In Trinity Lutheran Church of Columbia, Inc. v. Comer, the Supreme Court held that a State’s policy of prohibiting a church’s participation in a government benefit program, simply because it was a church, violated the Free Exercise Clause. This Comment argues that this holding is consistent with the history and precedent reinforcing government neutrality toward religion. The Religion Clauses, instead, prohibit government endorsement of a particular religious message and prohibit government discrimination based on religious identity. Furthermore, this Comment argues that future Trinity cases will hinge on how the reviewing court (1) defines the government benefit at issue and (2) determines if the funding at issue amounts to support of an essentially religious endeavor. This analysis is particularly important as religious groups continue to develop social enterprises and provide public services.
