From New Jersey to California, Christians are moving to counter years of lawsuits that have made governments wary about putting Nativity scenes on public property, and that occasionally have led schools to drop Christmas carols from holiday programs:

• In Bay Harbor Islands, Fla., a Christian sued in federal court after town officials refused to let her erect a Nativity scene next to a menorah, or Hanukkah candelabra, on a causeway. Last week, a judge ordered the town to comply.

• In Maplewood, N.J., parents and students recently petitioned the local school board after school officials dropped even instrumental versions of Christmas music from class programs.

• In Denver, a Protestant church responded to the city's decision to drop "Merry Christmas" from public signs by trying to enter a Christmas-themed float in the holiday parade. Supporters picketed the parade and sang Christmas carols after the float was rejected.

• In California, a group called the Committee to Save Merry Christmas is boycotting Federated Department Stores. The group claims that Federated's affiliates, including Macy's, prohibit clerks from saying "Merry Christmas" and ban the word "Christmas" from ads and store displays. The retail giant says it has no such policy.

Even Kwanzaa, the African-American harvest celebration, has taken a hit. In Los Angeles, the Rev. Jesse Lee Peterson, a conservative black activist, has urged black Christians to spurn Kwanzaa, which he calls a "pagan holiday."

Julie West is tired of being wished "Happy Holidays" instead of "Merry Christmas." She's annoyed with department stores that use "Season's Greetings" banners, and with public schools that teach about Hanukkah and Kwanzaa but won't touch the Nativity story.

So last week, she sent a baked protest to a holiday party at her first-grade son's school: a chocolate cake with vanilla frosting and red icing that spelled out "Happy Birthday Jesus."