The precedent set in Walz v. Tax Commission of the City of New York (1970) is one of a constellation of opinions guiding judicial interpretation of the Establishment Clause of the First Amendment to the U.S. Constitution. The Establishment Clause refers to the maxim that governmental bodies “shall make no law respecting an establishment of religion.” This provision and the First Amendment clause guaranteeing the right to exercise religion without governmental interference, the Free Exercise Clause, form the foundation for religious liberty in the United States. What actions result in the “establishment” of religion has engendered significant judicial interpretation during