"Since the ratification of the 14th Amendment, the natural rights protected in the Bill of Rights generally have been insulated from interference by the states, as well.
"All natural rights are of paramount importance to all persons. They are individualized personal gifts from the Creator and have been recognized as such in American law since Thomas Jefferson wrote in the Declaration of Independence that we are endowed with them by Him.
"One of those rights guarantees the free exercise of religion.
"Indeed, the Free Exercise Clause in the First Amendment was written to ensure that the new government could not coerce persons to behave differently than their religious views informed their consciences, or to punish them for not conforming to a government-mandated religious orthodoxy."
~ Judge Andrew Napolitano, from an editorial in the Washington Times