Jesse H. Choper,
Religion in the Public Schools: A Proposed Constitutional Standard, 47
Minn. L. Rev.
Available at: http://scholarship.law.berkeley.edu/facpubs/1060
Religion in the public schools: a proposed constitutional standard; proposes that, for purposes of testing the constitutional validity of religious activity in the public schools, the first amendment's establishment clause is violated whenever the state engages in "solely religious activity that is likely to result in compromising the student's religious or conscientious beliefs or influencing the student's freedom of religious or conscientious choice."