash
iStock.com/ekash

The Establishment Clause of the First Amendment says “Congress shall make no law respecting an establishment of religion.” But in practice, not everyone agrees on what abiding by that clause means in real-life situations. For instance, can a courthouse or a public park feature a nativity scene?

According to the Supreme Court, maybe not—or at least not unless it includes a menorah and a plastic reindeer, too. In the 1984 case of Lynch v. Donnelly, the court established a precedent that became known as the “reindeer rule," a legal standard that has governed public displays of holiday cheer ever since.

The case hinged on a Rhode Island display that was owned by the city of Pawtucket but was located in a park owned by a nonprofit organization. The annual display, which dated back 40 years, included a nativity scene (also known as a creche or crèche) in addition to other Christmastime symbols like reindeer pulling Santa’s sleigh, a Christmas tree, and a “seasons greetings” banner. The justices ruled in favor of the nativity scene, arguing that there was a secular argument to be made about including the religious reference:

The display is sponsored by the city to celebrate the Holiday recognized by Congress and national tradition and to depict the origins of that Holiday; these are legitimate secular purposes. Whatever benefit to one faith or religion or to all religions inclusion of the creche in the display effects, is indirect, remote, and incidental, and is no more an advancement or endorsement of religion than the congressional and executive recognition of the origins of Christmas, or the exhibition of religious paintings in governmentally supported museums.

In the case, Justice Sandra Day O’Connor put forth a legal rule of thumb called the “endorsement test,” writing that governments can run afoul of the Establishment Clause by appearing to endorse a specific religion or a belief, rather than being inclusive of a variety of beliefs. “Endorsement sends a message to nonadherents that they are outsiders, not full members of the political community, and an accompanying message to adherents that they are insiders, favored members of the political community,” O'Connor explained.

According to the National Constitution Center, “Court observers at the time saw the presence of the reindeer as broadening the purpose of the display.” And so the reindeer rule was born.

Then, a 1989 Supreme Court ruling in reference to two holiday displays inside and outside the Allegheny County courthouse in Pittsburgh made this standard even more clear. A nativity scene inside the courthouse that prominently displayed a banner that read, in Latin, “Glory to God for the birth of Jesus Christ,” with no secular objects on display, was ruled unconstitutional. Meanwhile, a display outside the courthouse with a menorah, a Christmas tree, and a sign that declared the city’s “salute to liberty,” as the case ruling puts it, was allowed to stay. With the overtly Christian indoor display, nothing counteracted the government endorsement of “a patently Christian message.”

As Justice Harry Blackmun wrote in his opinion, “Although the government may acknowledge Christmas as a cultural phenomenon, it may not observe it as a Christian holy day by suggesting that people praise God for the birth of Jesus,” while the menorah display combined “with a Christmas tree and a sign saluting liberty does not impermissibly endorse both the Christian and Jewish faiths, but simply recognizes that both Christmas and Chanukah are part of the same winter-holiday season, which has attained a secular status in our society. The widely accepted view of the Christmas tree as the preeminent secular symbol of the Christmas season emphasizes this point.” This ruling only applies to government property and government sponsored displays, though, which is why it's completely fine for private entities like churches to erect public displays of nativity scenes on their property.

Though the reindeer rule seems pretty clear, it hasn’t stopped towns from testing the boundaries of the court’s ruling over the decades since it was established.

In 2014, Cherokee County, Texas, for instance, got into a spat with the American Humanist Association over the constitutionality of a nativity scene in front of the county courthouse. The state attorney general publicly supported the county, and there was no forced removal of the display. That same year, similar controversies took place in towns in Virginia and Arkansas. Some cities have groups like the Thomas More Society and the American Nativity Scene Committee, which work to get Christian displays erected in public places across the country, to thank for their nativity scenes. The former calls nativity scenes “classic free speech.”

