The 'wall of separation between church and state' is a metaphor based on bad history, a metaphor which has proved useless as a guide to judging. It should be frankly and explicitly abandoned.
It is impossible to build sound constitutional doctrine upon a mistaken understanding of Constitutional history... The establishment clause has been expressly freighted with Jefferson's misleading metaphor for nearly forty years... There is simply no historical foundation for the proposition that the framers intended to build a wall of separation... The recent court decisions are in no way based on either the language or intent of the framers.
The "wall of separation between church and State" is a metaphor based on bad history.
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