The last decade of the 20th century has brought ferment and change in the American constitutional law concerning religious liberty. Change has come on several fronts. Throughout the 1990s, the U.S. Supreme Court and the Congress have battled over the scope of the right to free exercise of religion. First the Court narrowed the right dramatically, then Congress responded with a statute “restoring” the previous broader standard, only to see the Court invalidate the statute within four years. In addition, the prospect of full-blown government aid to religiously affiliated schools and other institutions came much closer to reality by 2000, as the Supreme Court grew more approving of such aid and as cities and states dissatisfied with the performance of public schools and government welfare agencies turned to assisting private and “faith-based” organizations as alternatives.