"I know what an Act to make things simpler means. It means that the people who drew it up don't understand it themselves and that every one of its clauses needs a law-suit to disentangle it."

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A profession that we are a nation "under God" is identical, for establishment clause purposes, to a profession that we are a nation "under Jesus," a nation "under Vishnu," a nation "under Zeus," or a nation "under no god," because none of these professions can be neutral with respect to religion.

— Alfred Goodwin