Abstract
A popular conception about the Religion Clauses of the First Amendment is that the Free Exercise Clause is in tension, or conflict, with the Establishment Clause.1 Accommodation under the Free Exercise Clause seems, in many cases, to conflict with the establishment clause principle that government must neither advance nor favor any religious practice or belief.2 In response to this seeming tension between the two mandates, Jonathan Nuechterlein, in a recent article, advances the theory that contrary to popular belief, the two clauses are not in conflict.3 Rather, the mandates of the two clauses fit together like pieces in a jigsaw puzzle.4 The traditional test of required accommodation under the Free Exercise clause5 employed by the courts define the outer limits of what is allowed under the Establishment Clause.6
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