The Religion Clauses of the First Amendment direct the separation of church
and state and protect the free exercise of religion. Despite their positio
n at the very beginning of the Bill of Rights, the Establishment and Free E
xercise Clauses only attained their modem meaning within roughly the last h
alf of the twentieth century. For much of that time, the Supreme Court's ap
proach to the Free Exercise Clause was exemplified by the cases of Sherbert
v. Verner and Wisconsin v. Yoder, while the Establishment Clause was imple
mented through the multipart test articulated in Lemon v. Kurtzman. A princ
ipled reading of these two areas of case law revealed a tension between acc
ommodations required under the first and limitations on government action i
mposed by the second. In recent years, the Court has substantially revised
its approach to nearly all facets of the Religion Clauses, but the resultin
g body of law is highly unstable. Nevertheless, some general themes are app
arent, including the rise of a position of "neutrality" towards religion an
d a general approach that appears less separationist and more accommodating
of mainstream religions.