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Education vs. Selective Teaching; The Continuing Conflict between Church and State

Updated on October 12, 2009

When faced with an issue that is not in the current news or splashed across the tabloids, many often revert to thinking, “That doesn’t affect me!” Although that is the easy way out, most times an issue doesn’t only affect one person, it affects everybody. Religion and education have been pre-destined to run into conflict about half a second after there was a decision to separate church and state. But did they really ever get separated? In most schools students are told not to wear their hats, while today it is a symbol of respect, it all originated from the church. Men were supposed to take off hats in church to show respect to God. Women, on the other hand, were not ‘suggested’ to do so because there is a verse in the Bible saying that women’s heads ought to remain covered. This is still a debated issue in some denominations of Christianity. From this verse, women could wear hats indoors, but men couldn't. Over time it extended to all public places.[1] The church still has a huge impact on the state. In many regions of our own country there is what seems to be a never ending controversy on how to teach evolution and the origin of man, if at all! Stimulated from Charles Darwin’s book, The Origin of Species(1859), the controversy between Science and Religion is continuing to cause lots of big-headaches in the United States. Since 1859, there have been cases of controversy over education and religion in Arkansas, Tennessee, Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Georgia, Maine, Oregon and Washington State. Throughout each case, the perspective that there is no place for only creationism in education only becomes more appealing.

Ideas of where humans originated from were already stirring up controversy long before any modern day court cases. Aristotle had already set in mind that science was a friend to humanity. He thought that the natural order of the world was orderly, and set this mentality into the public. Today we know that the natural order of things is chaos, or entropy. Aristotle came up with the idea of spontaneous generation, or abiogenesis. This is the idea that living organisms came from nonliving things.[2] For example, every year in the spring, the Nile River flooded areas of Egypt along the river. This flooding left behind nutrient-rich mud that enabled the people to grow that year’s crop of food. Oddly, along with the muddy soil, large numbers of frogs appeared that weren’t around in drier times. Aristotle came to the obvious conclusion that frogs came from mud. Of course in modern times we know very well that this is not the case; the eggs left there had hatched.

Progressing into the 1600’s, many scientists such as Francesco Redi, were questioning the theory of abiogenesis. By testing 3 jars with meat in it: one jar open, one jar with netting, and the other sealed, Redi successfully proved that maggots do not come from meat. This experiment successfully killed the theory of spontaneous generation. [3] Then along came Charles Darwin, from him we’ve adopted his idea of natural selection. This is the most widely accepted of his theories for evolution, stating that populations evolve over generations. When Darwin wrote his book, The Origin of Species, he knew he was entering controversial territory by questioning the history of humanity. Still today people are arguing this idea, but most importantly they are arguing whether or not to teach this idea.

Evolution in itself is a big complicated mess. There are many aspects to evolution; the main aspects that cause such a problem for religious groups are the fossil record and common decent. The trouble with the fossil record is there doesn’t seem to be a gray area between one species and another. As Emerson Thomas McMullen put it,

“If land animals truly came from sea creatures, one would expect to find plenty of evidence of this, such as fossils of fish with their fins turning into legs. Darwin wrote in his Origin of Species that "innumerable transitional forms must have existed." The predicted large numbers of fossil intermediate forms were never found.” [4]

This trouble with the fossil records logically leads to common decent. Although many are in denial, scientists have tons of supporting evidence that humans share a common ancestor, believed to have existed about 5 to 8 million years ago, with modern African apes such as gorillas or chimpanzees. From this common ancestor derived two separate lineages. One of these lineages resulted in the evolution of gorillas and chimps, and the other resulted into early human ancestors, hominids.[5] Many Creationists oppose this idea because they do not believe the earth to be more than 10,000 years old. For evidence of how humans arrived, they look to their faith for evidence.

Many biblical creationists argue that the earth was only created from 6,000 to 10,000 years ago. The theory of evolution states the earth has been around for at least 4.5 billion years. Scientists have gathered this information from observing nuclear decay, and the speed of light. The trouble is no human before 4,000 BCE was able to observe, measure, or record those specific processes. One of the most apparent indicators in our earth being at least 10 millenniums old is the sun. Our sun is only one of countless numbers of stars in the Milky Way. This galaxy alone is more than 100,000 lights years across. This is important because this shows that light from some stars in our galaxy has taken tens of thousands of years to reach earth. While this sounds logical, many believers in a younger earth argue that God created the galaxy with light rays going in all directions from each star, which would create the illusion of earth being older than it actually is. This is completely not fact based because this argument would mean that “God created” the universe as if it had a history at the time of itself being created. That doesn’t make all that much sense. [6]

