In Locke v. Davey, the United States Supreme Court held that a state-sponsored scholarship program that excluded students who were majoring in devotional theology did not violate the Free Exercise Clause of the United States Constitution. The Court's holding left a great deal of uncertainty on when states may withhold benefits on the basis of religion.
"Locke v. Davey: The Fine Line Between Free Exercise and Establishment,"
Mercer Law Review: Vol. 56:
3, Article 13.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol56/iss3/13