INTRODUCTION
In their article, "Public Schools and Religious Expression: The Diversity of School Districts' Policies Regarding Religious Expression,"1 Brown and Bowling take a first cut at describing and explaining school district compliance with federal guidelines on religious expression in public schools. Two important conclusions emerge from their analysis. First, they observe that compliance with federal guidelines is complicated by "the inherent complexities of intergovernmental policy and implementation in public education." Such complexity is accentuated by not only the number of interests, but their ideological commitments that raise the pitch of conflict. As Brown and …