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Trying BiologyThe Scopes Trial, Textbooks, and the Antievolution Movement in American Schools$

Adam R. Shapiro

Print publication date: 2013

Print ISBN-13: 9780226029450

Published to Chicago Scholarship Online: September 2013

DOI: 10.7208/chicago/9780226029597.001.0001

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Losing the Word: Measuring the Impact of Scopes

Losing the Word: Measuring the Impact of Scopes

Chapter:
(p.157) Chapter Eight Losing the Word: Measuring the Impact of Scopes
Source:
Trying Biology
Author(s):

Adam R. Shapiro

Publisher:
University of Chicago Press
DOI:10.7208/chicago/9780226029597.003.0069

Abstract and Keywords

This chapter explains that the actual impact of the Scopes trial and the antievolution movement on textbooks can be understood in terms of how textbooks were taught and interpreted. Evolutionary theories of mind were an important part of the intellectual framework that led to the creation of the curriculum of civic biology, and that model of educational psychology spoke directly to how students thought, read, and learned. The Civic Biology was never concerned with the teaching of the evolutionary development of life as just an intellectual curiosity. Evolution, like other important concepts of biology, were brought into science education as part of the new understanding of schooling as a form of social development.

Keywords:   antievolution, civic biology, scopes trial, textbooks, biology, social development

The debate over what effects the Scopes trial had on biology textbooks is long-standing. To some extent, that debate began even before the trial itself as newspapers reported that textbook publishers were feeling pressured by the upcoming court case (a claim textbook editors denied).1 Starting with studies in the 1970s, there have been attempts to quantify the contents of textbooks and to draw inferences about the impact of the Scopes trial from these assessments. In 1974, Judith V. Grabiner and Peter D. Miller concluded: “The teaching content of evolution in the high schools–as judged by the content of the average high school biology textbooks–declined after the Scopes trial.”2 Gerald Skoog followed this up in 1979 by observing that, in the early 1920s, “authors discussed evolution openly and attested to its validity” but that, “after 1925, statements of this nature were infrequent until the 1960s.”3

Both these studies have been very influential, not just for understanding the history of biology textbooks, but in shaping interpretations of the Scopes trial’s importance. They have also had an impact on recent debates over the teaching of evolution as other scholars have drawn on their methods (with refinements) to evaluate the content of more recent biology textbooks. Later studies have debated whether the best way to measure the evolutionary content of a textbook is “to measure the percentage of a text devoted to evolution” or to conduct a “simple, numerical word count” of evolutionary keywords.4 These quantitative techniques may have improved on Grabiner and Miller’s original study, which was more anecdotal and directly compared specific books like Hunter’s Civic Biology and New Civic Biology. But (p.158) the newer studies did not question the primary assumption that the Scopes trial was responsible for apparent changes between the early and the late 1920s. Even in the twenty-first century, there is debate over the extent of textbook differences, but no questioning the premise that such changes were caused by the Scopes trial. These studies have presupposed that the effects of the trial can be seen in the textbooks’ content, with little attention paid to how these books were actually sold, used, and read.

Shortly after Grabiner and Miller’s article was published, the paleontologist George Gaylord Simpson wrote that their study was “an instance of mistaking effect for cause.”5 In fact, both the causes and the effects require more careful attention. The antievolution movement was already affecting textbooks before the Scopes trial. Charles Thurber’s consultation with William Jennings Bryan took place well before the Tennessee law was passed. Peabody and Hunt’s textbook, which claimed not to teach evolution, was adopted in Tennessee a month before the Scopes trial began. George Hunter had even been working on a new edition of the Civic Biology before the trial. The changes made to Hunter’s book reflect both the influence of the trial itself and the success of strategies that had their beginnings before the trial. It is a better and more meaningful question to ask about the impact of the antievolution movement on textbooks, rather than isolating the Scopes trial as the sole cause. One must not lose sight of biology textbooks’ impact on the antievolution movement and see them merely as affected by the controversies. Influence goes both ways.

But there are no easy answers to even this improved question. Many of the textbooks published either shortly before or years after the trial avoided the use of the word evolution. By a word-counting measure, these books might be considered to have removed or diminished their discussion of the topic. But many of them replaced the word with an equivalent term or phrase and retained much of the same biological content. A more thematic measure of evolution that includes other keywords might show less of a decrease.

