1968 Nonpublic Elementary and Secondary Act violated the Establishment Clause of the First Amendment. The act established a system that had the public school system financially aiding nonpublic, and usually Catholic, schools for their school's expenses. The court decided that the act was unconstitutional, and their decision established the "Lemon Test" which offered a three-pronged approach to religion related cases. In Lynch v. Donnelly, the Supreme Court was faced with another issue with the Establishment Clause of the First Amendment. It was alleged that the seasonal Christmas display that included a crèche in Pawtucket, Rhode Island was unconstitutional and in violation of the Establishment Clause. Daniel Donnelly filed suit against Pawtucket mayor, Dennis Lynch and won in both the District Court and the Court of Appeals. However the U.S Supreme Court overturned the past decisions and ruled that the Christmas display was not a government endorsement of any particular message and did not violate the Establishment Clause. In County of Allegheny v. ACLU, two separate holiday displays in Pittsburgh, Pennsylvania were challenged by the American Civil Liberties Union. The first display was a Christian nativity scene inside the Allegheny County Courthouse. The other display was a large Hanukkah menorah placed outside the City-County building. The court found the crèche in violation of the Establishment Clause because they felt the main purpose of the display was to endorse religion. However, the same court ruled that the menorah was within constitutional appropriateness because of its "particular physical setting." All of these court cases, along with the numerous others, show that American courts have not articulated a consistent, clear rule explaining the government's relationship to religious expression, particularly if that expression occurs in government-supported settings. The Supreme Court is still searching for a consistent rationale for deciding cases in which the First Amendment's speech and establishment clauses intersect. See also Lemon v. Kurtzman Lynch v. Donnelly County of Allegheny v. ACLU Endorsement test With God, all things are possible References External links United States Supreme Court cases United States Free Speech Clause case law Establishment Clause case law 1995 in United States case law History of racism in Ohio Ku Klux Klan United States Supreme Court cases of the Rehnquist Court