<P> In Lemon the Court stated that the separation of church and state could never be absolute: "Our prior holdings do not call for total separation between church and state; total separation is not possible in an absolute sense . Some relationship between government and religious organizations is inevitable", the court wrote . "Judicial caveats against entanglement must recognize that the line of separation, far from being a' wall', is a blurred, indistinct, and variable barrier depending on all the circumstances of a particular relationship ." </P> <P> Accommodationists, in contrast, argue along with Justice William O. Douglas that "(w) e are a religious people whose institutions presuppose a Supreme Being". This group holds that the Lemon test should be applied selectively . As such, for many conservatives, the Establishment Clause solely prevents the establishment of a state church, not public acknowledgements of God nor "developing policies that encourage general religious beliefs that do not favor a particular sect and are consistent with the secular government's goals ." </P> <P> "Freedom of religion means freedom to hold an opinion or belief, but not to take action in violation of social duties or subversive to good order ." In Reynolds v. United States (1878), the Supreme Court found that while laws cannot interfere with religious belief and opinions, laws can regulate some religious practices (e.g., human sacrifices, and the now obsolete Hindu practice of suttee). The Court stated that to rule otherwise, "would be to make the professed doctrines of religious belief superior to the law of the land, and in effect permit every citizen to become a law unto himself . Government would exist only in name under such circumstances ." In Cantwell v. Connecticut (1940), the Court held that the Due Process Clause of the Fourteenth Amendment applied the Free Exercise Clause to the states . While the right to have religious beliefs is absolute, the freedom to act on such beliefs is not absolute . </P> <P> In Sherbert v. Verner (1963), the Supreme Court required states to meet the "strict scrutiny" standard when refusing to accommodate religiously motivated conduct . This meant that a government needed to have a "compelling interest" regarding such a refusal . The case involved Adele Sherbert, who was denied unemployment benefits by South Carolina because she refused to work on Saturdays, something forbidden by her Seventh - day Adventist faith . In Wisconsin v. Yoder (1972), the Court ruled that a law that "unduly burdens the practice of religion" without a compelling interest, even though it might be "neutral on its face", would be unconstitutional . </P>

The free exercise clause is a part of which freedom in the bill of rights