“In general, before, during and after the ratification of the First Amendment,24 public schools were seen as an environment friendly to religion. Indeed, religion was viewed as necessary to accomplish the purpose for which public schools were organized, whether that be religious inculcation or societal stability. However, the problems caused by the plurality's assessment of religion's role in public education, as a practical matter, were confronted even at a time when society was much more homogeneous than it is today” (Fuller, 92).