Aside from the speed of light, radioactivity is another way to detect life span, just as mentioned before. A nuclide is a radioactive form of matter which decays at a certain rate into another form of matter. After a certain amount of time which is equal to a nuclide’s half-life, there is logically only half of the original material left. While many argue that science is only theory and not fact, it is a fact that each nuclide with a half-life of 80 million years can be found naturally occurring on earth. Also, all nuclides with a half-life under 80 million years do not exist naturally at detectable levels of the earth’s strata. The only way to justify these observations is to say the world was formed billions of years ago. There are still numerous living nuclides around to be detectable. The younger nuclides have long since decayed and are no longer existent in that same form. A possible creationist rebuttal to this indication is that God might have decided to create the world so that is would only create the illusion of earth having a pre-creation history. Therefore, God would not have included nuclides with short half-lives. [7] Would God therefore have just decided to insert pre-historic fossils into different levels of the earth’s strata just to give scientists something to ponder about?

To try to fill in all of these gaps, creationists are now looking toward other ideas such as Intelligent Design (ID). This theory is an option many school boards are looking at to substitute evolution. This theory states that “biological life on earth came about by the direct acts of some intelligent designer. Organisms were custom-designed for certain functions, and were put together that way from scratch.”[8] Obviously, this is a direct opposition to Charles Darwin’s theory of evolution. Intelligent Design sees different species as evidence of a common designer instead of common descent. This argument also includes that the strength of gravity and the speed of light were chosen to permit life to arise somewhere. Generally, advocates of Intelligent Design accept the earth was created about 4 billion years ago. Creationists who believe the earth is younger often borrow arguments from this theory of ID, yet forget to include that this theory supports the idea of earth being far older than 6,000 years. Either way, the earth has been proven to be much older than just a few thousand of years, therefore making it a fact.

Evolution is the most widely accepted theory of human descent throughout the world. People, including students, have the choice to either accept, or not accept facts. Why should some students be deprived of the choice to choose? Education is “the act or process of imparting or acquiring general knowledge, developing the powers of reasoning and judgment, and generally of preparing oneself or others intellectually for mature life.”[9] Mature life probably means older life, is a person expected to know one way of thinking for their entire span of adulthood? Education is about incorporating wisdom and facts.[10] Education is not about trying to incorporate religious beliefs into a state’s facility for education.

Eventually through science, we have gotten all the way from arguing whether or not humans came from nonliving objects, to where we are today: arguing whether or not humans came from a creator, or from the theory of evolution. The biggest problem is which theory to teach and how to teach this theory to generations of students to come. School systems in the USA are still trying to figure out how to approach evolution and the origin of life in a classroom setting.

This problem is further complicated because we technically do not have a separation of church and state in public schools. Every elementary student is taught to recite the pledge of allegiance first thing in the morning. While reciting this allegiance, one must deliver it in a respectful manner. I don’t say “must” meaning “should,” I mean “must”, because if not, it is a violation of Title 4 of the United States Code.[11] In many states, such as New Mexico, students recite this twice; once in English, and once more in Spanish. This allegiance is as follows:

"I pledge allegiance to the Flag of the United States of America, and to the Republic for which it stands, one Nation, under God, indivisible, with liberty and justice for all.” This causes a controversy, because of the religious reference to God. “Citing a concurring opinion in a Supreme Court decision, the 9th Circuit said, ‘The Pledge, as currently codified, is an impermissible government endorsement of religion because it sends a message to unbelievers 'that they are outsiders, not full members of the political community, and an accompanying message to adherents that they are insiders, favored members of the political community.’”[12] While this is a subtle reference to God, there is simply no place for religion in education. However, one of the first encounters with religion in education was back in 1925 with the Scopes Monkey Trial.

Back in 1925 in Tennessee, an anti-evolution law declared:

"... that it shall be unlawful for any teacher in any of the Universities, Normals and all other public schools of the State which are supported in whole or in part by the public school funds of the State, to teach any theory that denies the story of the Divine Creation of man as taught in the Bible, and to teach instead that man has descended from a lower order of animals."[13]

Everything seemed to be going fine, until one day in Dayton, Tennessee. John Scopes, a high school biology teacher, was charged with illegally teaching the theory of evolution.

