Justice Breyer in the landmark case of Van Orden v Perry clearly espouses that the primary goal of the Establishment clause is to quell any doubts as to what constitutes monuments of historical meaning and what would bring about religious divisiveness. The issue of what would amount to divisiveness is an empirical question for which there is no standard unit of measure. The Park Board needs to restrain itself to the fundamental issue at hand as to whether permitting the erection of the monument would bring about a crack in society. The truth of the matter is that the more the Board becomes involved in religious matters, the greater the chances of the existence of social divisions based on religion. Should the board allow for the erection of
