In 2005, a Federal Judge in Georgia ruled that any sticker or notice violated the separation of Church and state, "Due to the manner in which the sticker refers to evolution as a theory, the sticker also has the effect of undermining evolution eduction. . . The distinction of evolution as a theory rather than a fact is the distinction that religiously motivated individuals have specifically asked school boards to make…. And in doing so improperly entagles religion and education" (Larson, 318).

Creation science now had to change, and now became intelligent design. Numerous districts either required it to be taught, or required statements about it be read at the same time as the teaching of any Darwinian theory. The first case, however, to test an individual district's policy to teach intelligent design. The plaintiffs argued that intelligent design was, in fact, creationism as an alternative to evolution. This, they...
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