But neither of these criteria measures how these textbooks were marketed and read. Historians of publishing have long criticized the idea that a book can control the way in which readers engage it. In the case of text-books–whose authority is reinforced by a system of state regulation and publisher marketing–there is a greater sense that readers (students) can have texts’ meanings prescribed for them, though the books themselves do not do so.6 Tennessee’s adoption of the New Civic Biology while evolution was prohibited, reinforced by salesmen-procured endorsements stating that (p.159) the book did not contain evolution, meant that most people in Tennessee thought that the book was nonevolutionary. But the New Civic Biology could have been interpreted as teaching evolution, and in states where it was less problematic to do so it likely was.

More than the number of evolutionary keywords, the actual influence the Scopes trial and the antievolution movement had on textbooks can be best understood in terms of how those textbooks were taught and interpreted. Evolutionary theories of mind were a key part of the intellectual framework that had led to the curriculum of civic biology, and that model of educational psychology spoke directly to how students thought, read, and learned. The Civic Biology was never concerned with the teaching of the evolutionary development of life as just an intellectual curiosity. Evolution and other key concepts of biology were brought into science education as part of the new understanding of schooling as a form of social development. Scientific concepts could be applied to an urbanizing and modernizing life. This view of education extended to changing the way young minds interacted with textbooks. Students were being taught to think inductively and to eschew the rote presentation of facts. Back in 1916, John Dewey lamented the “isolation of science from significant experience”: “The pupil learns symbols without the key to their meaning.”7 The most important sense in which biology (and other) textbooks were evolutionary was in their pedagogical commitment to the development of student minds, teaching them to connect symbols to their deeper meanings through the relationship of scientific theories to real-world experiences.

These post-Scopes biology textbooks, presented in a context in which certain readings were prescribed, lost sight of this evolutionary aim of education. Reading a book that taught the heredity and development of species without using the word evolution and being compelled to interpret these books as not teaching anything that the antievolution law prohibited encouraged a reading that relied on literal interpretation. This was a return to rote: an education that denied student abstraction that might have led to interpretations of the books as evolutionary. This form of pedagogy wholly undermined the grandest ambitions of civic biology and the reform of science education of the first two decades of the twentieth century: to apply the principles of the evolution of the child mind to bring about social progress.

By the late 1920s, evolutionary theories of mind were beginning to lose influence among American psychologists.8 Perhaps this helps explain why there was not a greater outcry. The change in textbook reading practices was obscured by the more superficial ways in which biology textbooks lost (p.160) evolution. But the idea that those textbooks’ coverage of evolution disappeared in the late 1920s helped pave the way for a story about its resurrection in the 1960s.

The Ruin and Restoration of Evolution

Regardless of how the concept is measured, evolution never really disappeared from biology textbooks. In his criticism of Grabiner and Miller, Simpson pointed out that textbooks by Ella Thea Smith published in the 1930s and 1940s did discuss evolution.9 There was also Alfred Kinsey’s text-book, whose sales were not as bad as Grabiner and Miller alleged.10 Nonetheless, the prevailing story of evolution in American schools is that it disappeared after 1925 and remained absent until the 1960s.11

Ronald P. Ladoucer has argued that this narrative is largely a “myth, created first as part of a public relations effort by the Biological Science Curriculum Study (BSCS) to differentiate, defend, and promote its work, and later as part of an attempt by scholars to sound a warning concerning the rise of the religious right.”12 Funded by a National Science Foundation grant in 1958, the BSCS was one of several initiatives meant to “transform” science education in the United States after World War II.13 These initiatives proceeded in ways similar to those of the early twentieth century, when the National Education Association committees had studied and suggested education reform–including the development of science education tied to real-world experiences like civic biology and the incorporation of the evolutionary pedagogy emerging from thinking like Herbert Spencer’s, G. Stanley Hall’s, and John Dewey’s. John L. Rudolph has shown that, despite the popular conception that this reform of science education was a response to the Soviet launch of the first man-made satellite in 1957, many of the initiatives had begun months or years before America’s first “Sputnik moment.”14 The BSCS resulted in the development of new biology curricula and new textbooks whose incorporation into American high schools was hailed as part of a new era in American science education. Along with similar programs in other sciences, it represented a greater level of federal involvement in science education than previously seen in the United States. BSCS supporters also invoked the specter of the Cold War to emphasize the role of science education in recruiting and training scientists who would allow the United States to compete with the Soviet Union. This represented a major shift in the aims of science education. In the era of civic biology, science educators were concerned less with producing new scientists than (p.161) with instilling a scientific ethos in all students, future scientists and nonscientists alike.15

Public attention to the teaching of evolution in the United States intensified in the late 1950s and early 1960s. The popularity of the 1955 play Inherit the Wind and the subsequent 1960 film, which presented a fictionalized account of the Scopes trial, reinforced many of the mythic distortions of what happened in Dayton.16 The year 1959 was also the centenary of the publication of the Origin of Species, and the conferences and public events commemorating the impact of Darwin and his thought also resulted in renewed popular discussion of Darwinism.17 These popularizing effects coincided with the pedagogical efforts of the BSCS.

