After the decision in Lemon v. Kurtzman, one three-pronged test controlled all Establishment Clause issues. The Lemon test has guided the court's analysis of a broad range of issues, including governmental speech on religious topics, governmental impositions of burdens and grants of benefits, and governmental delegations of civil power to religious bodies. The Lemon test was not originally intended to provide strict rules, but rather, "helpful signposts." However, the Court began using the Lemon test exclusively to evaluate Establishment Clause issues soon after the decision was rendered.

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