Zobrest v. Catalina Foothills School District

The U.S. Supreme Court has long affirmed the right of parents to send their children to parochial, or church-run, schools. However, the Court has acknowledged that there are limits to the type of assistance that states can provide to these schools and their students. Too much aid, or the wrong type of aid, can be challenged on the basis of the First Amendment's Establishment Clause prohibiting the establishment of a religion by the state. In numerous cases over the decades, the Court has struggled to define the limits of state aid to religious education. In some instances, it has issued bizarre or seemingly contradictory rulings. When the Court determined that a state could loan textbooks to religious schools, but not maps, an exasperated Sen. Daniel Patrick Moynihan was heard to remark, "What about atlases, or books of maps?" It was in this atmosphere of unclear boundaries that Zobrest v. Catalina Foothills School District was played out in 1993.