Chapter Two of the Education Consolidation and Improvement Act of 1981 (ECIA) provides for the allocation of federal funds for educational materials and equipment, such as library materials and computers, to elementary and secondary schools. Funds are provided to both public and private schools, but private schools must demonstrate that the “services, materials, and equipment” they receive will be used for the purpose of implementing “secular, neutral, and non-ideological” programs. In Jefferson Parish, Louisiana, roughly thirty percent of the Chapter Two funds available are allocated to private schools. Mary Helms (plaintiff) filed suit in federal district court against Mitchell (defendant), a state official, on the grounds that Chapter Two, as applied to Jefferson Parish, violated the Establishment Clause of the First Amendment because most of the private schools receiving funds were religiously affiliated. The district court held that Chapter Two as applied to Jefferson Parish was constitutional, but the court of appeals reversed. The United States Supreme Court granted certiorari.