separation of "church" and State

A nice, obvious point I had not yet considered-- from Richard John Neuhaus in First Things...

Richard Garnett, professor of law at Notre Dame, wants us to consider this: Most of what we call church–state disputes in American law are nothing of the sort. Where is “church” in battles over menorahs or nativity scenes in public squares, in whether a child in public school can read his favorite story that happens to be from the Bible, or whether the religiously motivated use of peyote is permitted, and on and on? These are called church–state controversies, but they typically pit individual freedom of conscience against the power of government. There is certainly “state” in these disputes, but there is typically no “church.”