"the combined display of the tree, the sign, and the menorah ... simply recognizes that both Christmas and Hanukkah are part of the same winter-holiday season, which has attained a secular status in our society." In Lynch v. Donnelly the Supreme Court also developed with the endorsement test a further test to determine the constitutionality under the Establishment Clause of certain government actions. In 2001, Roy Moore, then Chief Justice of Alabama, installed a monument to the Ten Commandments in the state judicial building. In 2003, he was ordered in the case of Glassroth v. Moore by a federal judge to remove the monument, but he refused to comply, ultimately leading to his removal from office. The Supreme Court refused to hear the case, allowing the lower court's decision to stand. On March 2, 2005, the Supreme Court heard arguments for two cases involving religious displays, Van Orden v. Perry and McCreary County v. ACLU of Kentucky. These were the first cases directly dealing with display of the Ten Commandments the Court had heard since Stone v. Graham (1980). These cases were decided on June 27, 2005. In Van Orden, the Court upheld, by a 5–4 vote, the legality of a Ten Commandments display at the Texas State Capitol due to the monument's "secular purpose". In McCreary County, however, the Court ruled 5–4 that displays of the Ten Commandments in several Kentucky county courthouses were unconstitutional because they were not clearly integrated with a secular display, and thus were considered to have a religious purpose. Blue laws In the 1964 case McGowan v. Maryland, the Supreme Court held that blue laws which restricted the sale of goods on Sundays (and were originally intended to increase Church attendance) did not violate the Establishment Clause because they served a present secular purpose of providing a uniform day of rest for everyone. See also Faith-based initiatives Lassonde v. Pleasanton Unified School District No Religious Test Clause Separation of church and state in the United States Torcaso v. Watkins United States religious history References Research resources First Amendment Library entry for Establishment Clause Cases (with links to all of the Supreme Court's Establishment Clause cases) Defending Jefferson's "wall of separation" metaphor Religious Expression in American Public Life: A Joint Statement of Current Law Further reading Royal C. Gilkey, "The Problem of Church and State in Terms of the Nonestablishment and Free Exercise of Religion",