2011] The Relative Irrelevance of the Establishment Clause 607
In the first decade of the twenty-first century, this close affiliation led
one former Republican senator to complain that the Republican Party was
becoming a “political arm of conservative Christians” and “the means for
carrying out a religious program” that included opposition to homosexuality,
same-sex marriage, stem-cell research, abortion, contraception, euthanasia,
and the use of reproductive technologies.
119
This debate within and outside
the Republican Party was sparked in part by the case of Terri Schiavo, the
Florida woman whose husband sought an order in 2005 allowing her care-
givers to terminate her life by removing her feeding tube after she had been
in a persistent vegetative state for almost fifteen years.
120
For many
observers, the attempt by government officials to intervene in the Schiavo
case reflected those officials’ or their constituents’ religious views.
121
Goldwater’s presidential bid; the failure of that campaign led to a decade-long resignation from the
political arena for fundamentalists.
Id. at 34–35.
In 1976, Jimmy Carter, an evangelist and Democrat, garnered some support from evangelicals in
his presidential victory. Id. at 36. Republican strategists saw this political reentry of evangelicals
as an opportunity. Id. Consequently, they joined forces with the well-known evangelical leader
Jerry Falwell to form the Moral Majority in 1979. Id. This strategy proved effective in Reagan’s
1980 victory, which marked the beginning of a clear affiliation between fundamentalist Christians
and the Republican Party.
HANKINS, supra note 117, at 146–48. The “Christian Right” proved
beneficial to the Republican Party throughout the 1980s, supporting Reagan’s reelection and George
Bush’s successful 1988 campaign.
KENNETH WALD & ALLISON CALHOUN-BROWN, RELIGION
AND
POLITICS IN THE UNITED STATES 228–30 (Cong. Quarterly Press 3d ed. 1997).
In the 1990s, the Christian Coalition, founded by Pat Robertson and managed by Ralph Reed,
took the place of the Moral Majority as the predominant Christian Right group and shifted its focus
toward affecting politics at the grassroots level.
HANKINS, supra note 117, at 154–55. In the new
millennium, the Christian Right has been represented by a wider variety of groups, including Focus
on the Family and the Family Research Council, both of which were founded by James Dobson. Id.
at 156. Their involvement is further evidenced in the 2008 Republican Platform, which referred to
the “Judeo-Christian heritage of our country.” R
EPUBLICAN NAT’L COMM., 2008 REPUBLICAN
PLATFORM 53 (2008), available at http://www.gop.com/2008Platform/2008platform.pdf. The
Republican Platforms of 1988 and 1992 contained similar references to a Judeo-Christian national
heritage, whereas those of 1996, 2000, and 2004 did not. One can search these platforms through a
database maintained by the The American Presidency Project. Political Party Platforms, T
HE
AMERICAN PRESIDENCY PROJECT, http://www.presidency.ucsb.edu/platforms.php. See generally
The 2004 Political Landscape, T
HE PEW RESEARCH CTR. FOR THE PEOPLE & THE PRESS,
http://people-press.org/report/?pageid=757 (finding that “[o]ver the past 15 years, religion and
religious faith also have become more strongly aligned with partisan and ideological identification,”
“[r]eligious commitment has increased substantially among self-identified conservatives,” and
“there is a nearly two-to-one Republican advantage among white evangelicals”).
119. Danforth, supra note 16; see also John C. Danforth, Onward (Moderate) Christian
Soldiers, N.Y. TIMES, June 17, 2005, at A27 (noting that moderate Christians often come to political
conclusions that differ from those of conservative Christians).
120. See Michael P. Allen, The Constitution at the Threshold of Life and Death: A Suggested
Approach to Accommodate an Interest in Life and a Right to Die, 53 A
M. U. L. REV. 971, 976–78
(2004) (discussing the actions taken by Republican Governor Jeb Bush during the Terri Schiavo
controversy and the efforts of “conservative political forces” to induce such political action);
Thomas C. Marks, Jr., Terri Schiavo and the Law, 67 A
LB. L. REV. 843, 844–45 (2004) (describing
the series of events that surrounded the Terri Schiavo controversy).
121. Numerous government officials, including the Governor of Florida, the leader of the
United States Senate, and the President of the United States, sought ways to block that removal on