Establishment Clause and Strict Scrutiny

[Jesse Merriam]

I am curious whether there is any commentary on why Establishment
Clause doctrine does not include a strict scrutiny framework.  Do list
members think that the Establishment Clause does not include this
framework because the clause is a structural guarantee and is thus
different from the many constitutional provisions that have been
subject to a balancing of government and individual interests? Or is
it because we just don't think that a situation would arise in which
promoting religion would actually be necessary to promote some
governmental interest?  Are there any other ideas about why the
Establishment Clause is different?

Thanks.

-Jesse Merriam