After a series of stinging defeats in the U.S. courts, one branch of biblical creationism mutated into a neocreationist movement known as intelligent design (ID) in the late 1980s. The selective pressure that led to this evolution was a single line in the 1987 Edwards decision by Supreme Court Justice William Brennan that emphasized differing views of human origins might be permissible in public schools if they were driven by “secular intent.” This led some creationists to strip the religious language and present their ideas as purely scientific. No serious person was fooled by this game of rhetorical dress-up, least of all a George W. Bush–appointed federal judge who ruled that ID is not scientific and cannot be divorced from its religious motivations ( Jones 2005). (For a history of the modern ID movement, see Barbara Forrest and Paul R. Gross’s 2007 book, Creationism’s Trojan Horse: The Wedge of Intelligent Design.)