“The City considers ‘established presence in the local community of Pompano Beach’ as an individual or religious organization that has a physical or active presence in Pompano Beach…
…including participation in local city events, i.e. memorial ceremonies.”

That language is not mine.
It comes straight out of the City’s records.

And it doesn’t appear anywhere in the City’s published Invocation Policy.

That’s the story.

What I Asked — and Why

I didn’t ask who should give invocations.
I didn’t ask who deserves the microphone.

I asked something dull and administrative:

How does the City decide who gets approved, and who gets denied, to give an invocation at City Commission meetings?

That question matters because invocation programs survive constitutional scrutiny only if they are:
neutral, open, and administered under knowable rules.

Process, not piety.

The Clerk Did His Job

Quickly and plainly:
The City Clerk’s Office was professional, responsive, and cooperative. Records were produced. Links were provided. Nothing was stonewalled.

This isn’t a transparency fight.
It’s a governance one.

What the Records Show

1. The City Tracks Outcomes, Not Decisions

The City produced full invocation schedules for 2024 and 2025.

They show a familiar pattern:
the same clergy, the same churches, rotating through the calendar.

This answers one question cleanly: who spoke.

It does not answer:

• who applied,
• who was rejected,
• or how eligibility was determined.

2. There Are No Approval or Denial Records

When I asked for records showing approval, rejection, deferral, or removal of invocation speakers, the City responded:

No records responsive.

Not “we denied some.”
Not “we approved others.”
Not even “we decide verbally.”

Just: no records.

That matters because without a record of a decision, there is nothing to challenge.
No notice.
No appeal.
No review.

That’s not a stylistic concern.
That’s a due-process failure.

3. Eligibility Lives in Email, Not Law

The City did produce internal communications discussing eligibility.

They rely on phrases like:

• “established presence”
• “physical or active presence”
• “ongoing dealings within the city”
• “participation in “memorial ceremonies”

That language functions as a rule.
But it is not an adopted rule.

This is administrative creep:
staff-level interpretation quietly becoming the law without legislative adoption or public notice.

A shadow policy.

4. Discretion Exists — and It’s Undocumented

Here’s where it gets more concrete.

Participation in City memorial ceremonies is treated as evidence of eligibility.

Ask the obvious follow-up questions:
Which ceremonies count?
Who decides that?
How is participation verified?
What happens if someone is excluded?

There are no written standards answering any of that.

So discretion lives here:
in subjective judgments about “engagement” and “presence,”
applied through email,
without documentation.

That’s not neutral administration.
That’s informal gatekeeping.

Why This Is a Problem (Even Without Bad Motives)

This isn’t about religion.
It’s about auditability.

A system that cannot produce:

a denial record

an eligibility worksheet
a decision memo

…cannot be meaningfully reviewed.

Courts don’t ask whether officials meant well.
They ask whether the system is capable of neutral operation.

Right now, this one isn’t.

Not because anyone is hostile.
Because the rules are unwritten, and the decisions leave no trace.

The Quiet Risk

Today’s applicants may all be familiar names.
Tomorrow’s applicant might not be.

When that person is told “no,” there will be:
no written denial,
no cited standard,
no decision-maker on record.

Just a shrug and a precedent list.

That’s how constitutional violations happen quietly.

The Fix Is Boring — and Necessary

Write the criteria.
Adopt them formally.
Apply them consistently.
Document the decisions.

That’s it.

Until then, the invocation program runs on institutional memory and informal discretion.

The records show that clearly.

And records don’t lie.

Process beats outrage.
Documentation beats intent.
And unwritten rules always choose winners.

— Chaz Stevens
REVOLT Training