There was still controversy after the Council at Nicea. Arianism had been defeated, but Semi-Arians (including Apollinarians and Macedonians) were still quite active. There was enough ambiguity in the Nicene Creed, they thought, to allow them to disagree with the Christology established at Nicea. The reign of Julian the Apostate allowed these groups to flourish, since the Church was unable to organize a Council to deal with their aberrant beliefs. The actions of Constantius also had a great deal to do with this flourishing of heterodoxy; his own opinions changed, and he allowed greater freedom for followers of a modified form of Arianism prior to his death.

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