In Colorado, school district officials announced plans for a permanent memorial to victims of the Columbine High School massacre, and parents of slain students were asked to design and submit their own ceramic tiles for inclusion in the memorial. The families of Daniel Rohrbough and Kelly Fleming submitted several tiles with religious themes, one with thirteen crosses, another with a verse from the Bible. The school district rejected the tiles, apparently fearing a lawsuit based on church-state separation, and returned them to the families. As a result, the families sued the school district for violating their rights. Brian Rohrbough pointed out that his son's killers, Dylan Klebold and Eric Harris, used to sport swastikas in school hallways without encountering similar legal problems.

†