In the case of School District of the City of Grand Rapids et al. v. Ball et al., 1984, the U.S Supreme Court ruled that two programs initiated by a Michigan public school district violated the Establishment Clause of First Amendment which prohibits any law respecting an establishment of religion. The first program involved teaching secular subjects in private schools by publicly employed teachers, while the second provided remedial and enrichment courses to nonpublic students at public expense on mobile units near private schools or leased premises adjacent to them. The court held that these programs had primary effect advancing religion as they were implemented in religiously oriented institutions thereby leading to symbolic union between church and state; also, it constituted excessive entanglement due to continuous monitoring required for ensuring content taught is purely secular.

In the dissenting opinion for School District of the City of Grand Rapids v. Ball, Justice White argued that the majority's decision was overly broad and restrictive in its interpretation of the Establishment Clause. He contended that there was no evidence to suggest that shared time or community education programs had a primary effect of advancing religion, nor did they excessively entangle church and state. The programs were open to all students regardless of their religious beliefs, which he believed demonstrated neutrality rather than favoritism towards any particular faith. Furthermore, he pointed out that these services were provided at public expense in numerous other contexts without raising constitutional concerns. Therefore, according to Justice White’s view, denying such benefits because some recipients might use them in a religious context seemed inconsistent with previous rulings by this Court as well as with common sense.