In sweeping terms, article XVI, section 5 of the California Constitution (article XVI, section 5) provides: “Neither the Legislature, nor any county, city and county, township, school district, or other *813municipal corporation, shall ever make an appropriation, or pay from any public fund whatever, or grant anything to or in aid of any religious sect, church, creed, or sectarian purpose, or help to support or sustain any school, college, university, hospital, or other institution controlled by any religious creed, church, or sectarian denomination whatever; nor shall any grant or donation of personal property or real estate ever be made by the State, or any city, city and county, town, or other municipal corporation for any religious creed, church, or sectarian purpose whatever; provided, that nothing in this section shall prevent the Legislature granting aid pursuant to Section 3 of Article XVI.” (Italics added.) This section “constitute^] ‘the definitive statement of the principle of government impartiality in the field of religion.’ [Citation.]” (California Educational Facilities Authority v. Priest (1974) 12 Cal.3d 593, 604 [116 Cal.Rptr. 361, 526 P.2d 513] (Priest).) Its purpose, as revealed by the debates of the constitutional convention that drafted it, is “to insure the separation of church and state and to guarantee that the power, authority, and financial resources of the government shall never be devoted to the advancement or support of religious or sectarian purposes. [Citation.]” (Ibid.)
Given the trial court’s uncontested factual findings that “[r]eligion is both mandatory and integral to every aspect of student life” at the schools here at issue, and that the schools are “organized primarily or exclusively for religious purposes,” “restrict[] admission of students by religious criteria,” “discriminate[] on the basis of religion in hiring faculty,” and “integrated” “[r]eligion . . . into classroom instruction,” I conclude that the proposed bond financing agreements now before us are invalid under both the plain language and our judicial construction of article XVI, section 5. In my view, that provision simply does not permit a public entity to act as a fundraiser for schools of this nature in order, as the majority puts it, “to encourage” the “development” of such schools (maj. opn., ante, at p. 795) and to “enhanced” their “ability ... to expand . . . .” (Id. at p. 803.) I therefore dissent.
Factual Background
Because the majority completely ignores the trial court’s factual findings and glosses over the details of the proposed bond financings, I begin by discussing those matters.
In each of the three validation actions here at issue, the California Statewide Communities Development Authority (the Authority) moved for a default judgment. In its moving papers, the Authority “assumed,” but did not concede, that each school “would be considered” to be “pervasively sectarian,” meaning that “ ‘religion is so pervasive [at the school] that a substantial portion of its functions are subsumed in [its] religious mission.’ ”
*814The Authority also submitted declarations in support of its motions. Regarding Oaks Christian School, the Authority’s supporting declarations stated: (1) the school is a “Christian school for the education of children in the sixth through twelfth grades”; (2) its “mission statement is ‘to grow in knowledge and wisdom through God’s grace, and to dedicate [oneself] to the pursuit of academic excellence, athletic distinction and Christian values’ ”; (3) students and their parents “must agree” to “support the School’s mission, statement of faith and Biblical goals and objectives”; (4) “[f]acuity members must be Christian and . . . sign a statement of faith”; and (5) the school “seeks,” among other things, “to develop ‘each student’s mind, body and spirit . . . through . . . spiritual training by the finest Christian teachers and coaches in the nation,’ ” “foster an understanding of the sovereignty of God to provide a framework for the application of knowledge,” “refine the body and character through teamwork and in competition that honors God,” and “encourage a passion to love God.” In its supporting brief, the Authority added that the school “require[s] . . . that students attend assembly period twice a week during which prayers may be held.”
Regarding California Baptist University, the Authority’s supporting declarations stated: (1) the school is “a Christian liberal arts institution offering undergraduate and graduate programs of study”; (2) it “seeks” students who “believe in biblically-based Christian principles” and “expect[s]” students “to live in accordance with such principles”; (3) it “require[s]” students “to attend a church of their choosing” and to “complete a certain number of courses in . . . Christian studies”; (4) it “requires that [all] faculty members be Christian, and [that] at least 51% of the faculty members ... be Baptist”; and (5) it “expect[s]” all faculty members “to maintain a theological and philosophical position consistent with the University’s principles.”
Regarding Azusa Pacific University, the Authority’s supporting declarations stated: (1) the school “is an evangelical Christian community of disciples and scholars who seek to advance the work of God in the world through academic excellence in liberal arts and professional programs of higher education that encourage students to develop a Christian perspective of truth and life”; (2) applicants “must evidence appreciation for the standards and spirit of the University, and exhibit moral character in harmony with its purpose”; (3) an applicant’s “involvement in church” is “reviewed” during the admission process; (4) students “must complete . . . 120 hours of student ministry assignments”; and (5) all faculty members must “be Christian and are expected to maintain a theological and philosophical position consistent with the University’s principles.” The Authority’s supporting brief added that the school requires students to “attend chapel.”
In each action, the trial court denied the Authority’s motion for default judgment. In its orders, the court first set forth the facts regarding the schools *815as detailed in the Authority’s declarations. It then found as to each school that the proposed bond financing “fail[ed]” to pass muster under article XVI, section 5, explaining: “Based upon the facts presented, the educational institution is organized primarily or exclusively for religious purposes. It restricts admission of students by religious criteria and discriminates on the basis of religion in hiring faculty. Religion is both mandatory and integral to every aspect of student life. Religion is integrated into classroom instruction, [ft] Thus low cost financing for the school’s ‘acquisition, construction, improvement, renovation, remodeling, furnishing and equipping’ of classrooms and other facilities necessarily involves financing religious indoctrination.”1
In the Court of Appeal, the Authority did not contest the trial court’s factual findings. On the contrary, it argued that because “there [were] no contested factual issues,” the only issue was whether the trial court had applied the correct “legal analysis” in focusing “on the religious nature of the school[s]” instead of “the nature of the benefit being provided.” Moreover, “[f]or purposes of th[e] appeal,” the Authority did “not dispute that [the schools] could be characterized as ‘pervasively sectarian,’ ” and it explained that “an educational institution is considered ‘pervasively sectarian’ when a substantial portion of [its] function is subsumed in its religious mission and it is impossible to separate its religious aspects from its secular aspects.” Similarly, in this court, the Authority does not contest the trial court’s findings. Thus, we must accept the trial court’s factual findings regarding the nature of the schools.2
The details of the proposed bond financing are set forth in purchase and sale agreements between the schools and the Authority, the governing statutes, and declarations the Authority submitted in support of its motions for default judgment. Under these agreements, the Authority, which is a public entity, promises to issue, sell, and deliver the bonds and to “apply the proceeds received from the sale” to pay for the costs of the bond sales and the specified projects at the schools. By both statute and the agreements with the schools, the bonds constitute “special obligations” of the Authority. (Gov. Code, § 91535, subd. (a); see also id., § 91541, subd. (e).) The Authority’s obligation is special in the sense that the bonds are payable only from funds the Authority receives from the schools under the agreements. (Ibid.) In this regard, the Authority’s agreements with Oaks Christian School and California Baptist University state: “The Authority shall not be obligated to pay the *816principal (or redemption price) of or interest on the Bonds, except from Revenues and other moneys received by the Trustee on behalf of the Authority pursuant to this Sale Agreement. . . . [f] The [school] hereby acknowledges that the Authority’s sole source of moneys to repay the Bonds will be provided by the payments made by the [school] pursuant to this Sale Agreement, together with investment income on certain funds held by the Trustee under the Indenture.” The Authority’s agreement with Azusa Pacific University contains a substantively identical provision.
