If you’re looking for evidence that Establishment Clause jurisprudence is a mess, look no further than the Sixth Circuit’s decision in Bormuth v. County of Jackson (decided September 6, 2017) and the Fourth Circuit’s decision in Lund v. Rowan County (decided July 14, 2017). Both cases involve the constitutional ity of governmental officials engaging in prayer before a public meeting. Both were decided by en banc circuit courts. And when all the votes in both cases are counted, there were 15 votes striking down legislative prayer, 14 votes upholding the same practice, and one neutral vote that would have remanded for further proceedings. This scenario begs for Supreme Court review. But if that happens, what next?