You’ve mischaracterized Bowen v. Kendrick. The law under Supreme Court review was the “Adolescent Family Life Act,” whereby counseling on premaritial teenage sexuality was funded. Among the provisions for eligibility were a beneficiary’s willingness to involve both governmental and RELIGIOUS agencies in dealing with the alleged problem.

In his majority opinion, Chief Justice Rehnquist cited the Flast decision to say that, in principle: “Federal taxpayers have standing to raise Establishment Clause claims against exercises of congressional power under the taxing and spending power of Article I, 8, of the Constitution.”

However, the Court found 5-4 that the law in question was motivated primarily by legitimate secular concerns, and that it did not have the primary effect of advancing religion.

To recap: insisting that the beneficiary of a governmental program seek advice from RELIGIOUS counsellors as one condition of his or her getting funds does not violate the Establishment Clause.

In other words, the decision was essentially an adverse one for us atheists.