With respect to each school, the Authority simultaneously executes both a purchase agreement and a separate sale agreement. In the purchase agreements, the schools sell and transfer to the Authority all of their right, title and interest in and to the school property on which the improvements will be made. In the sale agreements, the Authority sells and transfers back to the schools all of the interest in the schools’ property it acquired under the purchase agreements. The purchase price for the school property the Authority sells back to the schools is essentially the amount needed to pay off the principal, interest, and any premium on the bonds. “As security for the payment of the [b]onds, the Authority” assigns to a trustee its right to receive the schools’ payments for repurchasing the property, and directs the schools to make these payments directly to the trustee. The trustee, as assignee of the Authority, uses this money to pay off the bondholders on behalf of the Authority and to satisfy the “special obligation[]... of the [Authority” to pay the bondholders. (Gov. Code, § 91535, subd. (a).) As this discussion makes clear, although the schools are to be the sole source of the funds to pay the bondholders, the legal obligation to pay the bondholders is the Authority’s.3
The purpose of these machinations is to save the schools considerable money in financing costs. In general, bond investors will accept a lower interest rate on investments where the interest is tax-exempt. However, interest on bonds cannot be tax-exempt unless a governmental entity like the Authority is the bond issuer. Thus, as the Authority explained in the Court of Appeal, the schools, through the Authority’s participation as bond issuer, will *817be able to borrow money to pay for their projects at a lower interest rate, thus enabling them “to finance their respective projects at a lower cost than is available through conventional private financing.” The savings would be considerable; for example, according to a declaration the Authority submitted in support of its motions for default judgment, the proposed bond financing would have saved Oaks Christian School “approximately $52,500 per month” in financing costs under interest rates prevailing in 2002. Each of the purchase and sale agreements acknowledges the importance of these savings to the schools, stating that “obtaining Tax-Exempt status for the financing of the Costs of the Project is a significant factor in maintaining the operations of the [schools] within the jurisdiction of the Project Program Participant.”
The agreements also describe the projects to be financed through the bond sales. Oaks Christian School intends to use the funds to “acqui[re], construct[], improve[], renovat[e], remodel[], fumish[] and equip[] . . . classrooms, laboratories, administration offices, dining facilities, athletic facilities, parking facilities, [and] a co-generation facility.” California Baptist University intends to make similar use of the funds for “residence facilities, parking facilities, classrooms, administration offices, the academic and student center complex, [and] athletic facilities.” Azusa Pacific University intends to use the funds for similar purposes regarding “certain educational facilities . . . including ... a new . . . residence facility, a dining facility, [and] a mail center.” In the agreements, the schools “agree[] that no facility, place or building financed or refinanced with a portion of the proceeds of the Bonds will be used ... for sectarian instruction or as a place for religious worship or in connection with any part of the programs of any school or department of divinity for the useful life of the Project.”4
Discussion
“The determination of [California’s] public policy . . . resides, first, with the people as expressed in their Constitution . . . .” (Jensen v. Traders & General Ins. Co. (1959) 52 Cal.2d 786, 794 [345 P.2d 1].) In other words, the California Constitution is both “the highest expression of the will of the people of the state” (Ex parte Braun (1903) 141 Cal. 204, 211 [74 P. 780]) and “the preeminent expression of California law.” (American Academy of Pediatrics v. Lungren (1997) 16 Cal.4th 307, 314 [66 Cal.Rptr.2d 210, 940 P.2d 797] (Lungren).) Accordingly, when construing a provision of the *818state Constitution, our “paramount consideration” is “the intent of those who enacted the provision at issue. [Citation.] To determine that intent, [we] look first to the language of the constitutional text, giving the words their ordinary meaning. [Citations.]” (Leone v. Medical Board (2000) 22 Cal.4th 660, 665 [94 Cal.Rptr.2d 61, 995 P.2d 191].) We give the words their ordinary meaning because we “ ‘presume[]’ ” that they were “ ‘so understood by the framers, and by the people who adopted [them].’ ” (Miller v. Dunn (1887) 72 Cal. 462, 465 [14 P. 27].)
