ground that they used their property "solely and exclusively for religious worship." Despite the group's non-theistic beliefs, the court determined that the activities of the Fellowship of Humanity, which included weekly Sunday meetings, were analogous to the activities of theistic churches and thus entitled to an exemption. The Fellowship of Humanity case itself referred to Humanism but did not mention the term secular humanism. Nonetheless, this case was cited by Justice Black to justify the inclusion of secular humanism in the list of religions in his note. Presumably Justice Black added the word secular to emphasize the non-theistic nature of the Fellowship of Humanity and distinguish their brand of humanism from that associated with, for example, Christian humanism. Washington Ethical Society v. District of Columbia Another case alluded to in the Torcaso v. Watkins footnote, and said by some to have established secular humanism as a religion under the law, is the 1957 tax case of Washington Ethical Society v. District of Columbia, 249 F.2d 127 (D.C. Cir. 1957). The Washington Ethical Society functions much like a church, but regards itself as a non-theistic religious institution, honoring the importance of ethical living without mandating a belief in a supernatural origin for ethics. The case involved denial of the Society's application for tax exemption as a religious organization. The U.S. Court of Appeals reversed the Tax Court's ruling, defined the Society as a religious organization, and granted its tax exemption. The Society terms its practice Ethical Culture. Though Ethical Culture is based on a humanist philosophy, it is regarded by some as a type of religious humanism. Hence, it would seem most accurate to say that this case affirmed that a religion need not be theistic to qualify as a religion under the law, rather than asserting that it established generic secular humanism as a religion. In the cases of both the Fellowship of Humanity and the Washington Ethical Society, the court decisions turned not so much on the particular beliefs of practitioners as on the function and form of the practice being similar to the function and form of the practices in other religious institutions. Peloza v. Capistrano School District The implication in Justice Black's footnote that secular humanism is a religion has been seized upon by religious opponents of the teaching of evolution, who have made the argument that teaching evolution amounts to teaching a religious idea. The claim