Secularist forces in America’s religious struggle believe that church and state should be separated as completely as possible, while their accommodationist opponents believe the state should encourage religious activity. As the accommodationist order in America’s religious struggle gave way to secularist forces during the period of church–state activism by the Warren and Burger Courts (1953–86) on issues such as school prayer, evolution, and religious exemptions, accommodationists sought refuge in weakly attenuated voucher programs. This chapter shows how accommodationists came to rely upon a child benefit theory defense in court that emphasized the benefits to the child, rather than to the school. Accommodationists saw the rise of judicial secularism as a threat to their interests. Indirect benefits channeled through parents seemed to help insulate the state from secularist opposition. But most quasi-direct vouchers of the latter half of the twentieth century were struck down as unconstitutional because they entangled the state with religious purposes.