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more difficult for the schools to operate. But such is obviously not the purpose of the First
               Amendment.”)
               19  See Witters v. Washington Dept. of Services for the Blind, 474 U.S. 481 (1986)
               (allowing vocational assistance for the blind); Zobrest v. Catalina Foothills Sch. Dist., 509
               U.S. 1 (1993) (allowing sign-language interpreter); Zelman v. Simmons-Harris, 536 U.S.
               639 (2002) (allowing tuition vouchers).
               20  See, e.g., Watson v. Jones, 80 U.S. 679, 728 (1871) (“The law knows no heresy, and is
               committed to the support of no dogma, the establishment of no sect.”); West Virginia State
               Bd. of Education v. Barnette, 319 U.S. 624, 642 (1943) (“If there is any fixed star in our
               constitutional constellation, it is that no official, high or petty, can prescribe what shall be
               orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to
               confess by word or act their faith therein.”)
               21  See, e.g., Thomas v. Review Board, 450 U.S. 707, 717 (1981) (“Courts are not arbiters
               of scriptural interpretation.”) See also Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (1952)
               (First Amendment assures “a spirit of freedom for religious organizations, an independence
               from secular control or manipulation, in short, power to decide for themselves, free from
               state interference, matters of church government as well as those of faith and doctrine.”)
               22  See, e.g., Edwards v. Aguillard, 482 U.S. 578 (1987) (striking down law requiring
               “balanced treatment” of evolution and creationism in public schools); Epperson v.
               Arkansas, 393 U.S. 97 (1968) (striking down law prohibiting teaching of evolution in
               public schools and universities); School Dist. of Abington v. Schempp, 374 U.S. 203
               (1963) (striking down daily Bible reading and recitation of Lord’s Prayer in public schools);
               Engel v. Vitale, 370 U.S. 421 (1962) (striking down teacher-led recitation of “Regents’
               prayer” in public school).
               23  See, e.g., Committee for Public Education v. Nyquist, 413 U.S. 756 (1973) (applying
               Establishment Clause to strike down various forms of direct state aid to parochial
               schools).
               24  See Abington Twp. School Dist. v. Schempp, 374 U.S. 203, 225 (1963) (“It might well
               be said that one’s education is not complete without a study of comparative religion or the
               history of religion and its relationship to the advancement of civilization. It certainly may
               be said that the Bible is worthy of study for its literary and historic qualities. Nothing we
               have said here indicates that such study of the Bible or of religion, when presented
               objectively as part of a secular program of education, may not be effected consistently with
               the First Amendment.”); Stone v. Graham, 449 U.S. 39, 42 (1980) (noting that “the Bible
               may constitutionally be used in an appropriate study of history, civilization, ethics,
               comparative religion, or the like”).
               25  See, e.g., Van Orden v. Perry, 544 U.S. 677 (2005) (upholding Ten Commandments
               display); McCreary County v. ACLU of Ky., 545 U.S. 844 (2005) (striking down Ten
               Commandments display); Allegheny County v. ACLU of Pittsburgh, 492 U.S. 573 (1989)
               (upholding holiday display consisting of crèche and menorah, but striking down crèche-
               only display); Lynch v. Donnelly, 465 U.S. 668 (1984) (upholding display consisting of
               crèche and secular elements).
               26  Lynch v. Donnelly, 465 U.S. 668, 673 (1984) (quoting Zorach v. Clauson, 343 U.S.
               306, 314 [1952]).
               27  See Marsh v. Chambers, 463 U.S. 783 (1983) (rejecting Establishment Clause
               challenge to legislative prayer because it represents permissible “civil religion”). See also
               Declaration of Independence, preamble (the people are “endowed by their Creator with


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