The label of zero tolerance began with the Gun-Free Schools Act of 1994, when Congress authorized public-school funding subject to the adoption of zero-tolerance policies.14 Similar policies of intolerance coupled with expulsions for less serious behaviors than bringing a weapon to school had long been a part of private, and particularly religious, schools. The use of zero-tolerance policies in secular, public schools increased dramatically after the Columbine High School massacre, with principals declaring that safety concerns made them want zero tolerance for weapons. These have led to a large number of disproportionate responses to minor, or technical transgressions, many of which have attracted the attention of the international media. These cases include students being suspended or expelled for such offenses as possession of ibuprofen or Midol (both legal, non-prescription drugs commonly used to treat menstrual cramps and headaches) with permission of the students' parents, keeping pocketknives (small utility knife) in cars, and carrying sharp tools outside of a woodshop classroom (where they are often required materials). In Seal v. Morgan, a student was expelled for having a knife in his car on school property, despite his protestations that he was unaware of the knife's presence.15 In some jurisdictions, zero-tolerance policies have come into conflict with freedom of religion rules already in place allowing students to carry, for example, kirpans.