The U.S. Supreme Court case Bowen, Secretary of Health and Human Services v. Kendrick et al., 1987 involved the constitutionality of a federal law that provided funding for services related to adolescent sexual behavior and pregnancy. The Adolescent Family Life Act (AFLA) was challenged by appellees who argued it violated the Establishment Clause of the First Amendment because some funds were given to religious organizations. The court held in a 5-4 decision that AFLA did not violate the Constitution simply because it allowed religious organizations to receive funding; however, they remanded the case back to lower courts for further examination on whether there had been any violations in how those funds were used by these groups.

In the dissenting opinion for Bowen, Secretary of Health and Human Services v. Kendrick et al., Justice Blackmun argued that the Adolescent Family Life Act (AFLA) violated the Establishment Clause of the First Amendment by providing federal funding to religious organizations. He contended that AFLA's primary effect was advancing religion because it allowed these organizations to use government funds for religious instruction and indoctrination. Furthermore, he believed there were insufficient safeguards in place to prevent this misuse of funds as evidenced by several instances where grantees used their grants for explicitly religious activities. Additionally, he criticized majority’s decision stating it blurred lines between church and state instead of maintaining a healthy separation which is crucial in preserving individual freedom from governmental imposition or influence over religion.