Ironically, one of the people most responsible for the BSCS-era popularization of the idea that evolution disappeared was George Gaylord Simpson. In 1960, he wrote an influential article, “One Hundred Years without Darwin Are Enough,” in which he argued that American high schools were not in fact teaching evolution. But he claimed that it was not antievolution laws that were responsible for this. “Laws against evolution are still nominally in effect,” he noted. But they were not really enforced. Antievolutionism had won out largely because teachers and textbooks avoided the subject. Fear of controversy, not of the laws themselves, had led teachers and textbook publishers into self-censorship.18

This changed with the advent of the BSCS textbooks (first published in 1963) and other biology textbooks whose publishers rushed to copy their techniques. The BSCS textbooks emphatically presented evolution and reawakened the legal and political attention to antievolutionism.19 In 1965, Arkansas (which in 1928 had passed an antievolution law prohibiting both the teaching of evolution and the use of textbooks containing evolution) adopted a biology textbook that taught evolution. This led to a test case similar to Scopes. Rather than be prosecuted for criminal violation of the antievolution law, the Arkansas schoolteacher Susan Epperson preemptively sued the state for putting her in an impossible position, one that violated her due process rights. (If she did not teach the textbook, she would violate the law requiring teachers to use adopted texts; but, if she did use the text-book, she would violate the antievolution law.)20

Previously, in 1947, in another case concerning the rights of states to control their schools, the U.S. Supreme Court had ruled that the First Amendment prohibition against the establishment of religion applied to the states as well as to the federal government.21 On the basis of this precedent, the Court ruled in Susan Epperson’s favor and declared that state prohibitions (p.162) of the teaching of evolution were unconstitutional. Perhaps anticipating this, the state of Tennessee repealed its antievolution law in 1967, a year before Epperson v. Arkansas was decided.

Reaction to the Epperson ruling helped popularize an effort by antievolutionists to verify their creationist conclusions under the rubric of “science.” As Ronald L. Numbers points out, “the transmogrification of creationism from religion to science took place in direct response to” textbook adoption controversies in California in the early 1970s, “which encouraged creationists to believe that they could squeeze into science classrooms simply by shedding superfluous biblical weight.”22 “Creation science” or “scientific creationism” continued a paradigm of “science and religion” that came into view during the Scopes trial, which saw the definitions of both religion and science subject to debate. Though the Scopes debate centered more on whether ideas such as biblical literalism and theistic evolution could count as religion, the post-Epperson reaction of antievolutionists was to argue that their version of creation could count as science.

The antievolutionism of creationists and creation science proponents was very different from the antievolutionism of the 1920s. Unlike Bryan, they espoused the young age of the earth and insisted on the occurrence of a worldwide flood to account for observations such as those of fossils layered in various geological strata. These young earth creationists held views more similar to Darrow’s caricature of Bryan than to those of most antievolutionists of the Scopes era.23 The version of creation that their “science” was designed to confirm was the literal interpretation of Genesis.

After Epperson, opponents of evolution proposed laws that required giving “balanced treatment” to evolution and creation science. It is debatable whether this was done to actually promote creation science or more simply to revive antievolution laws by other means (by discouraging evolutionists from teaching evolution so that they would not have to teach creation science). But the legal fight that emerged over these laws once again focused on redefining science and religion. The 1981 federal trial McLean v. Arkansas Board of Education ruled that Arkansas’s newly enacted balanced-treatment law was unconstitutional because it represented an establishment of religion. The court effectively determined that creation science was religious in large part because it was not scientific. This legal reasoning enshrined as precedent the notion that science and religion were in opposition and mutually exclusive–a view of conflict that the Scopes trial helped make prevalent. This legal precedent has also led subsequent antievolutionary theories or evolution “alternatives” to be subjected to a de facto test of whether they (p.163) merit inclusion in the category science.24 The legal and political debate over evolution continues to rely on the science and religion legacy of the Scopes trial. It also relies on the trial’s perceived legacy to textbooks.

