Sekulow served as lead counsel and presented oral arguments in a case involving the free exercise rights of a college student who was denied a state scholarship because he declared his major to be pastoral studies. The majority decision determined that Washington’s policy prohibiting state scholarship funds from being used to assist students who pursue a degree in religious studies from a religious perspective is constitutional. However, the decision does not prohibit states from re-structuring scholarship programs to permit the pursuit of a degree in devotional theology.