Although none of the original state constitutions of the United States prohibited the use of public funds to assist church-related education, the inclusion or addition of such prohibitions in state constitutions occurred only in isolated instances up to the 1850s. However, the growth of nativist and anti-Catholic sentiments in the country hastened the movement to add such restrictions beginning in the mid-1800s.

In 1818, Connecticut was the first state to expressly limit its "school fund" to the support of "public" or "common" or "free" schools, but it did not explicitly forbid church-connected schools from being considered as "public" or "common" schools. Rhode Island adopted a similar constitutional amendment in 1843 and Kentucky and Indiana followed suit in 1850 and 1851, respectively.27

The first laws to explicitly exclude religiously affiliated private schools from sharing in the "public school fund" were amendments introduced into the constitutions of Ohio and Massachusetts in 1851 and 1855, respectively. The impetus behind these laws, however, seems to have been a desire to prevent state educational funds from being diverted to purposes other than general education, rather than a concern with church and state issues.28

Michigan was the first state, upon its entrance into the Union in 1835, to constitutionally prohibit the use of public funds "for the benefit of religious societies or theological seminaries." The second state was Wisconsin, which included an identical prohibition in its original constitution of 1848. "Religious society" eventually came to be interpreted strictly to mean a church.29

In 1864, Louisiana banned by constitutional amendment the use of government funds for any private schools. The amendment stated that, "No appropriation shall be made by the legislature for the support of any private school or institution." Subsequently, between 1868 and 1900, 14 more states amended their constitutions to prohibit any appropriation of public funds for religiously affiliated private schools, and seven other states adopted amendments limiting the use of school funds to "public" schools only. Many of these provisions—which are commonly referred to as Blaine Amendments, after Speaker of the House James G. Blaine30—were enacted as part of broader constitutional revisions related to Reconstruction in the South after the Civil War. In addition, the original constitutions of all new states admitted to the union since 1857, except those of Kansas (1859), West Virginia (1863) Nebraska (1866), and Hawaii (1959), have contained a prohibition against the direct use of public or state funds to aid religious institutions or schools.31

As states began to eliminate government funding for privately operated sectarian schools, they simultaneously began to centralize control of education. In Michigan, events were very similar.