The U.S. Senate requested a memorandum from Abraham Ribicoff, Secretary of Health, Education, and Welfare. They asked his department to address the propriety of federal funds flowing to religious schools.
Remarkably, early in this document Secretary Ribicoff declares that the debate over the propriety of federal aid to schools was over.
“The power of the Congress to enact S. 121 [an educartion bill] rests on its constitutional authority to appropriate funds to provdie for the general welfare. The scope of that congressional power has been so broadly defined by decision of the Supreme Court… there is no need to review the controversy which for a century and a half surrounded the Federal power of expenditure” (p. 3).
That the U.S. Constitution makes no mention in Article 1 Section 8 of a congressional authority to support schooling is no matter.
The memoradnum goes on to say that federal funds for private schools was permissible, so llong as they benefited the child and provided only “incidental benefits to church schools” (p. 6).
Suffice to say, not everyone in Congress agreed with the propriety of federal grants-in-aid to schooling (public or private), and those battles have continued to this day, albeit with fewer combatants.
Full citation: U.S. Congress, Senate, Senate Committee on Labor and Public Welfare, Subcommittee on Education, Constitutionality Federal Aid to Education in Its Various Aspects, 87th Congress, 1st session, document no. 29, May 1, 1961, U.S. Government Printing Office.