In light of the trial court’s uncontested factual findings, the proposed bond agreements in this case unquestionably are invalid under the ordinary meaning of article XVI, section 5’s language. As noted above, among other things, that provision prohibits public entities from “granting] anything to or in aid of any religious sect, church, creed, or sectarian purpose, or helping] to support or sustain any school, college, university, hospital, or other institution controlled by any religious creed, church, or sectarian denomination whatever.” (Art. XVI, § 5.) As we have explained, a bond financing program like the one here at issue “clearly provides a ‘benefit’ ” to participating schools “through the use of a [governmental] instrumentality,” by “enabling]” them “to borrow money ... at a cost below that of the marketplace.” (Priest, supra, 12 Cal.3d at p. 605.) Indeed, as noted above, under interest rates prevailing in 2002, the proposed bond program would have saved Oaks Christian School “approximately $52,500 per month” in financing costs. As also noted above, both the Authority and the schools have acknowledged that the savings realized through the bond program, which would be unavailable without a public entity’s participation, are “a significant factor in maintaining the operations of the [schools] within the jurisdiction of the Project Program Participant.” Given the trial court’s uncontested factual findings that the schools are “organized primarily or exclusively for religious purposes,” “restrict[] admission of students by religious criteria,” “discriminate^ on the basis of religion in hiring faculty,” and “integrate[]” “[r]eligion . . . into classroom instruction,” the proposed bond agreements clearly violate the ordinary meaning of article XVI, section 5’s prohibition against “granting] anything to or in aid of any religious sect ... or sectarian purpose, or helping] to support or sustain any school, college, university, hospital, or other institution controlled by any religious creed, church, or sectarian denomination whatever.”
In several relevant cases, we have explored the reach of article XVI, section 5, and its materially identical predecessor. The more recent—and in my view more authoritative—is California Teachers Assn. v. Riles (1981) 29 Cal.3d 794 [176 Cal.Rptr. 300, 632 P.2d 953] (Riles). There, we held that statutes authorizing the Superintendent of Public Instruction to lend, without charge, textbooks used in the public schools to students attending private sectarian schools were invalid under article XVI, section 5. (Riles, supra, at *819pp. 797-798.) The religious schools at issue in Riles “offer[ed] instruction in secular subjects, but they also [had] as their purpose the teaching of the tenets of their faith. Some of the[] schools [gave] preference to enrolling Catholic pupils; more than 97 percent of the students attending [the] schools [were] Catholic. The schools ordinarily require[d] students to receive religious instruction, attend religious services during the school day, and participate in prayers and religious ceremonies. Sectarian symbols and pictures [were] distributed throughout the schools’ buildings. The teachers in these schools [were] for the most part members of the church.” (Id. at pp. 799-800.)
In Riles, to determine the constitutional validity of the textbook lending program, we first considered “whether it only indirectly benefited] parochial schools.” (Riles, supra, 29 Cal.3d at p. 809.) The trial court had concluded that the program had “a clearly secular . . . purpose” and that the benefit it provided the schools, “though substantial, [was] only indirect and incidental.” (Id. at p. 800.) We disagreed, holding that the benefit sectarian schools received from the program could not “be characterized as . . . only indirect, remote, and incidental.” (Id. at p. 809.) In reaching this conclusion, we focused principally on “the inseparability of the benefit to the pupil and the school, and the impossibility of characterizing the advantage to one as remote and to the other as direct.” (Id. at p. 810.) We explained: “The books are supplied for use in the school, and we are unable to perceive any significant distinction from a constitutional standpoint whether they are loaned to the students for use in the school, or to the school for use by the students. In either circumstance, both the child and the school benefit. The United States Supreme Court has recognized as much in characterizing textbook loan programs as a form of financial assistance to the school even though the loan is nominally made to the student. There is no rational reason for concluding that the school benefits only indirectly or remotely from the loan if the child is the nominal recipient, for it is an undeniable fact that books are a critical element in enabling the school to carry out its essential mission to teach the students.” (Ibid., fn. omitted.)
We next explained in Riles that our conclusion that the benefit was “neither indirect nor remote [did] not end our inquiry,” because not all aid that “directly” benefits sectarian schools is “prohibited (e.g., providing fire protection),” and not all aid that indirectly benefits sectarian schools is “valid (e.g., reimbursement for the purchase of religious articles by students in public and nonpublic schools).” (Riles, supra, 29 Cal.3d at p. 811.) Ultimately, we explained, the program’s validity under article XVI, section 5, turned on “whether the character of the benefit [the program] provided . . . resulted] in the ‘support of any sectarian . . . school.’ ” (Riles, supra, 29 Cal.3d at p. 811.) We concluded that the program did result in such support, and was therefore invalid, because textbooks have “a central place in the educational mission of *820a school” and the benefit being provided “advance[d]” the schools’ “educational function.” (Ibid.) “In this respect,” we explained, “the [textbook lending] program [was] distinguishable from ‘generalized services government might provide to schools in common with others’ [citation], such as fire and police protection, the maintenance of roads and sidewalks, and similar public services. These services, unlike education, have no doctrinal content, and they do not advance the essential objective of the sectarian school, which is the education of the child.” (Id. at pp. 811-812.)
Finally, we held in Riles that the textbook lending program was invalid under article XVI, section 5, even if the schools “used” the books “only for secular instruction.” (Riles, supra, 29 Cal.3d at p. 812.) We reasoned that article XVI, section 5, “do[es] not confine [its] prohibition against financing sectarian schools in whole or in part to support for their religious teaching function, as distinguished from secular instruction.” (Riles, supra, 29 Cal.3d at p. 812.) We also explained that “[¡jurisdictions with similar constitutional provisions [had] also refuse[d] to make such a distinction” (ibid.), and we quoted with approval the following discussion from a Nebraska Supreme Court’s decision interpreting a provision “virtually identical” to article XVI, section 5: “ ‘[T]he court must examine the character of the aided activity rather than the manner or the form in which aid is given. . . . [O]ne of the main purposes of the parent sending his child to a parochial school is to insure the early inculcation of religion. Assuming that textbooks promote the notion of an absolutely neutral and equal secular educational program, the reimbursement or the loan of textbooks to the students is for the purpose of augmenting the public school secular education with religious training. The state, by aiding the parents and the students by textbooks, secular though they may be, is providing a program for aiding the church and in advancing religious education.’ ” (Riles, supra, 29 Cal.3d at p. 812, fn. 15.)
