The separation of church and state has been a long-debated topic in American history. Although based on Christian ideals, the framers of the Constitution explicitly intended for government to operate in a secular manner, in what is commonly referred to as the "establishment clause." When interpreting the Constitution as it relates to religion, there are two main philosophies. The first philosophy this article will explore will be called positive tolerance. In general, the idea of ​​positive tolerance creates an encouraging environment for all religions. The second philosophy, which we will call the “Wall of Separation”, encourages the government to free itself from religion. Although historically these two philosophies have competed for public popularity, as America moves into the future, the philosophy of the Separation Wall will take a stronghold and set the course for how the Establishment Clause will affect local government, schools and local governments. private religious practice. The legal basis for religious freedom cases is the First Amendment to 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 expression 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 assertion two schools of interpretation were born. The first school of thought, positive tolerance, was championed by Roger Williams. Its 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 a middle of paper ......titional. The court's opinion was delivered by Justice Black. It states: “There is, and can be, no dispute as to the purpose or effect of the requirement of the Maryland Bill of Rights before us; it establishes a religious standard that was designed to, and, if valid, prohibits any person who refuses to declare belief in God from holding any "public office of profit or trust" in Maryland. The power and authority of the State of Maryland is therefore placed on the side of a particular type of believer: those who are willing to say that they believe in "the existence of God." The Supreme Court's decision created a wall of separation. between the Church and this State. It is plausible to conclude that an affirmative tolerance approach would have recommended amending the Maryland Constitution to include the declaration of faith as an option rather than a requirement..