But some towns have proven to be a little more inclusive of other holiday decor—or at least wary of litigation. The Florida Capitol building in Tallahassee, for instance, has approved holiday displays that include not just nativity scenes, but privately funded decorative contributions from the Satanic Temple, Seinfeld fans (a Festivus pole), and Pastafarian followers of the Flying Spaghetti Monster.

But the U.S. remains a very Christian country, despite its longstanding religious freedom laws, and according to a 2014 Pew Research Center survey, 44 percent of American adults think Christian symbols are OK to display on government property, even in the absence of symbols from other faiths. It should be noted that a Pew survey that year on religion found that 71 percent of Americans identified as Christians, though the percentages of residents practicing other faiths or identifying as atheists has been rising. Still, that doesn’t mean that nativity scenes get total respect in America. Plenty of baby Jesuses get swiped out of their mangers every year.

10 of the Most Popular Portable Bluetooth Speakers on Amazon

Altech/Bose/JBL/Amazon
Altech/Bose/JBL/Amazon

As convenient as smartphones and tablets are, they don’t necessarily offer the best sound quality. But a well-built portable speaker can fill that need. And whether you’re looking for a speaker to use in the shower or a device to take on a long camping trip, these bestselling models from Amazon have you covered.

1. OontZ Angle 3 Bluetooth Portable Speaker; $26-$30 (4.4 stars)

Oontz portable bluetooth speaker
Cambridge Soundworks/Amazon

Of the 57,000-plus reviews that users have left for this speaker on Amazon, 72 percent of them are five stars. So it should come as no surprise that this is currently the best-selling portable Bluetooth speaker on the site. It comes in eight different colors and can play for up to 14 hours straight after a full charge. Plus, it’s splash proof, making it a perfect speaker for the shower, beach, or pool.

Buy it: Amazon

2. JBL Charge 3 Waterproof Portable Bluetooth Speaker; $110 (4.6 stars)

JBL portable bluetooth speaker
JBL/Amazon

This nifty speaker can connect with up to three devices at one time, so you and your friends can take turns sharing your favorite music. Its built-in battery can play music for up to 20 hours, and it can even charge smartphones and tablets via USB.

Buy it: Amazon

3. Anker Soundcore Bluetooth Speaker; $25-$28 (4.6 stars)

Anker portable bluetooth speaker
Anker/Amazon

This speaker boasts 24-hour battery life and a strong Bluetooth connection within a 66-foot radius. It also comes with a built-in microphone so you can easily take calls over speakerphone.

Buy it: Amazon

4. Bose SoundLink Color Bluetooth Speaker; $129 (4.4 stars)

Bose portable bluetooth speaker
Bose/Amazon

Bose is well-known for building user-friendly products that offer excellent sound quality. This portable speaker lets you connect to the Bose app, which makes it easier to switch between devices and personalize your settings. It’s also water-resistant, making it durable enough to handle a day at the pool or beach.

Buy it: Amazon

5. DOSS Soundbox Touch Portable Wireless Bluetooth Speaker; $28-$33 (4.4 stars)

DOSS portable bluetooth speaker
DOSS/Amazon

This portable speaker features an elegant system of touch controls that lets you easily switch between three methods of playing audio—Bluetooth, Micro SD, or auxiliary input. It can play for up to 20 hours after a full charge.

Buy it: Amazon

6. Altec Lansing Mini Wireless Bluetooth Speaker; $15-$20 (4.3 stars)

Altec Lansing portable bluetooth speaker
Altec Lansing/Amazon

This lightweight speaker is built for the outdoors. With its certified IP67 rating—meaning that it’s fully waterproof, shockproof, and dust proof—it’s durable enough to withstand harsh environments. Plus, it comes with a carabiner that can attach to a backpack or belt loop.

Buy it: Amazon

7. Tribit XSound Go Bluetooth Speaker; $33-$38 (4.6 stars)

Tribit portable bluetooth speaker
Tribit/Amazon

Tribit’s portable Bluetooth speaker weighs less than a pound and is fully waterproof and resistant to scratches and drops. It also comes with a tear-resistant strap for easy transportation, and the rechargeable battery can handle up to 24 hours of continuous use after a full charge. In 2020, it was Wirecutter's pick as the best budget portable Bluetooth speaker on the market.

