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Similar First Amendment cases have flooded the courts in the decades following Everson.
Having invoked Thomas Jefferson's metaphor of the wall of separation in the Everson decision, the lawmakers and courts have struggled how to balance governments ' dual duty to satisfy both the nonestablishment clause and the free exercise clause contained in the language of the amendment.
The majority and dissenting Justices in Everson split over this very question, with Rutledge in the minority by insisting that the Constitution forbids " every form of public aid or support for religion ".

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