The 9th Circuit relies only on 5th Amendment Due Process. Doesn’t yet need to reach 1st Am Establishment Clause. February 9, 2017 ~ Tim Hogan Share this: Share on X (Opens in new window) X Share on Facebook (Opens in new window) Facebook Like Loading... Published by Tim Hogan Expat New Englander. BA UMass Amherst. Political Science. Int'l Relations, 中文 Minors. JD, Univ. Hawaii Law Sch. Liberal. Still have my Kennedy Johnson Button. View all posts by Tim Hogan