any policies or laws that required the teaching of intelligent design in favor of a Teach the Controversy strategy. Institute Fellows reasoned that once the "fact" that a controversy indeed exists had been established in the public's mind, then the reintroduction of intelligent design into public school criteria would be much less controversial later. The best illustration of this shift in strategy is comparing the Discovery Institute's 1999 guidebook Intelligent Design in Public School Science Curricula which concludes "school boards have the authority to permit, and even encourage, teaching about design theory as an alternative to Darwinian evolution" to 2006 statements by Phillip E. Johnson, that his intent was never to use public school education as the forum for his ideas and that he hoped to ignite and perpetuate a debate in universities and among the higher echelon of scientific thinkers. With the December 2005 ruling in Kitzmiller v. Dover Area School District, wherein Judge John E. Jones III concluded that intelligent design is not science, intelligent design proponents were left with the Teach the Controversy strategy as the most likely method left to realize the goals stated in the wedge document. Thus, the Teach the Controversy strategy has become the primary thrust of the Discovery Institute in promoting its aims. Just as intelligent design is a stalking horse for the campaign against what its proponents claim is a materialist foundation in science that precludes God, Teach the Controversy has become a stalking horse for intelligent design. But the Dover ruling also characterized "teaching the controversy" as part of a religious ploy. Shift to the "Critical Analysis of Evolution" By May 2006 the Discovery Institute sought to replace the failed "teach the controversy" strategy with a strategy broadened to include examples of other supposedly legitimate scientific controversies. In Ohio and Michigan where school boards were again reviewing science curricula standards the Discovery Institute and its allies proposed lesson plans that included global warming, cloning and stem cell research as further examples of controversies that are akin to the alleged scientific controversy over evolution. All four topics are widely accepted by the majority of the scientific community as legitimate science, and all four are areas where US political conservatives have been known to be critical of the scientific consensus. Members of the scientific community have responded to this tactic by pointing out that like evolution whatever controversy may exist over cloning