Scopes Myths as Precedents

The idea that evolution in biology textbooks “declined” after 1925 has been central to ongoing legal debates over the teaching of evolution and its “alternatives,” “criticisms,” or “strengths and weaknesses.” This mutually reinforcing connection between the effects of the Scopes trial and biology education came to a head in 2005 with the verdict of the Kitzmiller et al. v. Dover Area School District trial in Pennsylvania. A school district that encouraged the study of “intelligent design” (ID) was sued by the parents of some high school students. Judge John E. Jones III’s ruling that ID was not a scientific theory and could not be taught in public schools drew largely on the fact that there was a historical pedigree connecting ID to other forms of creationism and, through that, to earlier forms of religious antievolutionism.25 That historical lineage was established in large part by an examination of the ID textbook recommended by the Dover school district, entitled Of Pandas and People.26 The early drafts of this textbook had been written prior to a 1987 Supreme Court ruling that upheld the opinion in the McLean case declaring unconstitutional the teaching of creationism or creation science in public schools. In the Dover trial, the court found that “cognates of the word creation (creationism and creationist), which appeared approximately 150 times [before 1987] were deliberately and systematically replaced with the phrase ID.”27 The editors of Pandas had drawn on the same strategy as those post-Scopes biology textbooks that had replaced only the word evolution.

Rejecting the argument that the “intelligent design” taught in Pandas was not creationism, Judge Jones proved himself to be a different kind of text reader than the 1931 Tennessee state textbook commission. He reasoned that the interpretation of the text put forward by its publishers was not consistent with how students would actually read. Students would interpret the book as having a religious meaning despite the absence of the explicitly religious term creation because they would be familiar with the religious pedigree of antievolution movements.

Opponents of antievolutionism characterized ID as equivalent to creationism, in part because the authors of Pandas had not changed much besides substituting the phrase intelligent design for the word creationism. They did not change the arguments or the evidence they used. Nonetheless, ID (p.164) advocates claim that intelligent design is science. They point to the fact that they make no direct statements about the truth of the Bible as proof that what they are doing is not religion.28 This sense of religion as Bible-oriented comes directly from the understanding of science and religion that emerged in Dayton. Bryan’s rejection of theistic evolution as a religious position aligned antievolutionism with views of religion that were more connected to the Bible and to revelation than to philosophical or natural religion. While Bryan did not claim that evolution was against the Bible because it contradicted the literal interpretation of Genesis, he did claim that the irreligious nature of evolution undermined belief in the truth of the Bible. ID advocates invoke the fact that they are not biblical literalists to support their claim that ID is not religion and make tacit use of the logic that, if it is not religion, it may be science.

In Dover, a member of the school board read students a prepared statement (after the school’s biology teachers refused to do so) encouraging them “to keep an open mind.” That statement also referred to Of Pandas and People as a “reference book.” This is another example of how school regulators attempt to shape the perceived authority of textbooks, the classroom, and course content. The reminder that “Pennsylvania Academic Standards require students to learn about Darwin’s Theory of Evolution and eventually to take a standardized test of which evolution is a part” shows the local school board attempting to undermine the authority of the state in dictating education content.29 That is, the implication that evolution is taught only because of the standardized test encourages students to learn no more about the subject than is necessary to conform to the law, to study it in as rote a fashion as possible. Although the language of open-mindedness suggests that the school board encouraged critical evaluation, the rest of the language suggests the greater credibility of intelligent design (described as an “explanation” rather than as a “theory…not a fact,” like evolution is).30

This statement in Dover was one of several examples in recent decades where state and local authorities have tried to dictate modes of reading and interpreting biology textbooks that undermine their evolutionary content. Several jurisdictions have required stickers to be placed in the front of their biology textbooks containing warnings about the books’ evolutionary content. While the language employed has varied somewhat from place to place, the stickers frequently invoke rhetoric that goes back to William Jennings Bryan’s distinction that evolution is a “theory, not a fact.” In these cases, as with the statement read aloud to Dover, Pennsylvania, students, the structure of textbook adoption and regulation was not embellishing the (p.165) authority of the textbooks being presented to students but systematically undermining it by presenting a competing authority.31 The battle of science and religion became a battle of Pennsylvania versus Dover or Alabama versus previous federal court decisions.32 Shortly after the Kitzmiller verdict, a federal appeals court upheld a district court ruling that the insertion of stickers like these in biology textbooks in Cobb County, Georgia, was unconstitutional.33

