United States Supreme Court Justice Clarence Thomas writing for a plurality of the Court in "Mitchell v. Helms" in 2000 advanced the idea that state constitutional prohibitions against public funding of religious schools were manifestations of anti-Catholic bigotry in the late 19th century. Thomas' reading of history and law led him to…

From 19th-century Protestant hegemony to today's religion-free zones, we have found no proper, constitutional role for religion and religious expression in public education. Both models are unjust and, in some cases, unconstitutional. A third model, composed of consensual guidelines, must be translated into local district policies and practices.…