Applying Riles and its analytical framework to this case, I conclude that the proposed bond financings at issue here are invalid under article XVI, section 5. In terms of their religious orientation, the schools at issue here are similar in important respects to the schools at issue in Riles', as the trial court found, “[r]eligion is both mandatory and integral to every aspect of student life” at the schools and the schools both “restrict[] admission of students by religious criteria” and “discriminate!] on the basis of religion in hiring faculty.” Indeed, religion is even more integral to the schools here than it was to the schools in Riles; whereas the trial court in Riles found unproven allegations that the schools there “conducted] their operations to fulfill religious purposes” or “blend[ed] secular and sectarian instruction” (Riles, supra, 29 Cal.3d at pp. 800-801), the trial court here found that the schools are “organized primarily or exclusively for religious purposes” and “integrate!]” “[r]eligion . . . into classroom instruction.” Moreover, the benefit to the schools in this case is every bit as direct as, and is probably far more *821substantial than, the benefit at issue in Riles. As explained above, in finding that the benefit of the textbook lending program was “neither indirect nor remote,” we emphasized in Riles that the program provided “a form of financial assistance to the school[s]” and that textbooks were “a critical element in enabling the school[s] to carry out [their] essential mission to teach the students.” (Riles, supra, 29 Cal.3d at pp. 811, 810.) Here, the proposed bond program clearly would provide a form of financial assistance to the schools; it would enable them to borrow money at below-market rates and significantly lower the cost of constructing, improving, furnishing, and equipping their facilities. Moreover, the facilities the proposed bond program would enable the schools to build or improve, and the furnishings and equipment it would enable them to buy, are critical elements in enabling them to carry out their essential mission to teach students. In this regard, the character of the benefit the proposed bond financings would provide would impermissibly result in the support of sectarian schools by “advancing]” their “educational function.” (Riles, supra, 29 Cal.3d at p. 811.) Finally, the schools’ promise not to use any “facility, place or building financed or refinanced with a portion of’ the bond proceeds “for sectarian instruction or as a place for religious worship or in connection with any part of the programs of any school or department of divinity” does not render the proposed bond financings constitutionally valid because, as Riles established, article XVI, section 5, “do[es] not confine [its] prohibition against financing sectarian schools in whole or in part to support for their religious teaching function, as distinguished from secular instruction.” (Riles, supra, 29 Cal.3d at p. 812.) Thus, under Riles, the proposed bond financings here violate article XVI, section 5.5
Several years before we decided Riles, in Priest, we discussed the scope of article XVI, section 5’s materially identical predecessor, California Constitution former article XIII, section 24, in connection with a statutory bond financing program that was similar in certain respects to the bond financing program now before us. The case arose when the State Treasurer, because of concerns about the statutory program’s constitutionality, refused to perform her duties regarding an approved bond financing. (Priest, supra, 12 Cal.3d at p. 598.) Regarding former article XIII, section 24, we began by explaining generally: “This section has been said to constitute ‘the definitive statement of the principle of government impartiality in the field of religion.’ [Citation.] An examination of the debates of the constitutional convention which drafted the Constitution of 1879 indicates that the provision was intended to insure the separation of church and state and to guarantee that the power, authority, *822and financial resources of the government shall never be devoted to the advancement or support of religious or sectarian purposes. [Citation.] Under this section, the fact that a statute has some identifiable secular objective will not immunize it from further analysis to ascertain whether it also has the direct, immediate, and substantial effect of advancing religion. . . . [f] The section has never been interpreted, however, to require governmental hostility to religion, nor to prohibit a religious institution from receiving an indirect, remote, and incidental benefit from a statute which has a secular primary purpose. [Citation.]” (Priest, supra, at pp. 604-605.)
After setting forth these general principles, we opined in Priest that the statutory bond program there at issue, although “appearing] to approach state involvement with religion [citation],” could not be said “in the abstract” to “cross[] the forbidden line.” (Priest, supra, 12 Cal.3d at p. 606.) We first explained that the statutory program “clearly provide[d] a ‘benefit’ ” by enabling schools “to borrow money through the use of a state instrumentality at a cost below that of the marketplace.” (Id. at p. 605.) We next noted, and deferred to, the Legislature’s determination that the statutory program, “in supporting the maintenance and improvement of facilities for higher education, [was] in the public interest [citations].” (Ibid.) Finally, we stated: “The benefits of the [program] are granted to sectarian and nonsectarian colleges on an equal basis; ... all aid for religious projects is strictly prohibited; and in no event is a financial burden imposed upon the state. In these circumstances the [statutory program] does not have a substantial effect of supporting religious activities.” (Id. at p. 606.)
Unlike the majority, which wholly embraces Priest without either analysis or hesitation, I believe there is good reason to question that decision’s authority and persuasiveness. To begin with, as Priest itself noted, the school seeking bond financing in that case was “not affiliated with any religious organization, and therefore [was] not directly concerned with a challenge to the [statutory program’s] validity . . . under” article XVI, section 5’s predecessor. (Priest, supra, 12 Cal.3d at p. 598, fn. 5.) For this reason, in Riles-—which, like Priest, Justice Mosk authored for the court—we explained that Priest was “dictum” insofar as it purported to address schools that were “affiliated with any religious denomination.” (Riles, supra, 29 Cal.3d at p. 806, fn. 10.) The majority ignores this statement in Riles in asserting that Priest “held that issuing revenue bonds to fund capital improvements at religiously affiliated colleges did not violate” article XVI, section 5’s predecessor. (Maj. opn., ante, at p. 799, italics added.)
