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At issue in Committee for Public Education and Religious Liberty (PEARL) v. Regan (1980) was the constitutionality of a statute from New York that authorized the use of public funds to reimburse church-related and secular nonpublic schools for performing various state-mandated testing and reporting services. The Supreme Court held that the 1974 New York law was constitutional, because it had a secular purpose, its primary effect did not advance religion, and it did not entangle the state with organized religion. While not recommending the case as “a litmus-paper test to distinguish permissible from impermissible aid to religiously oriented schools” (p. 662), the Court described its judgment as consistent with its historical effort to balance the constitutional mandate to separate church and state with the states' ...

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