of the First Amendment. David Niose argues that reference to religion is not more likely to be harmless merely because it is "ceremonial." Used for the purpose of defending religious references by the government as harmless, he says the term "ceremonial deism" is grossly inaccurate and even dangerous, and argues that genuinely discriminatory governmental actions often escape scrutiny, partly because they are shielded by the euphemism of "ceremonial deism". Professor Martha Nussbaum at the University of Chicago Law school stated in 2008 that "'Ceremonial Deism' is an odd name for a ritual affirmation that a Deist would be very reluctant to endorse, since Deists think of God as a rational causal principle but not as a personal judge and father." See also American civil religion Civil religion Deism Separation of church and state References First Amendment to the United States Constitution Separation of church and state in the United States Deism