Moreover, Priest’s assertion that article XVI, section 5’s predecessor had not been interpreted “to prohibit a religious institution from receiving an indirect, remote, and incidental benefit from a statute which has a secular *823primary purpose” (Priest, supra, 12 Cal.3d at p. 605) rested on very shaky ground. In support of this assertion, Priest cited our decision in Lundberg v. County of Alameda (1956) 46 Cal.2d 644 [298 P.2d 1] (Lundberg), and discussed the Court of Appeal’s decision in Bowker v. Baker (1946) 73 Cal.App.2d 653 [167 P.2d 256]. (Priest, supra, 12 Cal.3d at p. 605.) Lundberg does not in any way support Priest’s assertion; there, in rejecting a challenge to a tax exemption under another of article XVI, section 5’s materially identical predecessors, we tersely explained: “This section does not expressly mention tax exemptions, but, even if we assume that it prohibited them, it was superseded by the subsequent adoption of’ two other constitutional provisions. (Lundberg, supra, 46 Cal.2d at p. 653.) In Bowker, the Court of Appeal held that article XVI, section 5’s predecessor did not prohibit a school district from incurring “some slight added cost” (Bowker, supra, at p. 657) to permit parochial school students to occupy empty seats on public school buses, reasoning that “the direct benefit” of this expense “flowfed] to the children . . . , with only an indirect benefit to the private parochial school . . . .” (Id. at pp. 666-667.) Priest failed to mention Bowker’s narrow reasoning in making the much broader claim that article XVI, section 5’s predecessor did not “prohibit a religious institution from receiving an indirect, remote, and incidental benefit from a statute which has a secular primary purpose. [Citation.]” (Priest, supra, 12 Cal.3d at p. 605.) Moreover, in Riles, we rejected the “ ‘child benefit’ theory” on which Bowker was based, noting that it “ha[d] been criticized by courts and commentators” (Riles, supra, 29 Cal.3d at p. 807), had produced “dissonant decisions” that could not be “harmonize[d]” (id. at pp. 807, 808), and “in most instances . . . leads to results which are logically indefensible.” (Id. at p. 809.) Given these circumstances, it is little wonder that Riles, though written for the court by the same justice who wrote Priest, expressly declined to endorse or reaffirm either Priest or Bowker, and instead cast doubt on both by stating that because they were distinguishable, it was unnecessary to “consider whether [they] were correctly decided.”(Riles, supra, 29 Cal.3d at p. 813, fn. 16.)
These concerns aside, unlike the majority, I believe that the proposed bond financings in this case are invalid even under Priest’s dictum. As explained above, Priest stated that the purpose of article XVI, section 5, is “to guarantee that the power, authority, and financial resources of the government shall never be devoted to the advancement or support of religious or sectarian purposes,” and that even a statute with a “secular objective” is invalid if it “has the direct, immediate, and substantial effect of advancing religion.” (Priest, supra, 12 Cal.3d at p. 604.) For the reasons explained above, including and especially the trial court’s factual findings regarding the nature of the schools here at issue, the proposed bond financings would have the direct, immediate and substantial effect of advancing religion and would *824contravene the constitutional provision’s purpose, by devoting the government’s power and authority to raise money at below-market interest rates through the issuance and sale of tax-exempt bonds to the support and advancement of religious or sectarian purposes. This conclusion is fully consistent with Priest’s view that the bond financing program there at issue was not, “in the abstract” (id. at p. 606), invalid given the particular “circumstances” in that case. (Id. at p. 598, fn. 5.) As noted above, one of those “circumstances” was that “all aid for religious projects [was] strictly prohibited.” (Id. at p. 606.) The facts underlying this circumstance included not only statutory use limitations similar to the limitations in the restricted use covenants here at issue, but also the complete exclusion of schools that either “ ‘restricted] entry on . . . religious grounds’ ” or “ ‘require[d] all students gaining admission to receive instruction in the tenets of a particular faith.’ ” (Priest, supra, 12 Cal.3d at p. 596.) In Riles, we specifically noted this exclusion in distinguishing Priest. (Riles, supra, 29 Cal.3d at pp. 806, 813, fn. 16.) Here, given the trial court’s uncontested factual findings that “[religion is both mandatory and integral to every aspect of student life” at the schools, and that the schools are “organized primarily or exclusively for religious purposes,” “restrict[] admission of students by religious criteria,” “discriminate^ on the basis of religion in hiring faculty,” and “integrate^” “[r]eligion . . . into classroom instruction,” notwithstanding the restricted use covenants, the proposed bond financings would impermissibly provide aid for religious projects. Thus, even under Priest’s dictum, the proposed bond financing programs violate article XVI, section 5.6
In any event, Priest must be read in light of our subsequent decision in Riles. As explained above, the benefit the schools would receive in this case under the bond financing program would be “direct” as we interpreted that term in Riles. (Riles, supra, 29 Cal.3d at p. 810.) As also explained above, we held in Riles that the key question under article XVI, section 5, is not whether the benefit in question is direct or incidental to some public purpose— because not all direct benefits are invalid, and not all indirect benefits are permissible—but is “whether the character of the benefit . . . results in the ‘support of any sectarian . . . school’ ” by “advancing]” the school’s “essential objective ..., which is the education of the child.” (Riles, supra, 29 Cal.3d at pp. 811-812.) Notably, in Riles, notwithstanding the trial court’s conclusion that the program “ha[d] a clearly secular legislative purpose” (id. at *825p. 800), we invalidated the textbook lending program because textbooks “hav[e] a central place in the educational mission of a school” and are an “ ‘essential tool of education . . .’ [citation].” (Id. at p. 811.) Similarly, the classrooms, laboratories, residence and dining halls, and other facilities the schools here intend to build or improve with the bond proceeds, and the furnishings and equipment they intend to purchase with those proceeds, are also central to the schools’ educational mission and are essential tools of education.
The majority virtually ignores Riles, declaring in a footnote that it, unlike this case, involved “direct public aid!’ to parochial schools in the form of textbooks provided “at public expense.” (Maj. opn., ante, at p. 801, fn. 7.) By contrast, the majority asserts, because “no public funds are expended” in connection with the proposed bond financings here (ibid.), only “indirect assistance” is at issue in this case. (Id., at p. 799.)
