This Note’s analysis proceeds in four parts. Part II discusses the growing impossibility of achieving “state neutrality” which is a key element of the principle of nondiscrimination in religion. It also discusses the increase in religious diversity and secularism worldwide and its effect on the relationship between church and state. Part III explores how the Supreme Court’s Religion Clause jurisprudence concerning religious organizations receiving government benefits has evolved. Part IV discusses the PPP, including its advantages and disadvantages. Part V examines Germany’s “Church Tax” system and its potential use in the United States to mitigate the impact of a future crisis and prevent further deterioration of the Establishment Clause in future crisis relief programs.
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