Well, if you can argue your young daughter is being "indoctrinated" with Christianity and you are an atheist, you can completely destroy your wife's lifestyle.
As an evangelical, everything we do revolves around other Christians. We go to skating night, special education events, potlucks, picnics, Christian music concerts, coffees, and of course services.
So if he could extend this to bringing her no place a prayer was offered, he could totally divest his wife and daughter of friendship and support.
Sociopaths will try any trick in the book to "win". He doesn't care about his daughter.