The legacy of the Scopes trial and its influence on current debates is a complex one that should not leave any party satisfied. Textbook reading and use has been stripped of some of the inductive, nonrote learning that evolutionary educators like John Dewey, George W. Hunter, and Otis Caldwell thought were the most important improvements to science education. But, if widespread acceptance of a less inductive engagement with text represents a loss for evolutionists, it is at best a pyrrhic victory for the antievolutionist. The kinds of antievolutionism that have become so widespread are often rooted in the literal interpretation of the Bible that early Fundamentalists had disavowed. In the legal demand that alternatives and criticisms of evolution be fit into the rubric of science, religious antievolutionists have ceded the discussion of their reading practices to their own “scientific” standard bearers. The most prominent spokesmen for ID are those who identify themselves as scientists. This makes it impossible for antievolutionists to engage in fruitful discussion of the religious implications of their various theories. Antievolutionary alternatives are judged, not on their intellectual merits or theological virtues, but on their ability to pass as “science.”

Antievolutionism as “scientific” was emphasized by a 2012 Tennessee law declaring “teachers shall be permitted to help students understand…the scientific strengths and scientific weaknesses of existing scientific theories covered in the course being taught.” Critics panned this as a “money bill.”34

These are consequences of a kind of thinking about science and religion that has changed little since the Scopes trial. The trial’s participants ignored the specific contexts in which their debate emerged and redefined the nature of both science education and antievolutionism. In nearly all the antievolution cases brought to trial in America since 1925, the issues of who controls the schools, what textbooks are used there, how they are read, and on whose authority they are understood have been submerged in a narrative of essential conflict. Participants in these cases, assuming the birthright of the Scopes trial, return to the trope science and religion. In doing so, they present their cause as something unchangeable–like a dogma–as if they meant the warfare of it to outlive them. (p.166)

Notes:

(1) . “Monkey Talk Hits Book Publisher,” Chattanooga Times, June 5, 1925, 1.

(2) . Grabiner Judith V. and Miller Peter D., “Effects of the Scopes Trial: Was It a Victory for Evolutionists?” Science 185 (1974): 832.

(3) . Skoog Gerald, “Topic of Evolution in Secondary School Biology Textbooks, 1900–1977,” Science Education 63, no. 5 (1979): 628.

(4) . Moody David E., “Evolution and the Textbook Structure of Biology,” Science Education 80, no. 4 (December 1998): 396. See also Dorothy B. Rosenthal, “Evolution in High School Biology Textbooks: 1963–1983,” Science Education 69, no. 5 (October 1985): 637–48; Skoog Gerald, “The Coverage of Evolution in High School Biology Textbooks Published in the 1980s,” Science Education 68, no. 2 (April 1985): 117–28.

(5) . Simpson George Gaylord, “Evolution and Education,” Science 187, no. 4175 (February 7, 1975): 389–90.

(6) . Shapiro Adam R., “Between Training and Popularization: Regulating Science Textbooks in Secondary Education,” Isis 103, no. 1 (March 2012): 99–110.

(7) . Dewey John, Democracy and Education (New York: Macmillan, 1916), 257.

(8) . Richards Robert J., Darwin and the Emergence of Evolutionary Theories of Mind and Behavior (Chicago: University of Chicago Press, 1987), 506–8.

(9) . Simpson, “Evolution and Education,” 389–90. See also Ladoucer Ronald P., “Ella Thea Smith and the Lost History of American High School Biology Textbooks,” Journal of the History of Biology 41, no 3 (September 2008): 436n.

(10) . Grabiner and Miller, “Effects of the Scopes Trial,” 834. This claim that Kinsey’s and Smith’s books “either sold poorly or became extinct” is repeated in Moore Randy, “The Lingering Impact of the Scopes Trial on High School Biology Textbooks,” BioScience 51, no. 9 (2001): 792. For a more complete (and positive) assessment of Kinsey’s textbook sales, see Drucker Donna J., “Creating the Kinsey Reports: Intellectual and Methodological Influences on Alfred Kinsey’s Sex Research, 1919–1953” (Ph.D. diss., Indiana University, 2008), 44.

