Tuesday, April 7, 2020
The First Circuit in Perrier-Bilbo v. Cissna ruled against a challenge to the inclusion of the phrase "so help me God" in the naturalization oath. Plaintiff Perrier-Bilbo argued that the phrase violates the Establishment and Free Exercise Clauses of the First Amendment, the Religious Freedom
Restoration Act, and the Fifth Amendment equal protection and procedural due process protections. She requested that USCIS and lower courts be enjoined from using the phrase "so help me God" during the naturalization ceremony for which she was scheduled. The court found the inclusion of "so help me God" as a means of completing the naturalization oath does not violate the First or Fifth Amendments or RFRA.