For several reasons, the majority’s stated basis for disregarding Riles is invalid. Initially, the majority’s view rests on its unsupported assertion that the proposed bond financings would involve “no [expenditure of] public funds.” (Maj. opn., ante, at p. 801, fn. 7.) As noted above, the bonds here will be issued and sold by a public entity: the Authority. The majority does not explain why the proceeds from the sales, which will be used at the schools, are not public funds. Nor does the majority explain why the interest on those proceeds, which also will be used at the schools, are not public funds. Moreover, although the majority asserts that the obligation to pay the bondholders “falls to the recipient schools” and that the payment obligation will not be “secured by any public property” (maj. opn., ante, at p. 797), as noted above, payment of the bondholders is, by statute and by agreement, a special obligation of the Authority, and the Authority’s payment obligation is secured by its right to receive from the schools payments to repurchase school property from the Authority. The majority simply glosses over these aspects of the proposed bond financings.7
More broadly, the majority’s focus on whether the benefit would involve a direct expenditure of public funds is inconsistent with the language of article XVI, section 5, and our interpretation of that language in both Riles and *826Priest. The majority’s analysis indicates that only an expenditure of public money may constitute a direct benefit. However, in Priest, we expressly rejected that view, explaining that the “terms” of the constitutional provision “forbid granting ‘anything’ to or in aid of sectarian purposes, and prohibit public help to ‘support or sustain’ a sectarian-controlled school. The section thus forbids more than the appropriation or payment of public funds to support sectarian institutions. It bans any official involvement, whatever its form, which has the direct, immediate, and substantial effect of promoting religious purposes.” (Priest, supra, 12 Cal.3d at p. 605, fn. 12.) For reasons already explained, the bond financings proposed here would have such an effect, by enabling the schools “to obtain economic aid” they “would not otherwise be able to obtain without the government’s direct participation.” (Steele v. Industrial Development Bd. Of Metro (6th Cir. 2002) 301 F.3d 401, 438 (dis. opn. of Clay, J.).) Even if, as the majority asserts, there would be no expenditure of public funds, that circumstance would “not alter for one moment the fact that a direct economic benefit [would] accrue[] to [the schools] as a result of the government’s active participation in arranging for a low-cost loan that [would] enable[] the [schools] to advance [their] sectarian mission.” (Ibid.) Moreover, in Riles, as already noted, we held that even a so-called indirect benefit may violate article XVI, section 5, and that the key question is not whether the benefit in question is direct or incidental, but whether the “character of the benefit . . . results in the ‘support of any sectarian . . . school’ ” by “advancing]” the school’s “essential objective . . . , which is the education of the child.” (Riles, supra, 29 Cal.3d at pp. 811-812.) Thus, even the majority’s mistaken view that no “direct public aid’ is at issue here (maj. opn., ante, at p. 801, fn. 7) does not justify its complete disregard of our unanimous decision in Riles.
The majority’s analysis is at odds with Riles in another important respect. As noted above, we unanimously held in Riles that the textbook lending program there at issue was invalid under article XVI, section 5, even if the books were “used only for secular instruction.” (Riles, supra, 29 Cal.3d at p. 812.) We explained that article XVI, section 5, “do[es] not confine [its] prohibition against financing sectarian schools in whole or in part to support for their religious teaching function, as distinguished from secular instruction.” (Ibid.) Thus, under Riles, where a government program provides a benefit that “advance[s] the essential objective of [a] sectarian school,” the school’s ability to separate its religious and secular aspects and to use the benefit only for the latter does not save the program’s constitutionality. (Ibid.) Contrary to Riles, the majority’s test resurrects the inquiry into a school’s ability to separate its religious and secular aspects. Under that test, the constitutionality of aid given to a school that “provide[s] a broad curriculum in secular subjects” (maj. opn., ante, at p. 803), that “includes a religious perspective in its curriculum” (ibid.), and that “expresses]” its *827“religious viewpoint in [its] otherwise secular classes” (id. at p. 793), depends in part on whether the school uses the aid “for ‘religious projects’ ” (id. at p. 801), whether its “secular classes consist of information and coursework that is neutral with respect to religion” (id. at p. 793), and whether classes taught in facilities financed with bond proceeds “include[] as part of the instruction information or coursework that promotes or opposes a particular religion or religious beliefs.” (Id. at p. 804.) Under this analysis, the test of constitutionality depends on the extent to which a school separates its teaching of secular subjects from its teaching of religion. In this regard, the majority’s test is contrary to the language of article XVI, section 5, which, as we held in Riles, “do[es] not confine [its] prohibition against financing sectarian schools in whole or in part to support for their religious teaching function, as distinguished from secular instruction.” (Riles, supra, 29 Cal.3d at p. 812.)
Another problem with the majority’s newly minted test—which has not been proposed by any party to this case and which is not based on the language of article XVI, section 5, or on any existing case law—is that it is hopelessly vague in several respects. The majority states that a proposed bond financing is constitutional only if, among other things, the benefited school “offers a sufficiently broad curriculum in secular subjects . . . that [its] use of the educational facilities built or improved with the bond funding may be expected to promote the public interest in making secular education more available to California residents in general.” (Maj. opn., ante, at p. 806.) This formulation leaves the reader—and the trial court, which must apply the majority’s test on remand—asking: How broad is “sufficiently broad”? The majority states that offering classes in only “a few” secular subjects is not enough (maj. opn., ante, at p. 803), but exactly how many is “a few”—two, three, four?8 Do judges have discretion as to how many is “a few,” such that one judge may properly find that four secular subjects are not enough, while another may also properly find that four secular subjects are enough? Is any number more than “a few,” whatever that is, automatically enough to support the conclusion that the school’s “use of the educational facilities built or improved with the bond funding may be expected to promote the public interest in making secular education more available to California residents in general”? (Maj. opn., ante, at p. 806.) The majority provides no guidance on these questions.
The majority’s test is also vague in directing trial courts to determine whether “the academic content” of a religious school’s courses in secular subjects is typical of that provided in nonreligious schools. (Maj. opn., ante, at p. 804.) The majority fails to define what it means by the term “academic *828content.” The word “academic” simply means “of, belonging to, or associated with an academy or school.” (Webster’s 3d New Intenat. Dict. (2002) p. 9.) Thus, all content of a religious school’s courses in secular subjects constitutes “academic content.” Presumably, the majority means something else by its use of the term, but the majority does not say what. Insofar as the majority is using the term to mean nonreligious content, the majority’s test is tautological; the nonreligious content of a religious school’s course in a secular subject would seemingly have to be typical of the content provided in a nonreligious school’s course in the same subject.
The majority’s test is tautological in another sense. According to the majority, a school that includes a religious perspective in its curriculum may be the beneficiary of a bond financing only if two purportedly separate requirements are met: the school must offer “a sufficiently broad curriculum in secular subjects” (maj. opn., ante, at p. 806, italics added) and “the information and coursework used to teach [those] secular subjects must be neutral with respect to religion.” (Id., at p. 804.) In my view, a subject qualifies as “secular,” by definition, only if it consists of information and coursework that is neutral with respect to religion. In other words, any subject that qualifies as secular will necessarily consist of information and coursework that is neutral with respect to religion. Thus, these two separately stated requirements of the majority’s test are, in actuality, but one.
