  Recently, some proponents of state neutrality have argued that the third formulation of the constraint is insufficiently demanding. State action may have an adequate neutral justification and yet remain non-neutral.  For example, if state action that was designed to promote a particular religion were justified on the grounds that doing so were an effective means to serve some neutral end, such as civil peace, then the action would remain non-neutral, even if otherwise justified (Patten 2012, Kramer 2017). In response, proponents of state neutrality can propose a fourth formulation of the constraint, one that combines elements from the second and third formulations.