Thomas v. Review Ed. of the Indiana Employment Security Div. Whether or not other practitioners of Wicca hold different beliefs is not determinative. According to expert testimony, Wicca is a neopagan religion having its roots in pre-Christian Europe. Wicca accepts a number of Deities representing things found in nature. In doing this, Wiccans use elements representing air, earth, water, and fire.
Incense represents air.
Wicca is not a doctrinaire set of beliefs, but is more akin to a set of practices which vary between groups and between individual practitioners. There are more solitary practitioners than group practitioners of Wicca. Marsh is a solitary practitioner. It is possible to cast a Wiccan circle without the use of incense. However, many Wiccans believe that incense is necessary to cast a circle.