The first trial was a spectacle to nearly a thousand people. William Jennings Bryan helped the prosecution, and Clarence Darrow represented John Scopes. This turned from a legal matter, into a trial deciding the difference between good and evil, or truth and ignorance. Many assumed that if science won, Christianity would go. Darrow argued that academic freedom was being violated and claimed that the legislature had shown a religious preference. It is not lawful for legislature to do that; they would be violating the separation of church and state. But, they did. Darrow also maintained that the evolutionary theory was consistent with certain interpretations of the Bible, and in an especially dramatic session he sharply questioned Bryan on the latter's literal interpretation.

“‘Do you believe Joshua made the sun stand still?” Darrow asked at one point, regarding the biblical passage that speaks of a miraculously lengthened day.

“I believe what the Bible says. I suppose you mean that the earth stood still?” Bryan replied, anticipating the standard gibe against biblical literalism under a Copernican cosmology.

Darrow feigned innocence. “I don’t know. I am talking about the Bible now.”

“I accept the Bible absolutely,” Bryan affirmed. “I believe it was inspired by the Almighty, and He may have used language that could be understood at that time instead of using language that could not be understood until Darrow was born.”

This rejoinder evoked laughter and applause from the partisan Tennessee audience, yet Darrow had struck a blow; even a biblical literalist such as Bryan recognized the need to interpret some scriptural passages. Darrow drove the point home with further questions. “If the day was lengthened by stopping either the earth or the sun, it must have been the earth?”

“Well, I should say so,” an exasperated Bryan sighed, and in so doing fell into another trap.

Darrow snapped it shut by asking, “Now, Mr. Bryan, have you ever pondered what would have happened to the earth if it had stood still?”


“You have not?” Darrow asked with mock incredulity.

Bryan fell back on faith. “No; the God I believe in could have taken care of that, Mr. Darrow.’”[14]

Darrow went on to point out the likely outcome of a situation such as that, pointing out geology and physics. This trial lasted from July 10th until July 21st. It ended with John Scopes being convicted. Though the trial in the courtroom may have ended, this struggle is continuing more than 80 years later, still threatening the definition of education as we know it.

In 1997, Portland Public Schools were sending home a form asking parents to enroll their sons in a YMCA Boy Scout program. Although this sounds innocent, atheist Nancy Powel soon read on and found “the paper disclosed the mission statement of the YMCA: to promote Christianity.” [15] She kept objecting to this until she finally reached the School Board. People did not understand the nature of her opposition. “Why are you so opposed to the Boy Scouts?" They asked. She took her time to thoroughly explain that she did not have opposition to the Boy Scouts. On the contrary,

“She supports the right of any organization to have whatever rules for admission that they want. What this mother was objecting to was the entanglement of our secular school system with religious organizations, and the schools' violation of its own guidelines. Incredibly, the school officials simply denied that either the Scouts or the YMCA were advocates for religion. The denials are doubly amazing considering that each of these organizations proudly proclaims its religious connection. For example, the Scout oath which is recited at every meeting starts, ‘On my honor, I will do my best to do my duty to God and my country…’” After diligent research she found that, “both the national and local Parent Teachers Associations support her position. In fact, the PTA claims that every school official has been mailed official PTA guidelines mentioning that the PTA discourages any entanglement of public schools with the Boy Scouts. Not one person in the school system's chain of command had ever mentioned that fact.” [16]

It all starts with a simple Boy Scouts program, the next thing you know students are going home and reporting to his/her parents that humanity all came from the theory Intelligent Design (ID), from a common creator.

In January of 2001, the Ohio Board of Education received a letter from Dr. Jonathon Wells wanting to incorporate Intelligent Design into the curriculum. A year later, in the early part of 2002 the Ohio State Board of Education held some public hearings to determine if Intelligent Design should be taught in schools in addition to evolution. Dr. Jonathan Wells spoke in favor of Intelligent Design, and Christian biologist Dr. Kenneth Miller of Brown University spoke against including Intelligent Design in the curriculum. This ended on February 10th with a modified curriculum promoting “academic freedom” by a vote of 13-5. [17] Although is it really academic freedom? “The lesson professes to encourage students to “‘critically examine’” evidences for and against evolution and invites them to examine and discuss definitions of some common evolutionary terms and concepts.”[18]

