In this article it will be argued that the establishment clause, properly viewed, functions as a structural provision regimenting the nature and degree of involvement between government and religious associations." The degree of involvement should be a limited one, although it is clear that the interrelationship need not nor cannot be eliminated altogether. Although the degree of desired separation has proven to be a continuing controversy, the goal of separation is not so divisive. The aim of separation of church and government is for each to give the other sufficient breathing space. The ordering principle is reciprocity in which "both religion and government can best work to achieve their lofty aims if each is left free from the other within its respective sphere." Those who were influential in our nation's history envisioned the churches and the state in a kind of parallelism, with neither subordinate to the other.' Each should be guarded from being co-opted by the other, and each required to forbear from undue entanglement with the instrumentalities of the other. Importantly, if the clause's structural ordering of these two circles of influence in society is reciprocal, then religious organizations are afforded a high level of protection from governmental interference.
Carl H. Esbeck, Establishment Clause Limits On Governmental Interference With Religious Organizations, 41 Wash. & Lee L. Rev. 347 (1984)