Just a thought while pondering and reading about the big church-state news of the day. Judge Janet Hall's injunction halting a Connecticut school district's plans to use First Cathedral for commencement ceremonies did not in fact rule that any use of a religious building for graduation ceremonies would necessarily be unconstitutional.

She does come close to pointing in that direction (noting for example that some faiths prohibit followers from entering the sanctuary of another religion, putting some students in the position of violating their beliefs merely to attend graduation), but this opinion was pointed especially at the particulars of the facility in question in this case – both its appearance and its history as host to prior graduation events. Judge Hall concluded that Enfield's use of First Cathedral much more closely resembles an arrangement that had previously been found unconstitutional (Spacco v Bridgewater School Dept.) than it did to another instance where a church building had been found a permissible option (Porta v Klagholz). This case, she adds, falls clearly on one side of that spectrum of precedent:

…even if every modification identified in the May 25, 2010 resolution is implemented, those attending the graduation ceremonies at First Cathedral will still encounter: (1) the large cross on the Cathedral’s roof; (2) the large central cross at the Cathedral’s main entrance; (3) the stained glass depiction of worshipers in the Cathedral’s main entrance; (4) the large cross behind the stage that undoubtedly constitutes the focal point of the entire sanctuary.

First Cathedral remains a far more “religious” environment than the vast majority of other publicly-leased religious spaces that have been the subject of Establishment Clause claims.

Still, this opinion allows for the possibility that a church building could still fall within the permissible category. Its reasoning does not lead to a blanket ban on the use of religious structures under the right circumstances.