Zorach v. Clauson

Although Zorach is at odds with other Supreme Court precedents, it has evolved into the Lemon test for acceptable state accommodation of religion.

In the 1940s, New York City adopted a program of "released time" that permitted public school students to take time off during the normal school day to attend religious instruction away from the actual school premises. Tessim Zorach, together with other taxpayers and parents in New York, brought suit against Andrew Clauson and other members of the city school board, challenging the program. After a series of New York state courts rejected his challenge, Zorach took his case to the U.S. Supreme Court.