For the past quarter century, Boy Scouts of America has been defending itself against legal attacks for educating boys to do their “duty to God” and keep “morally straight.” Until 2000, most litigation was brought by adults or youth seeking membership. The decision of the Supreme Court of the United States in Boy Scouts of America v. Dale1 extinguished the membership cases but sparked a new round of litigation. Following Dale, the cases have challenged Boy Scouts’ relationship with government entities. In a few instances, Boy Scouts has sued the government to protect its constitutional rights.