Since students have no say in their public education’s curriculum, the National Center for Science Education (NCSE) was founded in 1983 to improve public understanding of evolution, and help keep the education of evolution “safe” from sectarian attacks. Four years later the Supreme Court demolished a Louisiana anti-evolution law in the court case titled Edwards vs. Aguillard.[19] The anti-evolution law required to have both creationism and evolution taught. “This 7-2 decision ended any prospect of public schools in the United States being legally forced to teach explicate creationism. One consequence of this case was that some antievolutionists choose to use the term “‘intelligent design’” instead of “‘creationism’.” [20]

Many people thought this meant the long lasting debate between creation and evolution had been put to an end. “Instead, it returned to the local level, where new strategies appeared in countless communities; eventually, the problem re-appeared at the state level as well. More and more parents, teachers, and citizens are looking for guidance in coping with the evolution/creation controversy in their communities.”[21]Now creationists are developing new strategies to incorporate “creation science” into the public school curriculum.

One strategy is introducing evolution with an emphasis on “theory” instead of fact. These proposals use the ordinary definition of "theory" as "hunch," or "guess," claiming that evolution is "only a theory.”[22] This strategy has been proposed repeatedly and is still being proposed. However, this would need another discussion which determines what constitutes a scientific theory. By understanding the terms each side is being categorized under, students would better understand the controversy and the issue. The California State Board of Education Policy on the Teaching of Natural Sciences quotes this good, concise definition from the 1986 edition of the Hammond Barnhart Dictionary of Science: "Theory... an explanation or model based on observation, experimentation, and reasoning, especially one that has been tested and confirmed as a general principle helping to explain and predict natural phenomena...."[23] Theories help explain observable facts of nature by experiments. Many religious Christians use this definition as a way to fall back on the approach that evolution does not concern them because of evolution now can be classified as ‘just a theory.’ While evolution and creationism are built off of completely opposite bases, they both share faith. Because nobody has ever seen a reptile turn into a bird, there is a faith in scientific explanation that this has indeed happened. This leads to questioning what is in fact, a fact?

“Since many Christians have concluded that evolution is incompatible with the Biblical account of creation, we would do well to investigate if evolution is a fact or a theory -- or perhaps neither… Evolutionists recognize two types of evolution -- micro evolution, which is observable, and macro evolution, which isn't. The very name "micro evolution" is intended to imply that it is this kind of variation that accumulates to produce macro evolution though a growing number of evolutionists admit there is no evidence for this. Thus an observable phenomenon is extrapolated into an unobservable phenomenon for which there is no evidence, and then the latter is declared to be a "fact" on the strength of the former. It is this kind of limitless extrapolation that comprises much of the argument for evolution…Evolution is not observable, repeatable, or refutable and thus does not qualify as either a scientific fact or theory. Evolution must be accepted with faith by its believers, many of whom deny the existence, or at least the power, of the Creator. Similarly, the Biblical account of creation is not observable, repeatable or refutable by man. Special creation is accepted with faith by those who believe that the Bible is the revelation of an omnipotent and omniscient Creator whose Word is more reliable than the speculations of men.”[24]

Just as this analyst said, many scientists find this debate to be controversial because there are misunderstandings on the definitions of the terms they are using. How is it, that out of all the dictionaries on the planet, the only country that can’t seem to agree on one definition is the United States?

Is it not odd that the United States of America is the only country with this debate having such a huge impact on current students and, therefore, on future generations of students to come? The U.S.A needs to start becoming more religiously tolerant. To start, we would first need a president who understands the meaning of the first amendment Establishment Clause of the US constitution. Every president since George Washington, excluding Thomas Jefferson has, in fact, been Christian. Thomas Jefferson was a deist but followed the moral teachings of Jesus. While all these presidents were aware of the wide variety of different religions, it wasn’t until 1802 that the phrase “separation of Church and State” became synonymous with the first amendment Establishment Clause: "Congress shall make no law respecting an establishment of religion.”[25] The meaning of this Establishment Clause continues to be debated. Being from the constitution, certain laws can now be declared unconstitutional. If its meaning is interpreted differently, then there would be problems for later decisions regarding religious freedom. The majority opinion of the Supreme Court outlined a test for deciding when a law violates this clause. This test is called the “Lemon Test… According to the decision, a law involving religion is constitutional if it has a secular (non-religious) purpose, is neutral toward religion (neither for nor against it), and does not result in "excessive entanglements" between government and religion.”[26] This doesn’t seem to be working out in modern day America.

Here we are in the year 2008, with a president who enforces Christian views on the entire country. The Establishment Clause was very specific about “excessive entanglements,” yet the President of the United States has spent billions of dollars funding faith-based private schools and organizations. Many support his funding plan, especially the groups who benefit from it.

