How have courts interpreted the "no preference" clause in the Federal Religious Freedom Act?

In Sands, the court upheld an injunction against a school district's use of prayers at graduation ceremonies. A plurality of the court noted: "The Attorney General of this state has observed that '[i]t would be difficult to imagine a more sweeping statement of the principle of governmental impartiality in the field of religion' than that found in the 'no preference' clause (25 Ops.Cal.Atty.Gen. 316, 319 (1955)), and California courts have interpreted the clause as being more protective of the principle of separation than the federal guarantee (Fox v. City of Los Angeles, supra, 22 Cal.3d 792, 150 Cal.Rptr. 867, 587 P.2d 663)." (Sands, supra, 53 Cal.3d at p. 883, 281 Cal.Rptr. 34, 809 P.2d 809.)