From the beginning of modern religious-liberty jurisprudence, the most difficult and penetrating questions about the proper relationship between church and state have arisen with special frequency, controversy, and fervor in the often-charged atmosphere of education. As Professor Joseph Viteritti notes, “As far back as can be remembered, religion has been at the center of American education, as a source of both inspiration and agitation.” Likewise, Professor Thomas Berg observes that “religion and education are perennially mixing.” When reviewing the battles about when the state must accommodate the religious demands of individual citizens and how the government should balance recognition of religious traditions in American history against the prohibition on government endorsement of religion, we find that school boards, school administrators, teachers, students, and their parents have often occupied the front lines.