De facto coerced prayer already has returned. Remember the case of that high school football coach who conducted very loud, very public prayer meetings after games? The school district told him to stop, because several players were saying that they felt coerced to pray. They were saying that they felt if they didn't participate, they would be on the coach's bad side.

Well, with the help of religious liberty advocates, the coach sued, and his case went all the way to the Supreme Court.

The majority ruled, in essence, that the players' reasonable fears of coercion were not important.