RIP, Alton T. Lemon — the Lemon of the Lemon test.

"Mr. Lemon’s lawsuit challenged a 1968 Pennsylvania law that reimbursed religious schools for some expenses, including teachers’ salaries and textbooks, so long as they related to instruction on secular subjects also taught in the public schools."

Chief Justice Warren E. Burger, writing for the court in Lemon v. Kurtzman, said the law violated the First Amendment’s prohibition of government establishment of religion.

The ruling set out what came to be known as the Lemon test, which requires courts to consider whether the challenged government practice has a secular purpose, whether its primary effect is to advance or inhibit religion, and whether it fosters excessive government entanglement with religion....

The lawyers for the plaintiffs put Mr. Lemon’s name first in the caption of the case.

That was no accident, Professor Laycock said. The case was decided against the backdrop of resistance to the desegregation of public schools, and the choice of Mr. Lemon, who was black, underscored the point.

Alton T. Lemon died on May 4th at the age of 84.