In the conflict between accommodationist and separationist views of the establishment clause, the supreme court has in recent times:

the virginia plan called for three branches of government and two houses of congress. representation in each house would be determined by population. the new jersey plan called for three branches of government and a single house of congress. each state would have an equal vote.

in mcculloch v. maryland (1819) the supreme court ruled that congress had implied powers under the necessary and proper clause of article i, section 8 of the constitution to create the second bank of the united states and that the state of maryland lacked the power to tax the bank.

gibbons v. ogden, (1824), was a landmark decision in which the supreme court of the united states held that the power to regulate interstate commerce, granted to congress by the commerce clause of the united states constitution, encompassed the power to regulate navigation.