Edwin Gaustad, professor of history at the University of California, Riverside, asserted in 1985:

Some recent discussion has suggested that the founding fathers thought they were guaranteeing only a freedom for religion, not a freedom from religion. This is surely true of neither Madison nor Jefferson, nor of Baptists who followed in their train. John Leland, an eighteenth-century Baptist itinerant in Virginia, argued that whether a man believed in one god, twenty gods, or no god was not the concern of the state. Religion is not in any direct way the concern of the state, he further declared. The law should not favor ministers, nor should it penalize them. "The law should be silent about them: protect them as citizens, not as sacred officers, for the civil law knows no sacred officers."

In the inevitable interaction between the civil and the ecclesiastical estates, what is a legitimate entanglement and what is an excessive or totally inappropriate entanglement? What are the boundaries that must not be overstepped, whether on theological or moral or Constitutional grounds? Supreme Court justices over the years, and especially in the last four decades, have not found easy answers to those questions. Nor have the leaders of virtually all denominations in America found the lines clear and the answers easy. The application of principle is more difficult than the assertion of it.

On theological grounds, the state has no right to be the armed avenger against "false" religion nor the armed defender of "true" religion. On Constitutional grounds, the state has no right to be either religion's foe or religion's patron. On theological and moral grounds, the churches have no right to coerce the consciences of others: on theological and moral and constitutional grounds, the churches have every right to organize, propagandize, persuade, influence, lobby and cajole. In between such broad declarations of principle, there is room for much disagreement and discord and litigation and confusion and (in the words of Chief Justice Burger) "play in the joints."