Originalist critics of the modern concept of the "separation of church and state" argue that it is contrary to the conception of the phrase as the Founding Fathers understood it. But society and the law have changed. In the case of "Locke v. Davey" (2004), briefs before the Supreme Court, including by the U.S. government, argued that some state constitutional amendments relating to the modern conception of separation of church and state (Blaine Amendments) were motivated by and intended to enact anti-Catholicism.