Snow, who often voted with the Republicans, was considered one of the most conservative Democrats in the General Assembly, and his record reflected the views of his constituents.
New guidelines published by the Welsh Assembly Government last week said school governors should take in religious views and consider whether their uniform policy interferes with the right to manifest a religion or belief.
Nick Fenwick, FUW, suggested that the views the minister expressed might have been different had the assembly government made more "robust statement" about their preferred direction of travel.