No man is more responsible for the Constitution than James Madison. Leading delegate at the Philadelphia Convention, advocate and expositor as Publius, author and sponsor of the Bill of Rights: Madison rightfully earned his title “Father of the Constitution.” Along with Thomas Jefferson, he also played the leading role in Virginia's battle for religious freedom, authoring in the process his landmark statement on religious liberty, “Memorial and Remonstrance Against Religious Assessments.” It should be no surprise, then, that along with Thomas Jefferson, Madison has been considered an authoritative guide to the meaning of the First Amendment's religion clauses. The meaning of the “Memorial,” however, is a matter of significant dispute. Strict separationist judges and scholars claim that Madison partnered with Jefferson to erect a “wall of separation” between church and state, thereby prohibiting all governmental support for religion. Nonpreferentialists challenge this interpretation, contending that, regardless of Jefferson's aims, Madison meant only to prevent the state from favoring one religious sect over others. The state may support religion, they claim, so long as it supports all religions equally. For Free Exercise cases, Madison has been invoked to defend the right to religious exemptions from facially neutral but burdensome laws.