In this case, The Satanic Temple Inc. and Mortimer Adramelech v. Mark Campbell, Adam Steen, and the Iowa Department of Administrative Services, we see a group of individuals seeking to freely exercise their religion within the Iowa State Capitol building. However, this practice is extremely controversial and complicated for a few reasons that we’ll dive into a little further.
The Satanic Temple sought permission to hold a one-day holiday event in the Iowa State Capitol Rotunda. This event would take place on December 12, 2026. At this event, attendees would engage in many activities such as different rituals, caroling, coloring pages for children, ornament-making for families, etc. However, the event would also include a Krampus costume contest, and this causes some concern for certain individuals.
The group had previously sought to hold events very similar to this one in 2024 and 2025 and the Iowa State Department of Administrative Services denied those applications. There was an approved event in 2023 where the group was permitted to hold a display in the Capitol alongside other groups and their displays. The Satanic Temple chose to erect a display of “Baphomet” which became controversial and was destroyed by a man who traveled all the way from Mississippi to do so. The reason for the 2024 denial was in part due to the prior vandalism, but was largely centered around the costume contest. “Krampus” is a horned figure, said to be half-goat, half-demon, and he traditionally accompanies Santa Claus during the Christmas season, most of the time carrying sticks. Legend has it that while Santa rewards well behaved children with gifts, Krampus punishes misbehaving children. Director Adam Steen, after reviewing photos of the proposed costumes, cited concerns that allowing this event to take place in the State Capitol building would be dangerous as the sticks could be used as weapons against children, and also that the event could be “harmful to minors.” After this denial The Satanic Temple offered to eliminate the costume contest and modify the event but the Department never responded to this offer. When the same application was submitted in 2025, the Department again denied it in a short email, and the event was held somewhere else.
Now in 2026, a third application was submitted back in March regarding the potential event this upcoming December. The Department initially showed some cooperation. However, Director Mark Campbell has since formally denied the application, stating that it was the very same event that had previously been rejected time and time again. Because of this, The Satanic Temple sued on claims of prohibited free speech under the First Amendment, as well as violations of the Free Exercise Clause, and concerns about equal protection. They sought a preliminary injunction requiring the State of Iowa to allow their event to proceed.
In the preliminary injunction hearing the court concluded on the following. Rather than conducting his own review, Director Campbell largely relied on Steen’s denial. In addition to that, neither one of the individuals did nearly enough research into the figure Krampus in order to make an informed decision. Less restrictive means were never considered. The denial focused more on the message or symbolism of Krampus more than any actual safety threat. And finally, the Capitol had security procedures in place to help maintain safety at the event. While no official decision has been made regarding the lawsuit, the court granted the injunction and ordered The Satanic Temple’s 2026 event application to be approved by the Department.
The constitutional question at hand in this case seems pretty straight forward at face value but answering it can become quite complex. The question I would like to address is whether or not The Satanic Temple is allowed and protected by the constitution of the United States to hold its holiday event in the Iowa State Capitol building.
From a Free Exercise perspective, The Satanic Temple as a religious group has been repeatedly burdened by the state because of its religious practices, specifically, its attempt to hold a holiday event in the State Capitol building and being denied numerous times while other religious groups had been permitted to do the exact same thing. This event was part of The Satanic Temple’s religious expression, and the denial was due to judgments about the content of the religion rather than any legitimate safety threat. The event was referred to as “evil” by Campbell and Steen, showing a great deal of hostility toward the religion because of their choice of expression, and this allows us to draw on precedents from cases like Church of Lukumi Babalu Aye v. Hialeah where government action based on hostility raises a great deal of skepticism when violations of free exercise are in question.
The question of a compelling state interest must be considered. The Department made claims of increased danger because of the event. But, the counter argument could be the fact that the Capitol had procedures in place to make sure that no dangerous objects entered the building. In my mind, this significantly weakens the argument of a compelling state interest because of “sticks” at a costume contest. If the compelling state interest is due to the potential harm done to minors because of the content, message, or symbolism being promoted at the event, that begins to blur the line between judging belief and action.
From an Establishment perspective, we must consider the issue of neutrality. The Capitol regularly permitted Christmas trees, nativity scenes, menorahs, and other holiday displays. One could say, “Well, those displays have long-standing historical significance since the religions they represent have been around for a long time.” This is unconstitutional. To say that one religion should be allowed but another should not simply based on how long each religion has been around is in violation of the First Amendment as it seeks to protect minority religions. If officials approved Christian holiday expression but excluded Satanic holiday expression because they considered it offensive, “scary,” or immoral, that suggests endorsements of some religious viewpoints over others, which is unconstitutional. The Establishment Clause prohibits the state from having the ability to decide which religions are acceptable or deserving of access to public forums.
I don’t think The Satanic Temple should have had its application denied time and time again simply because people don’t agree with their religious viewpoints. If safety were a legitimate concern, and there was enough of a compelling state interest I would have a harder time providing such an accommodation to this religious practice, however, the group agreed to modify its event, and on top of that, the state had security measures in place to ensure safety was maintained. I also don’t think the state should have the ability to restrict certain groups like The Satanic Temple from participating in this open forum while allowing groups of other religious faiths to freely practice and hold events. I would therefore deem the denials of The Satanic Temple’s holiday event in the Iowa State Capitol building unconstitutional under the First Amendment.
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