 The University of Virginia defense claimed that denying student activity funding of the religious magazine was necessary to avoid the University's violating the Establishment Clause of the First Amendment.The Supreme Court disagreed with the University; constitutional law scholar Michael W. McConnell argued on behalf of the student religious publication, and John Calvin Jeffries argued on behalf of the University of Virginia.The decision centered upon Memorial and Remonstrance Against Religious Assessments, a document on religious freedom by James Madison.