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The First Amendment to the United States Constitution prevents states from passing laws that purposefully advance or prohibit religion, thereby ensuring the separation of church and state.  In Zelman v. Simmons-Harris, the Supreme Court considered whether a state instituted school voucher program (Program) in which the majority of students used their vouchers to attend private religious institutions unconstitutionally advanced religion.  The Court held that the Program does not violate the Establishment Clause because it permits individuals to choose public, secular or non-secular private institutions, and is therefore neutral to religious beliefs. . . .