“Administration officials say that faith-based groups are often less expensive and more effective in helping the needy, a contention that traditional service providers challenge. “‘By any account, the administration's initiative has made it easier for a broader range of faith-based programs to apply for federal funds, and we appreciate that,’” said Douglas Rice, director of housing and community development policy for Catholic Charities USA, whose local affiliates have benefited from the shift.”[27]

While these organizations are benefiting, the funding is supported by the tax payers’ money, and by the decision to cut down on expenses going to secular anti-poverty programs.

Three years ago, President George W. Bushsigned legislation to further fund “faith based” groups, including religious based private schools, while cutting down on funding secular anti-poverty programs, and using the tax-payers’ money.[28]

“Bush's budget proposal for next year [2007] contemplates adding $385 million in new religion-based programs to this year's eventual total. The federal government awarded more than $2 billion in such grants in 2004 -- nearly double the amount awarded in 2003. Funding under the president's faith- and community-based initiative has gone up despite Congress's refusal to enact legislation that would allow faith-based groups to discriminate by religion when hiring staff, something Bush says should be allowed as long as they offer their services to people of all faiths and do not use federal money to proselytize…Bush's faith-based initiative also privileges Christianity above all other religions. After sifting through every grant announcement I could get my hands on from Bush's faith-based offices, I couldn't find a single grant issued to a religious charity that wasn't Christian -- no Jewish charities, no Muslim charities, nothing. And when I spoke with Jim Towey, director of the White House Office of Faith-Based and Community Initiatives, he confirmed that no direct federal grants from his program had gone to a non-Christian religious group.”[29]

The founding fathers would be very disappointed. There is more than one creation story, yet many educators think only one should be taught. The president is aware of varying religions, yet thinks only Christian affiliated private schools deserve funding. Quite unconstitutional, considering the US is supposed to be neutral toward religion.

If biblical creationists get to have an impact on what students are learning, what about the creation stories of Indians, Japanese, Africans, Hawaiians, and the tribes of Native Americans? There are thousands of religious creation stories. In New Mexico alone, the three greatest groups are Hispanics, Native-Americans and Puritan-rooted Caucasian people. Each of these groups has their own creation story, yet the one that is taught in these creationist schools is that of the Puritan-rooted Caucasian people. By only teaching biblical creationism, we are still allowing Christianity to dominate all the other creation stories. Taking religion out of education would be very difficult. There are so many religions in the country it would be impossible to take each aspectof religion out. The solution is to incorporate an all inclusive origins class into the curriculum, along with a science class which includes evolution. The all inclusive origins class would cover the creation stories of not just one religion, but of religions from all around the world. By still including evolution, the students will get the idea of creation from a scientific perspective as well.

The debate between evolution and creation has, over time, transformed into a debate between church and state. There will continue to be heated discussions on whether or not to include the arguments of evolution, or Intelligent Design. But without including both theories, teachers would be hindering the students’ right to decide and choose for themselves what they want to believe in. The violation of the first amendment clause turns education into nothing more than selective teaching.

Works Consulted

25 Abboud, Alexandra . "Separation of Church and State in the U.S." Telling America's Story. USINFO. (13 April 2008).

26Abboud, Alexandra . "Separation of Church and State in the U.S." Telling America's Story. USINFO. (13 April 2008

2 All About Science - Knowledge and Discovery. The Origin of Life: Spontaneous

Generation. (4 February 2008).

4Carver, Liz . Where We Came From . PBS. (4 February 2008).

19 Dorman, Clark. "Edwards v. Aguillard U.S. Supreme Court Decision." The TalkOrigins Archive. (8 April 2008).

14 Drews, Carl. Some Objections to Intelligent Design. Jambo Productions Inc.

http://www.theistic- (8 March 2008).

27 Fletcher, Michael A. "Two Fronts in the War on Poverty." The Washington Post. The Washington Post Company. (14 April 2008).

[1] Frankhauser, D. B., and J. S. Carter. Spontaneous Generation. Celermont College. (4 February 2008).

