In noting the distinction between "civil liberties" and "civil rights", I emphasized. that the Bill of Rights mostly restricts actions by the government rather than creating substantive affirmative rights. As such ,we describe these protections as our civil liberties. We then reviewed the holdings in the major "Establishment" cases and "free exercise " cases. Starting with Engle v Vitale's prohibition on prayer in school, we examined the court's conservative drift by addressing the recent Kennedy case holding that under the"free exercise " clause a coach at a public school could kneel and conduct a post-game team prayer . We then addressed the scope of the Second Amendment as outlined in the Heller and McDonald cases. I reviewed the various interpretations on the scope of the amendment's language, and discussed the "incorporation" theory (under the due process clause of the 14th Amendment) which applied the Heller case to the states thereby declaring unconstitutional Chicago's outright ban on hand gun ownership.