"It is true, of course, that the phrase 'separation of church and state' does not appear in the Constitution. But it was inevitable that some convenient term should come into existence to verbalize a principle so clearly and widely held by the American people.... [T]he right to a fair trial is generally accepted to be a constitutional principle; yet the term "fair trial" is not found in the Constitution. To bring the point even closer home, who would deny that "religious liberty" is a constitutional principle? Yet that phrase too is not in the Constitution. The universal acceptance which all these terms, including "separation of church and state," have received in America would seem to confirm rather than disparage their reality as basic American democratic principles." Leo Pfeffer, Church, State, and Freedom (Beacon Press: Boston, 1967).