Using recent establishment clause decisions concerning vocal prayer, silent meditation, and prayer groups in the public schools, this article suggests that courts have applied the seemingly consistent doctrine of the tripartite test to arrive at quite different results, based in part on extralegal sources. Two such sources are the attitudinal variance among judges and the practical posture provided by administrators. The latter source, as exemplified in the prayer-group cases, can be an important and sometimes ironic influence on the judicial outcome. Hence, those school districts that seek to disallow access to such groups could do so either by developing a policy that severely limited extracurricular activities or, under a more open policy, by allowing access but maximizing sponsorship, support, and supervision. It is argued that school districts that seek to accommodate such groups should have an expansive policy that does not mention religion and that keeps involvement to a minimum. (Author/TE)