Susan Jacoby rejects the Christianist misappropriation of the phrase:
Twenty years ago, I could be reasonably sure, if I opened a fundraising appeal mentioning religious liberty on the envelope, that the notice came from a group like Americans United for Separation of Church and State or the ACLU. Now such appeals come from the likes of Focus on the Family and the Catholic hierarchy. They have no shame, and they want religious liberty only for themselves. If secularists are to succeed in making any inroads on the default position of religion, they must reclaim the original definition of religious liberty, as exemplified by those who passed [the 1786 Virginia Act for Establishing Religious Freedom.] … The first state law to officially draw a line between government and religious institutions was written when religious conservatives in Virginia attempted to tax citizens for Christian teaching in public schools. This act would become the template for the federal Constitution and the Bill of Rights.