(11) . Skoog, “Topic of Evolution in Secondary School Biology Textbooks,” 622; Grabiner and Miller, “Effects of the Scopes Trial,” 836.

(12) . Ladoucer, “Ella Thea Smith and the Lost History of American High School Biology Textbooks,” 435.

(13) . Grobman Arnold B., The Changing Classroom: The Role of the Biological Science Curriculum Study (Garden City, NY: Doubleday, 1969), 10; Rudolph John L., Scientists in the Classroom: The Cold War Reconstruction of American Science Education (New York: Palgrave Macmillan, 2002), 137–64.

(14) . Rudolph, Scientists in the Classroom, 34–101.

(15) . Shapiro, “Between Training and Popularization,” 102–4.

(16) . Wertheim Albert, “The McCarthy Era and American Theatre,” Theatre Journal 34, no. 2 (May 1982): 221–22; Clark Constance Areson, “Evolution for John Doe: Pictures, the Public, and the Scopes Trial Debate,” Journal of American History 87, no. 4 (March 2001): 1277; Randy (p.187) Moore, “Creationism in the United States: VII, The Lingering Impact of ’Inherit the Wind,’” American Biology Teacher 61, no. 4 (April 1999): 246; Larson Edward J., Summer for the Gods: The Scopes Trial and America’s Continuing Debate over Science and Religion (Cambridge, MA: Harvard University Press, 1997), 238–44.

(17) . Smocovitis Vassiliki Betty, “The 1959 Darwin Centennial Celebration in America,” Osiris, 2nd ser., 14 (1999): 274–323. For an example of how discussion of Darwinism increased around 1960, see also the Google Ngram at http://ngrams.googlelabs.com/graph?content=darwinism&year_start=1800&year_end=2000&corpus=0&smoothing=1] (accessed February 3, 2011).

(18) . Simpson George Gaylord, “One Hundred Years without Darwin Are Enough,” Teachers College Record 60 (1961): 617–626. Simpson credited the geneticist H. J. Mueller with the phrase that gave the article its title.

(19) . Numbers Ronald L., The Creationists, expanded ed. (Cambridge, MA: Harvard University Press, 2003), 265.

(20) . Epperson v. Arkansas, 393 U.S. 97 (1968).

(21) . Everson v. Board of Education, 330 U.S. 1 (1947).

(22) . Numbers, The Creationists, 271.

(23) . For more on the different varieties of creationism, see Numbers, The Creationists.

(24) . McLean v. Arkansas Board of Education, 529 F. Supp. 1255 (1982). Philosophers of science have debated whether it is correct to classify creation science as not science or as a type of science that happens to be incorrect. For an example of this debate, see Ruse Michael, “Creation Science Is Not Science,” in Philosophy of Science: The Central Issues, ed. Curd Martin and J. A. Cover (New York: Norton, 1998), 150–60; Lauden Larry, “Commentary on Ruse: Science at the Bar– Causes for Concern,” in ibid., 161–66; and Ruse Michael, “Response to Lauden’s Commentary: Pro Judice,” in ibid., 167–73.

(25) . Kitzmiller et al. v. Dover Area School District, 400 F. Supp. 2d 707 (2005).

(26) . Davis Percival and Kenyon Dean H., Of Pandas and People: The Central Question of Biological Origins (1989), 2nd ed. (Dallas: Haughton, 1993).

(27) . Kitzmiller et al. v. Dover Area School District, 400 F. Supp. 2d 707 (2005), 32.

(28) . Ibid.

(29) . Ibid., 39.

(30) . Ibid., 40, 41.

(31) . Shapiro, “Between Training and Popularization,” 109.

(32) . Numbers Ronald L., Darwinism Comes to America (Cambridge, MA: Harvard University Press, 1998), 9–10.

(33) . Selman v. Cobb County School Dist., 390 F. Supp. 2d 1286 (2005); Selman v. Cobb County School Dist., 449 F.3d 1320 (2006).

(34) . “Senate Bill 893,” http://www.tn.gov/Bills/107/Bill/SB0893.pdf (accessed January 9, 2013). For “monkey bill,” see, for example, “Tennessee ’monkey bill’ becomes law,” Nature, April 11, 2012. http://www.nature.com/news/tennessee-monkey-bill-becomes-law-1.10423 (accessed January 9, 2013). Unlike Governor Peay, who issued a statement explaining his reasons for signing the Butler Act, Tennessee Governor Bill Haslam allowed the bill to become law by neither vetoing it nor signing it.