concurring. While I agree with the result reached by the majority, I believe that the majority asks and answers the wrong question, causing it to delve into a lengthy and unnecessary analysis of the distinction (or lack thereof) between religious education and religious worship. It has eschewed a more straightforward analysis based on the plain meaning of Chapter I, Article 3 of the Vermont Constitution and the specific facts of this case, and has unnecessarily confused our holding as a result.
The issue before us is simple. Chittenden School District wishes to use tax revenues to fund tuition payments to Mount Saint Joseph’s Academy (MSJ). The plain language of Article 3 prohibits the state from compelling citizens to support a place of worship. Taxation is compelled support. MSJ, the parties agree, is a pervasively sectarian school at which religious worship regularly takes place in conjunction with educational activities. Therefore, the payments to MSJ violate Article 3.
Chittenden School District and plaintiffs-intervenors did not confront the plain language of Article 3 either in their appellate briefs or at oral argument.1 To the extent plaintiffs made any argument based on the Vermont Constitution, it was that the Compelled Support Clause of Chapter I, Article 3 and the Education Clause of Chapter II, § 68 are coextensive with the federal provisions. As plaintiffs emphasize, and as we detailed in Campbell v. Manchester Board of School Directors, 161 Vt. 441, 448-51, 641 A.2d 352, 357-58 (1994), the historic concern under the Establishment Clause of the First Amendment has been with excessive entanglement between religious organizations and governmental actors. The focus in recent cases involving funding of religious schools has been the question of who receives or controls the expenditure of the public money — private individuals *346or the sectarian school. See, e.g., Witters v. Washington Dep’t of Servs. for the Blind, 474 U.S. 481, 488 (1986) (use of grant money to allow student to train as pastor does not violate Establishment Clause where money was provided directly to student); Mueller v. Allen, 463 U.S. 388, 400 (1983) (allowing tax deduction for educational expenses permissible under Establishment Clause because financial benefit is ultimately controlled by private choices of individual parents).
Relying on the logic of these federal cases, plaintiffs argue that as long as benefits are distributed by and/or to neutral parties — the parents — there is no excessive entanglement with religion because there is no connection between public money and religious activities. They make virtually the same argument under the Vermont Constitution, but carry it one step further. Because 16 V.S.A. § 822 requires school districts to make tuition payments directly to the school, plaintiffs contend that there is no meaningful distinction between payment to a sectarian school chosen by parents and payment to parents who then send the money to a sectarian school.
Plaintiffs’ argument is not, as the majority states, that there is no violation of the Vermont Constitution in this case because religious education is distinct from religious worship. See 169 Vt. at 325, 738 A.2d at 556. Indeed, plaintiffs make quite clear at numerous points in their brief that they want the Court to consider the constitutionality of tuition payments in the specific context of a pervasively sectarian school — a school at which no attempt is made to separate education from worship. Rather, they claim that the Vermont Constitution is not violated by payments to sectarian schools because the “taxes are supporting fellow residents rather than the schools.” However persuasive plaintiffs’ arguments may be under federal law, these arguments do not address the state constitutional question that we must answer.
In my view, the First Amendment and the Compelled Support Clause cannot be read as parallel provisions. Textually, they differ markedly. The Establishment Clause of the First Amendment states that “Congress shall make no law respecting an establishment of religion.” U.S. Const, amend. I. As noted, the concern under this clause is whether a particular government action is likely to result in “excessive entanglement” with religion. See Lemon v. Kurtzman, 403 U.S. 602, 612-13 (1971). The critical question under the Establishment Clause, therefore, concerns the nature of the relationship between the state and the recipient religious organization.
By contrast, the relevant text of Article 3 of the Vermont Constitution states that “no person ought to, or of right can be compelled to *347attend any religious worship, or erect or support any place of worship, or maintain any minister, contrary to the dictates of conscience.” Vt. Const, ch. I., art. 3. The language of the Compelled Support Clause, on its face, bars the state from taxing citizens for the support of religion. Under the Compelled Support Clause, the insertion of a private decisionmaker between the governmental actor and recipient religious organization will not remedy the constitutional problem with transferring public funds to religious organizations. The critical question under the Compelled Support Clause is not the nature of the relationship between the state and the recipient religious organization, but the nature of the organization receiving public funds. That is, is it a “place of worship”?
Thus, while the religious nature of the recipient institution may not be determinative under the federal framework, it is the question under the Vermont Constitution. Again, because plaintiffs essentially see the religious nature of MSJ as irrelevant to the constitutionality of the tuition payment scheme (because they argue the payments are controlled by parents rather than the school), they make no argument, nor could they, that MSJ is not a place of worship. In other words, plaintiffs do not even attempt to make any distinction between religious education and religious worship, and it therefore seems unnecessary to undertake a lengthy analysis of this issue.
Nothing in our precedents compels a parallel reading of the Vermont and federal provisions. Plaintiffs contend that both Swart v. South Burlington Town School District, 122 Vt. 177, 167 A.2d 514 (1961), and Vermont Educational Buildings Financing Agency v. Mann, 127 Vt. 262, 247 A.2d 68 (1968), support this position. Swart held that tuition payments to sectarian institutions were unconstitutional under the First Amendment. In Mann, the Court sanctioned participation by a sectarian institution of higher learning in a program that assisted the construction of educational facilities through the use of state tax-exempt bonding. Neither case provides guidance here because, although each alluded to Article 3 of the Vermont Constitution, and Mann even went so far as to state that the Vermont Constitution provides no “explicit injunction precluding assistance to sectarian education,” 127 Vt. at 269, 247 A.2d at 73, both cases were decided exclusively under First Amendment principles.
