However, critics often view the moment of silence as publicly endorsing prayer "in disguise". This issue has been especially raised by atheist groups and advocates, who argue that no non-religious purpose is served by designating an official moment of silence. Moments of silence point to the tension in the U.S. Constitution and society between accommodation and endorsement. Accommodation of religion is to ensure an environment where a person or student can practice their religion. A question with "moments of silence" laws is whether accommodation was already achieved by the fact that a student can pray or meditate on his/her own without an official moment of silence. Barry Lynn of Americans United for Separation of Church and State said, on a "moment of silence" case, "Students were already allowed to pray, meditate, or reflect under the statute before it was amended. The addition of the word 'pray' where it wasn't needed clearly shows that legislators intended to promote religion, and that's not their job." Courts have stated on these moments of silence cases that a secular purpose is necessary and according to "Wallace v. Jaffree", a "statute must be invalidated if it is entirely motivated by a purpose to advance religion."