The separation of church and state has been a long-debated topic in American history. Although founded on Christian ideals, the framers of the Constitution explicitly established that the government would function in a secular manner, in what is commonly referred to as the “Establishment Clause.” When interpreting the Constitution as it pertains to religion, there are two main philosophies. The first philosophy this article will explore will be called Positive Tolerance. Overall, the idea of ​​positive tolerance creates an encouraging environment for all religions. The second philosophy, which will be called the “Wall of Separation,” encourages government freedom from religion. While these two philosophies have historically trended back and forth in public popularity, as America moves into the future, the Separation Wall philosophy will take hold and set the stage for how the Establishment Clause will affect local government, schools and private religious practice. The legal basis for religious freedom cases is based in the First Amendment of the United States Constitution. The First Amendment states: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or restrict freedom of speech or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances. From this statement two schools of interpretation were born. The first school of thought, Positive Tolerance, was championed by Roger Williams. His philosophy centers on the idea that government has a duty to create an environment in which religion is not inhibited by government. Williams argued that the church needed…half the paper…holder. The court's opinion was delivered by Justice Black, who states: “there is, and cannot be, any controversy as to the purpose or effect of the requirements of the Maryland Bill of Rights before us – establishes a test religious that is designed to and, if valid, prohibits anyone who refuses to declare a belief in God from holding a public "office of profit or trust" in Maryland. The power and authority of the State of Maryland is thus placed on the side of a particular type of believer: those who are willing to say they believe "in the existence of God." The Supreme Court decision created a wall of separation. between Church and State it is plausible to conclude that a positive toleration approach would have recommended amending the Maryland Constitution to include the declaration of faith as an option rather than a requirement..