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Before the 19th century, many Americans worked on Christmas, but in the industrial era the holiday began also to honor universal values, such as home, children and family life, and to incorporate secular customs like exchanging gifts and cards, and the decoration and display of evergreen "Christmas Trees." Congress proclaimed Christmas a federal holiday in 1870. In 1999, a federal court acknowledged these secular aspects in rejecting a claim that the holiday impermissibly endorsed and furthered a particular religious belief.