As currently employed, the very concept of accommodation suggests the need of the state to define that to which it is making accommodation. And accommodate to what? Who is to accommodate whom? Which demands require accommodation? Which may be legitimately denied? Would it be so simple to substitute for "it's just a little prayer" the phrase "it's just a little satan adoration"? The power to accommodate is the power to control and therefore to refuse accommodation.
Without a Prayer: Religious Expression in Public Schools, (1996)