<P> The required beliefs of these clauses include belief in a Supreme Being and belief in a future state of rewards and punishments . (Tennessee Constitution Article IX, Section 2 is one such example .) Some of these same states specify that the oath of office include the words "so help me God ." In some cases these beliefs (or oaths) were historically required of jurors and witnesses in court . At one time, such restrictions were allowed under the doctrine of states' rights; today they are deemed to be in violation of the federal First Amendment, as applied to the states via the 14th amendment, and hence unconstitutional and unenforceable . </P> <P> While sometimes questioned as possible violations of separation, the appointment of official chaplains for government functions, voluntary prayer meetings at the Department of Justice outside of duty hours, voluntary prayer at meals in U.S. armed forces, inclusion of the (optional) phrase "so help me God" in the oaths for many elected offices, FBI agents, etc., have been held not to violate the First Amendment, since they fall within the realm of free exercise of religion . </P> <P> Relaxed zoning rules and special parking privileges for churches, the tax - free status of church property, the fact that Christmas is a federal holiday, etc., have also been questioned, but have been considered examples of the governmental prerogative in deciding practical and beneficial arrangements for the society . The national motto "In God We Trust" has been challenged as a violation, but the Supreme Court has ruled that ceremonial deism is not religious in nature . A circuit court ruling affirmed Ohio's right to use as its motto a passage from the Bible, "With God, all things are possible", because it displayed no preference for a particular religion . </P> <P> Jeffries and Ryan (2001) argue that the modern concept of separation of church and state dates from the mid-twentieth century rulings of the Supreme Court . The central point, they argue, was a constitutional ban against aid to religious schools, followed by a later ban on religious observance in public education . Jeffries and Ryan argue that these two propositions--that public aid should not go to religious schools and that public schools should not be religious--make up the separationist position of the modern Establishment Clause . </P>

The founding fathers chose to ensure religious freedom in the first amendment in order to -