Yes, Virginia, there is an Establishment Clause

FFRF’s Winter Solstice display returned to the Loudoun County Courthouse, Leesburg, Va., this season with the help of local activist Ken Levesque (pictured). Ken and other members had also received FFRF’s help with an outdoor display to counter a nativity scene in 2009 that has been placed prominently at the courthouse for many years. Following state-church complaints, the county adopted a “public forum” policy and designated spots for 10 displays. FFRF’s was the second one posted.

Freedom From Religion Foundation