Only one religious freedom case is currently before the Supreme Court this upcoming term: Trinity Lutheran Church of Columbia v. Pauley. Trinity Lutheran is a case about a religious preschool that was rejected from a state program that provides reimbursement grants to purchase rubberized surface material (tire scraps) for children’s playgrounds. The preschool was ultimately denied the grant for its playground solely because the playground belongs to a religious organization. At its core, the Trinity Lutheran playground case strikes at the heart of American jurisprudence, asking: What is fair play in a pluralistic society?