Both cases made statements concerning the relative sweep of the state and federal provisions. Swart stated that the First Amendment “seems . . . more demanding,” i.e., more difficult to satisfy than Article 3.122 Vt. at 184, 167 A.2d at 518. Mann asserted that “[i]n this *348area, the limits of the First Amendment of the Federal Constitution are more restrictive.” 127 Vt. at 269, 247 A.2d at 73. The suggestion being made by plaintiffs is that, since the tuition payment scheme at issue here would be constitutional under contemporary First Amendment analysis, it must, therefore, be allowable under the supposedly more permissive Vermont Constitution. Especially in light of the manner in which federal jurisprudence has changed in the thirty- to forty-year period since Mann and Swart were decided, I cannot agree with the proposition that the Vermont Constitution is the more permissive in this area. Furthermore, even if these statements were accurate when made, they were dicta, for in each case, the Court went on to treat the questions as matters to be resolved under First Amendment principles alone. Dicta, it need hardly be stated, have no binding precedential effect.
The present case highlights the problems that occur if we focus our concern on whether the Vermont Constitution is more or less restrictive than the United States Constitution. By doing so, we would lash construction of the Vermont Constitution to the unsteady mast of federal jurisprudence, ensuring that our interpretation will always be in relative terms rather than independently grounded. When federal jurisprudence changes, then our jurisprudence will be required to change as well. In fact, that is why plaintiffs are before us today: because the United States Supreme Court has shifted its Establishment Clause analysis in a way that suggests a more favorable outcome for public support of religious schools. It is preferable that our interpretation of the Vermont Constitution be distinct and freestanding, and that the Court articulate the adequate and independent state grounds for decisions when the Vermont Constitution is invoked. See State v. Badger, 141 Vt. 430, 449, 450 A.2d 336, 347 (1982) (although there are similarities between federal and Vermont constitutions, Vermont Constitution is not mere reflection of federal charter).
If we therefore decline plaintiffs’ invitation to collapse Vermont’s Compelled Support Clause into the federal Establishment Clause, the resolution of this case — based on the plain language of Article 3 and the facts before us — is clear. It also points clearly to the Avays in which the majority unnecessarily complicates our analysis and holding in this case.
First, examining the history of Article 3 adds nothing to the resolution of this case beyond what can be gained from an analysis of the plain language of Article 3. Plain language should be our first
*349resource in interpreting the law, particularly when it provides as clear a guide as the plain language of the Compelled Support Clause does here.2 Courts in other states that have considered the issue in light of similarly worded compelled-support clauses have concluded that the clause precludes the use of public funds to support sectarian schools. See Williams v. Board of Trustees, 191 S.W 507 (Ky. 1917); Findley v. City of Conneaut, 62 N.E.2d 318 (Ohio 1945); Almond v. Day, 89 S.E.2d 851 (Va. 1955).
Second, the majority explicitly refuses to rest its analysis on the facts of this case, stating, “[T]his case is not about MSJ or any other parochial school as such.” 169 Vt. at 318, 738 A.2d at 546. If this is true, I fail to see the point of the majority’s lengthy recitation of facts pertinent to MSJ. Further, why is this case not about MSJ? We are generally bound to construe laws as constitutional, if possible. See State v. Cantrell, 151 Vt. 130, 134, 558 A.2d 639, 642 (1989) (“Where possible, a statute must be construed to avoid constitutional infirmities.”). We will not declare a law unconstitutional on its face based on the possibility that it might be unconstitutionally enforced in some circumstances. See Kimbell v. Hooper, 164 Vt. 80, 88, 665 A.2d 44, 49 (1995). A proper decision in this case must be based on the factual record developed at trial, and the holding should be limited to the constitutionality of the tuition funding statute as applied in this instance.
Having declined to limit itself to the facts of this case, the majority embarks on a lengthy foray into history to address the supposed distinction between religious education and religious worship. Through this exercise, the majority attempts to predict when and under what circumstances public funding of sectarian schools would be permissible under Article 3. While these lines may be drawn some day, in a different case, there is no need and no justification on the facts of this case for attempting to do so today. There has been no *350effort whatsoever on the part of plaintiffs to demonstrate that the MSJ curriculum does not involve the propagation of religious beliefs. In fact, plaintiffs have purposely demonstrated the opposite — that MSJ is pervasively sectarian — in order to test the question of whether public funding of such an institution is constitutional. It clearly is not, and we should limit our holding to that conclusion, rather than speculating about the potential constitutionality of factual situations that are not before us.3
Chittenden spent two and one-half pages in its principal brief discussing the Vermont Constitution, and plaintiffs-intervenors cited the Compelled Support Clause in a footnote. At oral argument, Chittenden’s only contention under the Vermont Constitution was that the Compelled Support Clause should be read as coextensive with the federal Establishment Clause.
The majority infers that I “would find unconstitutional any subsidy for activities in or by a sectarian school, irrespective of the sectarian nature of those activities.” 169 Vt. at 342 n.24, 738 A.2d at 562 n.24. It is precisely because of my belief in the primacy of the facts presented in this case that such an inference is wholly unwarranted. If and when such activities come before us, I would address them in their context, as I have attempted to do here.
1 am as sensitive as the majority to the limitations of the “plain language” approach to constitutional interpretation, and I largely agree with the principles set forth in the majority opinion. See 169 Vt. at 326-29, 738 A.2d at 551-53. But the language of a document that is at the center of a controversy is virtually always the starting point for analysis. If one is to go beyond it, there must be reasons for doing so, such as ambiguity in the language, history or precedent that calls its apparent meaning into question, the existence of facts or circumstances that may not have been contemplated when the language was set down, or other factors. It is always an appropriate course to search for such factors, but none have been unearthed here. The majority’s search in this case appears to have been triggered by a determination that it was necessary to distinguish between religious education and religious worship, a question I find irrelevant under the facts presented here.