Scholars examining the controversy over church-state relations in the modern era have concentrated almost exclusively on its constitutional aspects. This is to be expected since the U.S. Supreme Court has handed down epic decisions that have drawn an increasingly sharper picture of the First Amendment's guideline concerning the government's involvement in religion. The Court did, in fact, lead the way in establishing or reestablishing the doctrine called “separation of church and state.” But the Court touched off a furious debate within the states that has intermittently yet persistently influenced public policy since the early 1960s. It is time that scholars examine more closely the participants outside of the Court.