The Devil in the Details

Start with the law, because the law is the whole trick. In Town of Greece v. Galloway, the Supreme Court held in 2014 that a legislative body may open its meetings with prayer, and that what gets said in one is not for judges to parse: requiring invocations to be nonsectarian, the Court wrote, would force legislatures and courts alike “to act as supervisors and censors of religious speech.” What saved the town’s own practice was that it had never sorted its volunteers by creed: a minister or layperson of any persuasion, the town maintained, including an atheist, could give the invocation.

That is the hinge, and it is narrower than it first appears. Greece does not oblige a council to hear from all comers — and it does not hand a council that invites its speakers a free pass either. The duty not to discriminate follows the selection, however the selection is made; a county that screened atheists out of an invitation-only roster lost in the Eleventh Circuit on exactly that ground. What the rule means in practice is that a council which has thrown the floor open cannot then sort the volunteers by what they believe. Read it from a city attorney’s chair: choose your invocation-givers on neutral, non-religious grounds, the way Boston does, and you keep your discretion; let the public sign up and you have given it away. You cannot keep out the one you’d rather not hear. And there is an organization built precisely to test that proposition.

A clarification the headlines usually skip: the group behind most of these invocations is The Satanic Temple. It is not the Church of Satan, and it does not worship the devil, contrary to how it sounds. Founded in 2013, it is a non-theistic organization — it does not believe in a literal Satan or anything supernatural — organized around seven tenets about compassion, reason, and bodily autonomy. It uses the imagery of Satan as a literary symbol of dissent, and it uses invocation policies as a civics stress test: if the government will host one religion’s prayer, it must host everyone’s. Whether that is mischief or principle is a fair debate. That it is effective is not.

Ottumwa’s council had adopted its invocation policy that January, on a 4–1 vote (Resolution 18-2026). The text is almost poignant in hindsight: it promises to respect “the diversity of both organized and unorganized religious denominations, as well as other faiths, belief systems, or the lack thereof.” Any resident may volunteer; it’s first-come, first-served; the mayor may not screen what gets said. For nine months the sign-up list behaved exactly as the council must have pictured it: Baptist and Pentecostal pastors, a Church of the Open Bible minister, a Catholic priest booked for later in October.

The lone dissenter, Council Member Cara Galloway, had said this would happen. Later in that same October meeting, she told her colleagues she had warned, back when they debated the policy, that “having someone from the Church of Satan or a prayer about Satan … this could happen and we would need to allow it.” (Her phrase “Church of Satan” is the common mix-up; the group was the Satanic Temple.) Her point, on the record, is the thesis of this whole piece: “I think we’ve opened ourselves up for others to object or respond to others’ invocations, and we need to remember that we are up here to be neutral.” As the clip above shows, the council had, in the most literal way, written the trap and then sprung it.

That is not where Ottumwa has left it. Dalbey is on the calendar to give the invocation again on November 3. Mayor Benjamin Foote has said he is reviewing the policy and would like a limit on how often one person can take the slot; the council has adopted nothing. The Freedom From Religion Foundation has written to the city attacking its response to a non-Christian invocation and urging it to drop invocations altogether. Ottumwa is still inside the choice this piece is about: a frequency cap it could probably impose on everyone, and a policy it cannot rewrite around one speaker.

Here is the detail that turns a string of weird-news clips into one story. The words Dalbey read in Ottumwa were not his. They are a standard text, written by Satanic Temple co-founder Lucien Greaves, and the Temple’s members recite it almost verbatim wherever they go. You can hear the same lines — “unbowed and unfettered by arcane doctrines born of fearful minds,” the “Luciferian impulse to eat of the tree of knowledge,” the closing “It is done. Hail Satan” — in Pensacola in 2016, in San Marcos in 2023, in Alaska in 2023, and in Ottumwa in 2026. It is less a curse than a script.

The oldest and most theatrical performance of that script is a decade old, in Pensacola, Florida. David Suhor, a co-founder of the Satanic Temple of West Florida, arrived in a hooded black robe and did not read the invocation but sang it, sounding a pitch pipe first to find his key, to an altered version of Albert Hay Malotte’s 1935 melody for the Lord’s Prayer. The room answered by reciting that same prayer over him. About a third of those present walked out, and police escorted protesters from the chamber. The council had seated him only after its president concluded that refusing would invite litigation. Watch the first minute and the comedy and the constitutional law arrive together.

