This paper reviews First Amendment federal court cases pertaining to religion in schools, suggesting that the findings reveal a judiciary uncertain of where to strike a balance between the interests of the majority and the rights of the minority. The first area discussed is public aid to private schools. The cases covered in this discussion illustrate why courts have had difficulty defining with precision the wall separating church from state in private school aid: children benefit from such aid, but so do religious organizations. The next area covered is prayer and Bible reading in public schools, an extraordinarily sensitive component of constitutional law on account of the religious diversity and the sense of duty to individual principle inherent in our populace. The third area of litigation discussed is student religious meetings in public school facilities, because this issue is affected by the Equal Access Act (1984). This is followed by a discussion of the regulation of parochial schools, an area characterized by conflict between the compelling state interest in high-quality education for all children and the constitutional rights of those children who attend parochial schools and their parents. The conclusion suggests that jurists are unlikely to develop unambiguous criteria for delineating the proper distance between church and state. Notes are included. (TE)