invalidation of the challenged law. In his written dissent, Justice Rutledge argued: The funds used here were raised by taxation. The Court does not dispute nor could it that their use does in fact give aid and encouragement to religious instruction. It only concludes that this aid is not 'support' in law. But Madison and Jefferson were concerned with aid and support in fact not as a legal conclusion 'entangled in precedents.' Here parents pay money to send their children to parochial schools and funds raised by taxation are used to reimburse them. This not only helps the children to get to school and the parents to send them. It aids them in a substantial way to get the very thing which they are sent to the particular school to secure, namely, religious training and teaching. 330 U.S. 1, 45. Aftermath In its first 100 years, the United States Supreme Court interpreted the Constitution's Bill of Rights as a limit on federal government and considered the states bound only by those rights granted to its citizens by their own state constitutions. Because the federal laws were then remote influences on most on the personal affairs of its citizens, minimal attention was paid by the Court to how those provisions in the federal Bill of Rights were to be interpreted. Following the passage of the Thirteenth to the Fifteenth Amendments to the Constitution at the end of the American Civil War, the Supreme Court would hear hundreds of cases involving conflicts over the constitutionality of laws passed by the states. The decisions in those cases were often criticized as resulting more from the biases of the individual Justices than the applicable rule of law or constitutional duty to protect individual rights. However, by the 1930s, the Court began consistently reasoning that the Fourteenth Amendment guaranteed citizens First Amendment protections from even state and local governments, a process known as incorporation. The 1940 decision in Cantwell v. Connecticut was the first Supreme Court decision to apply the First Amendment's religious protections to the states. The case focusing on the so-called Free Exercise Clause. Everson followed in 1947 and was the first decision that incorporated the Establishment Clause. Numerous state cases followed disentangling the church from public schools, most notably the 1951 New Mexico case of Zellers v. Huff. Similar First Amendment cases have flooded the courts in the decades following Everson. Having