So the devil signs up. Now the council has to do something, on camera, in front of its neighbors. What it does turns out to be surprisingly predictable: there are only about three exits. The chart below holds seven bodies — the six that actually heard the invocation, plus Phoenix, which shut its microphone before the Temple could reach it.

Battle Ground, Washington, took the first exit — keep the mic open and let it ride. Its council adopted a rotating, first-come invocation policy (Resolution 26-04) on August 3, 2026, on a 5–1 vote, after an hour of packed public comment. The resolution itself is doing more work than the summary suggests: the slot is offered to “people affiliated with local faith-based organizations and ministries,” anyone unaffiliated is pointed instead to a statement or a moment of silence, and every invocation “shall be positive and uplifting.” A later clause of the same resolution says a speaker’s faith “or lack thereof” shall not preclude them. At the first invocation under the policy, on October 5, the slot went to Bast Sekhmet of the Satanic Temple of Washington, who used the three minutes to explain the organization and its beliefs, and signed off looking forward to “doing this again next year” — the policy allows each speaker one invocation per calendar year.

San Marcos, Texas, shows what “open” looks like when nobody else shows up. The council had offered the invocation to local clergy, and — per the San Marcos Record — none volunteered. So the slot went to the one person who did: Lanzifer Eligos Longinus, a co-head of the Temple’s Austin congregation. Roughly a hundred protesters gathered outside; inside, the same script played again.

If the law makes an open mic impossible to close selectively, is there any lawful way to say no? There is. Boston never ran an open sign-up. Its council invites invocation-givers, chosen for their ties to the community rather than their faith, and when the Satanic Temple demanded a slot and sued, the First Circuit ruled for the city in 2024: “The Constitution does not require that legislative bodies accept all speakers who request to give invocations.” The difference between Boston and Ottumwa isn’t that one allows prayer and the other doesn’t. It’s a single clause in a policy: invited, or open.

The other two exits are retreats, and the first of them is less stable than it looks. Phoenix tried it in 2016: told a Satanic Temple member was scheduled to pray, the council ended spoken prayer altogether, 5–4, and switched to a moment of silence — after its city attorney warned that hand-picking speakers would be a First Amendment violation the city would “be likely to lose”. The silence lasted seven weeks. On March 2 the same council voted 7–2 to bring spoken invocations back, and later that month passed the ordinance, 6–2, that handed them to the city’s police and fire chaplains. Phoenix did not end up silent. It ended up with a closed roster — the third exit, reached by a longer road. Tulsa, Oklahoma, took the same first step in early 2025, 8–1, and so far has stayed there.

But Tulsa is also the cautionary tale about labels, and the one case here that didn’t come from an open mic at all. What set it off wasn’t Satanic, and it wasn’t a stranger who signed up: in November 2024, a pagan priestess named Amy McAdams, invited by Councilor Crista Patrick, gave an invocation to Medusa — “monstrous hero of the oppressed and abused” — asking the council to be “champions for all in this city, not just those in power.” The governor and the state schools chief branded it “satanic”. Paganism is not Satanism, which is not the Satanic Temple, which is not the Church of Satan — a set of distinctions that tends to collapse the moment someone says the word “Hail.”

The third exit — hand the microphone to a closed roster of official chaplains — belongs to the Kenai Peninsula Borough, Alaska, which ran the entire cycle start to finish. Its original policy limited invocations to groups with an “established presence” on the peninsula; an atheist, a Jewish resident, and the Temple’s Iris Fontana were turned away, sued, and won. The borough was forced open. Fontana gave invocations. Then, on November 7, 2023, the Assembly voted unanimously to restrict invocations to the borough’s volunteer emergency-services chaplains — effective the first of the year. That left a window, and Fontana took it: on December 12 she gave the last public invocation before the policy took effect, reading the same words one final time.

None of this is really about Satan, which is the point the Satanic Temple has been making the whole time. It is about a sentence in a policy. A council that wants a prayer before its meetings has to decide, up front, whether it is inviting a few neighbors or opening a public microphone — because once it opens the microphone, the Constitution won’t let it take the mic back from just one guest. It can go silent for everyone, or live with what it hears; what it cannot do is single out the Temple. The towns that got a Satanic invocation are not unusually cursed, and most of them were not careless either. Ottumwa’s council was warned, in almost these words, and adopted the policy anyway; Kenai had its microphone prised open by a court; San Marcos simply found that nobody else wanted the slot. What they share is a sentence nobody expected anyone to test, and a visitor who turned up to test it.