humanist wedding than are married by any religious denomination, including Scotland's largest churches; over 20% of Scottish weddings are humanist. In Norway, over 20% of young people choose humanist coming-of-age ceremonies every year. Legal mentions in the United States The issue of whether and in what sense secular humanism might be considered a religion, and what the implications of this would be, has become the subject of legal maneuvering and political debate in the United States. The first reference to "secular humanism" in a US legal context was in 1961, although church-state separation lawyer Leo Pfeffer had referred to it in his 1958 book, Creeds in Competition. Hatch amendment The Education for Economic Security Act of 1984 included a section, Section 20 U.S.C.A. 4059, which initially read: "Grants under this subchapter ['Magnet School Assistance'] may not be used for consultants, for transportation or for any activity which does not augment academic improvement." With no public notice, Senator Orrin Hatch tacked onto the proposed exclusionary subsection the words "or for any course of instruction the substance of which is Secular Humanism". Implementation of this provision ran into practical problems because neither the Senator's staff, nor the Senate's Committee on Labor and Human Resources, nor the Department of Justice could propose a definition of what would constitute a "course of instruction the substance of which is Secular Humanism". So, this determination was left up to local school boards. The provision provoked a storm of controversy which within a year led Senator Hatch to propose, and Congress to pass, an amendment to delete from the statute all reference to secular humanism. While this episode did not dissuade fundamentalists from continuing to object to what they regarded as the "teaching of Secular Humanism", it did point out the vagueness of the claim. Case law Torcaso v. Watkins The phrase "secular humanism" became prominent after it was used in the United States Supreme Court case Torcaso v. Watkins. In the 1961 decision, Justice Hugo Black commented in a footnote, "Among religions in this country which do not teach what would generally be considered a belief in the existence of God are Buddhism, Taoism, Ethical Culture, Secular Humanism, and others." Fellowship of Humanity v. County of Alameda The footnote in Torcaso v. Watkins referenced Fellowship of Humanity v. County of Alameda, a 1957 case in which an organization of humanists sought a tax exemption on the