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The Lemon test is applied to determine when a law has the effect of establishing a religion. It was formulated by Chief Justice Warren Burger for the majority opinion in Lemon versusKurtzman (1971).

Lemon challenged Rhode Island and Pennsylvania programs supplementing religious, private-school teacher salaries for including secular subjects in the curriculum. The Court ruled that these programs violated the establishment clause.

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Q: Why did they create the lemon test?
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