In a previous piece on the ICLRS blog, I argued that the legal understanding of freedom of religion should be extended and interpreted to encompass individual spirituality. The beliefs of the “spiritual but not religious” (SBNR) may be very different than the traditional understanding of religion as a hierarchical, institutional, fixed set of beliefs about God that impose duties on believers, but I suggested that, nonetheless, the spiritual views of “SBNRs” should be given respect and protection. But from a constitutional perspective, freedom of religion is just one side of the coin. What about the other side: establishment of religion? In what follows, I intend to sketch the contours of how individual spirituality may interact with constitutional guarantees of non-establishment.