21 Matsumura, Molleen . Facing Challenges to Evolution Education. National Center for Science Education.

22 Matsumura, Molleen . Facing Challenges to Evolution Education. National Center for Science Education.

3 McMullen, Emerson T. Coelacanths and Other Living Fossils: No Change Over Time . (4 February 2008).

24 Menton, David N. Is Evolution a Theory, a Fact, or a Law?. Missouri Association for Creation. (10 March 2008).

7 “Powell, Nancy. Religion and Boy Scouts in Portland Public Schools,” Politics of


8 Powell, Nancy. Religion and Boy Scouts in Portland Public Schools,” Politics of


11 Robinson, B A. Indicators of an . Ontario Consultants on Religious Tolerance. (8 March 2008).

6 Robinson, B A. Indicators of an . Ontario Consultants on Religious Tolerance. (8 March 2008).

15 Schafersman, Steven. OHIO ANTI-EVOLUTION MODEL CURRICULUM CONTROVERSY. Texas Citizens for Science. (8 March 2008).

17Schafersman, Steven. OHIO ANTI-EVOLUTION MODEL CURRICULUM CONTROVERSY. Texas Citizens for Science. (8 March 2008).

18 Schafersman, Steven. OHIO ANTI-EVOLUTION MODEL CURRICULUM CONTROVERSY. Texas Citizens for Science. (8 March 2008).

5 U.S. Code, “Title 4—Flag and Seal, Seat of Government, and the States,” Chapter 1-

The Flag,

28 Wilson, Bruce. $500 Million for federal "bigotry based" initiative ?. scoop. (13 April 2008).

[1] J Richard, ""no hats in class rule" -why?." ProTeacher Community . (4 March 2008).

[2] D B Frankhauser and J. S. Carter, Spontaneous Generation. Celermont College. (4 February 2008).

[3] All About Science - Knowledge and Discovery. The Origin of Life: Spontaneous Generation. (4 February 2008).

[4] Emmerson T McMullen, Coelacanths and Other Living Fossils: No Change Over Time . (4 February 2008).

[5] Liz Carver, Where We Came From . PBS. (4 February 2008).

[6] B A Robinson, Indicators of an . Ontario Consultants on Religious Tolerance. (8 March 2008).

[7] B A Robinson, Indicators of an . Ontario Consultants on Religious Tolerance. (8 March 2008).

[8] Carl Drews, Some Objections to Intelligent Design. Jambo Productions Inc. (8 March 2008).

[9] The American Heritage® Dictionary of the English Language, Fourth Edition Copyright © 2000 by Houghton Mifflin Company. Published by Houghton Mifflin Company. All rights reserved.

[10] Carl Drews, Some Objections to Intelligent Design. Jambo Productions Inc. (8 March 2008).

[11] U.S. Code, “Title 4—Flag and Seal, Seat of Government, and the States,” Chapter 1-The Flag,

[12] “Lawmakers Blast Pledge Ruling,” CNN Law Center, (accessed January 22, 2008).

[13] Douglass Linder, Tennesse Evolution Statute. (10 February 2008).

[14] Edward J. Larson, Summer for the Gods. New York: Basic Books, A Member of the Perseus Books Group, 1997.

[15] “Nancy Powell, Religion and Boy Scouts in Portland Public Schools,” Politics of Religion,

[16] Nancy Powell, Religion and Boy Scouts in Portland Public Schools,” Politics of Religion,

[17] Steven Schafersman, OHIO ANTI-EVOLUTION MODEL CURRICULUM CONTROVERSY. Texas Citizens for Science. (8 March 2008).

[18] Steven Schafersman, OHIO ANTI-EVOLUTION MODEL CURRICULUM CONTROVERSY. Texas Citizens for Science. (8 March 2008).

[19] Clark Dorman, "Edwards v. Aguillard U.S. Supreme Court Decision." The TalkOrigins Archive. (8 April 2008).

[20] Ibid.

[21] Molleen Matsumura, Facing Challenges to Evolution Education. National Center for Science Education.

[22] Molleen Matsumura, Facing Challenges to Evolution Education. National Center for Science Education.

[23] Ibid.

[24] David N. Menton, Is Evolution a Theory, a Fact, or a Law?. Missouri Association for Creation. (10 March 2008).

[25] Alexandra Abboud, "Separation of Church and State in the U.S." Telling America's Story. USINFO. (13 April 2008).

[26] Alexandra Abboud, "Separation of Church and State in the U.S." Telling America's Story. USINFO. (13 April 2008

[27] Michael A. Fletcher, "Two Fronts in the War on Poverty." The Washington Post. The Washington Post Company. (14 April 2008).

[28] Bruce Wilson, $500 Million for federal "bigotry based" initiative ?. scoop. (13 April 2008).

[29] Ibid.


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