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Chief Justice [[Warren Burger]] wrote the ''Lemon'' decision for the Court, but admitted privately that he never intended for it to be applied in the broad manner that it was.<ref>Dinner conversation between the late Chief Justice [[Warren Burger]] and [[Andrew Schlafly]] in late 1991.</ref>
 
Chief Justice [[Warren Burger]] wrote the ''Lemon'' decision for the Court, but admitted privately that he never intended for it to be applied in the broad manner that it was.<ref>Dinner conversation between the late Chief Justice [[Warren Burger]] and [[Andrew Schlafly]] in late 1991.</ref>
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== Criticisms ==
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The Lemon test has often been criticised because it promotes the religion of [[atheism]]. By not practicing any religion, the government is actively, radically atheist. This of course directly violates the [[First Amendment]], which it was supposed to implement. This is a perfect example of the [[liberal]] bias of the Supreme Court.
      
== References ==
 
== References ==
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