And yet, Justice Sandra Day O’Connor in 1984 argued that the use of religious phrases and symbols in the public square can often have no religious significance. They merely “ceremonial Deism” — the use of religion to make a point involving civic engagement — she said, quoting Dean Eugene V. Rostow of the Yale Law School. She acknowledged that government “sponsorship of a religious message” may send a message to “nonadherents that they are outsiders, not full members of the political community, and an accompanying message to adherents that they are insiders, favored members of the political community” and said the court’s duty is to determine whether official use of religious language or symbolism “endorses” one religion at the expense of all other ones.