The majority’s test is also ambiguous in that it announces seemingly inconsistent standards. On the one hand, the majority states that a benefited school may not use the bond proceeds “for ‘religious projects,’ that is ‘sectarian instruction or as a place for religious worship or in connection with any part of the programs of any school or department of divinity for the useful life of the Project.’ ” (Maj. opn., ante, at p. 801.) On the other hand, the majority states that it is constitutionally permissible for a religious school, in those same facilities, to express its religious viewpoints and perspectives in the course of teaching secular subjects. (Maj. opn., ante, at p. 794.) The majority fails to explain why a school’s expression of its religious viewpoints and perspectives in secular classes does not constitute “sectarian instruction,” or why the building or improvement of a facility in which a school will express its religious viewpoints and perspectives does not constitute a “religious project.” In this regard, the majority’s analysis seems to be internally inconsistent; the first part of the majority’s four-part test appears to permit what the third part prohibits. More importantly, the majority’s analysis expressly permits the schools to impart their religious viewpoints and perspectives in secular courses, in classrooms built, improved, furnished and equipped with money raised by a public entity—the Authority—on the schools’ behalf through the Authority’s issuance and sale of bonds. In my view, this violates both the plain meaning and our judicial construction of article XVI, section 5.
*829A related ambiguity in the majority’s test is the distinction the majority appears to draw between religious instruction and the expression of religious viewpoints and perspectives. On the one hand, the majority declares that a religious school may not, in facilities financed with bond proceeds, teach a “class that includes as part of the instruction information or coursework that promotes or opposes a particular religion or religious beliefs.” (Maj. opn., ante, at p. 804.) On the other hand, the majority states, a school may “express[j” its “religious viewpoints] in [its] otherwise secular classes.” (Maj. opn., ante, at p. 793.) Thus, in the majority’s view, there is a difference between expressing a religious viewpoint, which is permissible, and “including] as part of the instruction information or coursework that promotes or opposes a particular religion or religious beliefs,” which is not permissible. (Maj. opn., ante, at p. 804.) Unfortunately, the majority fails to explain where the difference lies, or how a court is supposed to tell one from the other.
The majority’s test also gives rise to several other concerns. First, it appears to require significant and unworkable monitoring to determine whether the schools, in teaching secular courses, are impermissibly including information or coursework that promotes or opposes a particular religion or religious beliefs, or are merely expressing religious viewpoints and perspectives. In this regard, notwithstanding the majority’s claim to the contrary (maj. opn., ante, at p. 804), the majority’s test will require scrutiny of the schools’ day-to-day operations by the Authority and the courts.9 Second, the majority’s test appears to be too narrow to address the constitutional concerns the proposed bond financings raise. Although the majority acknowledges “concern that a school with a religious perspective may [impermissibly] use the facilities built or improved with the revenue bond proceeds to substantially further its religious mission,” the test the majority announces to address this concern focuses only on what happens inside the schools’ classrooms. (Maj. opn., ante, at p. 803.) Notably, as already explained, the schools here intend to use the bond proceeds not just for classrooms, but also for dining and residence halls and an academic and student center complex. The majority’s analysis appears to ignore the extent to which the schools may use those facilities to further their religious missions.10
*830Finally, for several reasons, I disagree with the majority’s view that the proposed bond financings here are valid because they are “in the nature of a tax policy rather than an aid program.” (Maj. opn., ante, at p. 804, fn. 9.) First, the majority’s discussion rests on the untested and unwarranted assumption that anything that may be characterized as being “in the nature of a tax policy” because it somehow involves a “tax exemption]” (ibid.) does not, for that reason, violate article XVI, section 5. Nothing supports this assumption; on the contrary, in Lundberg, in rejecting a constitutional challenge to a tax exemption for property used for school purposes and owned by religious entities, we relied on other constitutional provisions that expressly authorized the exemption and “superseded” any prohibition in article XVI, section 5’s predecessor. (Lundberg, supra, 46 Cal.2d at p. 653.) The majority cites no constitutional provision that expressly authorizes the proposed bond financings in this case.11 Second, the majority’s discussion rests on another untested and unwarranted assumption: that the terms “tax policy” and “aid program” (maj. opn., ante, at p. 804, fn. 9) are mutually exclusive, and that something that can be called a tax policy necessarily cannot also constitute an aid program. Third, I disagree with an express premise of the majority’s “tax policy” analysis: that enabling schools to borrow funds at below-market interest rates is merely an “ ‘incidental result’ ” of providing private investors with a tax exemption. (Maj. opn., ante, at p. 805.) It is clear that enabling schools to borrow funds at below-market interest rates is both the intended result and primary purpose of the bond financing program. Indeed, there seems to be no other reason for the program’s existence; plenty of other tax-exempt investments are available to private investors, and the only reason for providing this one is to enable the schools to finance construction and improvement projects at an interest rate lower than would be available through conventional private financing.
The majority’s “tax policy” discussion suffers from a fourth flaw: it is based on an analysis we long ago criticized and rejected in Riles. There, as noted above, we explained that the “ ‘child benefit’ theory”—which looks to whether a school is benefited only as an incidental result of a benefit provided directly to students—“has been criticized by courts and commentators” (Riles, supra, 29 Cal.3d at p. 807), produces “dissonant decisions” that cannot be “harmonize[d]” (id. at pp. 807-808), and “in most instances . . . leads to results which are logically indefensible.” (Id. at p. 809.) The majority here *831adopts a close variant of that discredited theory, by reasoning that the schools benefit only incidentally from a tax benefit being provided directly to private investors. In my view, having rejected that approach 25 years ago in Riles, we should not adopt it now. In any event, just as “[tjhere [was] no rational reason” in Riles “for concluding” that the schools there “benefited] only indirectly or remotely from the loan” of textbooks to students (id. at p. 810), there is no rational reason here for concluding that the schools would benefit only indirectly or remotely from the tax advantages being made available to private investors. On the contrary, given the availability of other tax-free investments, the primary beneficiary of the proposed bond financings here would be the schools, which would save millions of dollars in financing costs.
