The U.S. Supreme Court case Guy Mitchell, et al. v. Mary L. Helms, et al., 1999 revolved around the issue of whether public funds could be used to provide educational materials and equipment to religious schools without violating the Establishment Clause of the First Amendment which prohibits government endorsement or promotion of religion. The court ruled in a 6-3 decision that such aid did not violate the Constitution as long as it was offered on a neutral basis and did not promote religion directly or indirectly. The case originated from Jefferson Parish in Louisiana where Chapter 2 of Education Consolidation and Improvement Act (ECIA) allowed federal funds for instructional materials like computers, library resources etc., to be given to both public and private schools including those with religious affiliations. Justice O'Connor delivered an opinion stating that so long as assistance is provided based on neutral criteria without regard for recipient's religious character, there would be no violation against establishment clause.

In the dissenting opinion for Guy Mitchell, et al. v. Mary L. Helms, et al., Justice Souter argued that providing public funds to religious schools through Chapter 2 of the Education Consolidation and Improvement Act violated the Establishment Clause of the First Amendment because it resulted in government indoctrination of religion. He contended that even though materials and equipment provided by these funds were secular in nature, they could still be used to advance religious education indirectly which would amount to state sponsorship of religion. Furthermore, he disagreed with plurality's view about "true private choice," stating that this case lacked elements necessary for such a choice as most beneficiaries were parochial schools chosen by parents based on their sectarian character rather than any neutral criteria set by law or policy makers.