Missouri’s constitution prohibits direct or indirect public aid to houses of worship and other religious institutions. Based on this provision, the State excludes houses of worship, including the petitioner—a church, from a program that provides direct grants to pay for outdoor resurfacing materials. ADL joined with American United for Separation of Church and State, other civil rights groups, and religious organizations on a friend-of-the court brief. It argues that the First Amendment’s free exercise clause does not require petitioner to be included in the direct grant program. Furthermore, the state constitutional provision at issue is permitted by the "play in the joints" between the U.S. Constitution’s establishment and free clauses, and it is justified by the experience of the framers of the Constitution, who were deeply concerned about public funding of houses of worship.