In the end, this case seems relatively simple. By issuing and selling bonds, making the proceeds available to the schools, and accepting the special obligation to pay the bondholders, the Authority—a public entity—would be raising money on behalf of the schools at below-market interest rates that the schools could not obtain on their own. As the majority explains, the Authority’s purpose in taking these actions would be “to encourage” the “development” of the schools (maj. opn., ante, at p. 795) and to “enhance[]” their “ability ... to expand . . . .” (Id. at p. 803.) By so interceding in the marketplace on the schools’ behalf, the Authority would save the schools millions of dollars in financing costs and would significantly enhance their ability to carry out their mission. Given the trial court’s factual findings regarding that mission and the religious nature of these schools, even if no transfer of public funds is involved, the proposed bond financings violate article XVI, section 5’s prohibition against “granting] anything to or in aid of any religious sect ... or sectarian purpose, or helping] to support or sustain any school, college, university, hospital, or other institution controlled by any religious creed, church, or sectarian denomination whatever.”
I emphasize that my conclusion does not reflect “ ‘hostility to religion’ ” (maj. opn., ante, at p. 805) any more than did our unanimous holding in Riles that lending secular textbooks to religious schools violates article XVI, section 5, even if the schools use the textbooks only for secular instruction. Rather, my conclusion reflects my fealty to the will of the people as expressed first and foremost in the language of the California Constitution, and my view of the judiciary’s limited role in applying that Constitution. “The question before us is not whether, as a matter of policy, the [proposed bond financings are] wise or beneficial, but instead whether [they are] constitutional. We [must] determine the validity of the [proposed bond financings] by applying
*832the relevant legal principles embodied in the California Constitution, the preeminent expression of California law enacted by the people.” (Lungren, supra, 16 Cal.4th at p. 314.) Applying those constitutional principles, I conclude that the proposed bond financings here at issue are invalid under article XVI, section 5.1 therefore dissent.
Werdegar, J., and Moreno, J., concurred.
The trial court’s orders make clear that the court based its ruling on the facts presented in the Authority’s declarations. Thus, the majority errs in asserting that “it is unclear ... on what evidence” the trial court based its findings. (Maj. opn., ante, at p. 807, fn. 11.)
Curiously, despite the trial court’s findings and the Authority’s failure to contest those findings, the majority is merely willing to “infer” that the schools here “include a religious perspective along with [their] teaching of secular subjects.” (Maj. opn., ante, at p. 803, fn. 8.)
The Authority’s purchase agreements with Oaks Christian School and California Baptist University each specify that the Authority must pay $1 to purchase the schools’ property. The Authority’s purchase agreement with Azusa Pacific University does not specify an amount for the Authority’s purchase of the school’s property. Instead, it requires the Authority to make installment payments “in an amount necessary for the Trustee to make the transfers and deposits required pursuant to Section 5.02 of the Indenture.” It also specifies that the Authority’s obligation to make these installment payments “is limited exclusively to the payments and other moneys and assets received by the Trustee on behalf of the Authority pursuant to the Sale Agreement,” and it directs the school to “make each Sale Payment due under the Sale Agreement directly to the Trustee in satisfaction of the Authority’s Installment Payment obligations.”
The quoted language appears in the Authority’s agreements with Oaks Christian School and California Baptist University. In slightly different language, the Authority’s agreement with Azusa Pacific University states: “No portion of the proceeds of the Bonds shall be used to finance or refinance any facility, place or building used or to be used ... for sectarian instruction or as a place for religious worship or in connection with any part of the programs of any University or department of divinity for the useful life of the Project.” These provisions will hereafter be referred to as restricted use covenants.
The restricted use covenants do not cure the constitutional infirmity for an additional reason: they fail to limit the schools’ use of the furnishings and equipment purchased with the bond proceeds. By their terms, they limit only the use of any “facility, place or building financed or refinanced with a portion of’ the bond proceeds.
The majority asserts that Priest’s dictum regarding the validity under the state Constitution of the statutory bond program as applied to religiously affiliated schools “did not depend on those colleges giving no admissions preference to adherents of their own faiths.” (Maj. opn., ante, at p. 800, fn. 6.) However, the majority cites nothing from Priest to support its assertion, and the majority’s unsupported assertion ignores both the factual context of Priest and our discussion of Priest in Riles. The majority also ignores the fact, as previously noted, that the restricted use covenants do not limit the schools’ use of the furnishings and equipment they purchase with the bond proceeds.
The majority insists that the bondholders have “no recourse for nonpayment against the Authority.” (Maj. opn., ante, at p. 801.) However, the bondholders would appear to have recourse against the Authority insofar as the schools have made payments to the Authority to enable it to pay the bondholders. The majority also glosses over another aspect of the bond financing agreements: after the schools transfer their interest in school property to the Authority, the Authority will transfer its interest back to the schools. The majority does not explain why the latter transfer would not violate article XVI, section 5’s prohibition against a public entity’s making “any grant or donation of . . . real estate ... for any religious creed, church, or sectarian purpose whatever.”
The word “few” is defined as “[a]n indefinitely small number of persons or things.” (American Heritage Dict. (4th ed. 2000) p. 654, italics added.)
Unlike the majority, I am not convinced that it will be sufficient merely to examine the schools’ “course descriptions.” (Maj. opn., ante, at p. 804.) There is no reason to suppose that the actual religious content of a purportedly secular course taught in a sectarian school will be accurately reflected in a formal course description.
As the majority’s analysis implicitly recognizes, the restricted use covenants are not the answer to this problem. If they were, then there would be no need to determine whether the schools, notwithstanding the restricted use covenants, are impermissibly including in their teaching of secular subjects information or coursework that promotes or opposes a particular religion or religious beliefs.
In finding that the proposed financings have a secular purpose, the majority relies on article IX, section 1 of the California Constitution, which directs “the Legislature [to] encourage by all suitable means the promotion of intellectual, scientific, moral, and agricultural improvement.” (See maj. opn., ante, at pp. 792, 802-803.) By its terms, that section is relevant to acts of “the Legislature.” (Cal. Const., art. IX, § 1.) At issue here are proposed acts of the Authority, not the Legislature. Moreover, the section speaks only to the use of “suitable means.” (Ibid.., italics added.) Means that violate other provisions of the state Constitution, such as article XVI, section 5, cannot be regarded as “suitable.” (Cal. Const., art. IX, § 1.)