Supreme Court rulings, starting with "Lynch v. Donnelly" in 1984, have permitted religious themes in government-funded Christmas displays that had "legitimate secular purposes". Since these rulings have been splintered and have left governments uncertain of their limits, many such displays have included secular elements such as reindeer, snowmen and elves along with the religious elements. Other recent court cases have brought up additional issues such as the inclusion of Christmas carols in public school performances, but none of these cases have reached the Supreme Court.