Buy it: Amazon

8. VicTsing SoundHot C6 Portable Bluetooth Speaker; $18 (4.3 stars)

VicTsing portable bluetooth speaker
VicTsing/Amazon

The SoundHot portable Bluetooth speaker is designed for convenience wherever you go. It comes with a detachable suction cup and a carabiner so you can keep it secure while you’re showering, kayaking, or hiking, to name just a few.

Buy it: Amazon

9. AOMAIS Sport II Portable Wireless Bluetooth Speaker; $30 (4.4 stars)

AOMAIS portable bluetooth speaker
AOMAIS/Amazon

This portable speaker is certified to handle deep waters and harsh weather, making it perfect for your next big adventure. It can play for up to 15 hours on a full charge and offers a stable Bluetooth connection within a 100-foot radius.

Buy it: Amazon

10. XLEADER SoundAngel Touch Bluetooth Speaker; $19-$23 (4.4 stars)

XLeader portable bluetooth speaker
XLEADER/Amazon

This stylish device is available in black, silver, gold, and rose gold. Plus, it’s equipped with Bluetooth 5.0, a more powerful technology that can pair with devices up to 800 feet away. The SoundAngel speaker itself isn’t water-resistant, but it comes with a waterproof case for protection in less-than-ideal conditions.

Buy it: Amazon

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5 Ways to Keep Your Dog Calm on the Fourth of July

iStock/Getty Images Plus/melissabrock1
iStock/Getty Images Plus/melissabrock1

The Fourth of July can be rough for dogs. Fireworks displays light up their senses with unfamiliar noises, flashes, and smells, and parties flood their homes with strange guests who may invade the rooms they usually have as private retreats. And when distressed dogs escape, howl, or thrash around the house, Independence Day can quickly become a nightmare for their owners, too. To minimize Fido's stress this holiday, we spoke to some dog experts to discover the best ways to keep your canine calm on the Fourth of July.

1. Exercise Your Dog

Anthony Newman, the dog whisperer who runs New York City's Calm Energy Dog Training, says that exercise is a great way to help your dog let off some nervous energy. "Whenever Fido is going to be neglected for an extended period of time, or around any stressful stimuli, it always helps to tire him out just before—and even during the night if you can," Newman says. "As the saying goes, a tired dog is a good dog! He'll be calmer, happier, and more peaceful."

2. Keep Your Dog Indoors

Dr. Stephanie Liff, head veterinarian at Pure Paws Veterinary Care, says the best place to keep your pet during a fireworks show is inside and away from the windows. "If the pet is very scared, an escape-proof crate or a sound-insulated room, such as an internal bathroom, may help the pet to feel more secure," Liff tells Mental Floss. "If you cannot keep your pet inside, make sure that the pet is prevented from escape (monitor all exits and tell guests to monitor your pet)."

3. Socialize Your Dog

While your dog may feel more secure in a room away from all the noise, Newman points out that keeping your dog isolated in another room for too long can be stressful for your pet. "Release his curiosity and let him in on the fun, to run around and play with both two-legged as well as four-legged guests," Newman says. "Then back to his obedient room, bed, car, crate, or spot. Rinse and repeat as needed throughout the night."

4. Take Control of Your Dog

According to Newman, the best way to keep your dog calm during the chaos of July 4th is to stay in charge. "If your dog winces, shivers, and runs away at loud noises, the last thing he wants is to feel like nobody else is looking out for him," Newman says. Don't let your dog run rampant around the house or follow him around trying to soothe him. Instead, Newman says it's important to "take control by attaching a super-light leash that you can grab and lead him whenever you need."

5. Explore Medicating Your Dog

In extreme cases of nervousness, Liff says that you should talk to your vet about medication to sedate your dog.