As Winding as the Serpentine Wall: Tennessee’s Adoption Statute Under Lemon

This comment argues that Tenn. Code Ann. 36-1-147 is unconstitutional under both the Tennessee and U.S. constitutions. The Comment demonstrates that the test outlined in Lemon v. Kurzman is appropriate for legislation of this kind, as it is a statute regulating a secular activity in which religious institutions participate. The Comment continues by looking into the legislative history of 36-1-147 and applying the Lemon test to the statute at hand.