The Fourth Circuit (O’Connor, Assoc. J., sitting by designation) has issued a decision (PDF) upholding the Fredericksburg (Va.) City Council’s practice of opening each meeting with a non-denominational prayer made by a member. Nothing earth shattering in the opinion, which relies on Marsh v. Chambers, 463 U.S. 783 (1983) and its own decision in Simpson v. Chesterfield Co. Bd. of Supervisors, 404 F.3d 276 (4th Cir. 2005).