The focus of this article is an examination of public university funding of student organizations, particularly where that funding is tied to a student vote or referendum. The earliest Supreme Court venture into student funding occurred in Rosenberger v. Rector and Visitors of University of Virginia where although not infolving a referendum, the funding decision required a student government vote and the Court made the seminal determination that university funding for student organizations constituted a limited public forum and, as a result, funding had to be provided on a viewpoint-neutral basis. In Rosenberger, the Court held that a university could not refuse to fund a religious student organization's publication that used a religious viewpoint to examine social and political issues.