https://en.m.wikipedia.org/wiki/Marsh_v._Alabama https://en.m.wikipedia.org/wiki/Marsh_v._Alabama Also reference the 14th amendment. Prior to it's ratification

https://en.m.wikipedia.org/wiki/Marsh_v._Alabama https://en.m.wikipedia.org/wiki/Marsh_v._Alabama Also reference the 14th amendment. Prior to it's ratification the bill of rights was construed only to apply to the federal government. It's ratification brought application of the bill of rights to the states, and then to private entities.