law, and perhaps also in common sense, that evolution is not a religion and that teaching evolution does not violate the Establishment Clause, Epperson v. Arkansas, supra, Willoughby v. Stever, No. 15574-75 (D.D.C. May 18, 1973); aff'd. 504 F.2d 271 (D.C. Cir. 1974), cert. denied, 420 U.S. 924 (1975); Wright v. Houston Indep. School Dist., 366 F. Supp. 1208 (S.D. Tex 1978), aff.d. 486 F.2d 137 (5th Cir. 1973), cert. denied 417 U.S. 969 (1974). A related claim is that evolution is atheistic (see the Atheism section below); creationists sometimes merge the two claims and describe evolution as an "atheistic religion" (cf. humanism). This argument against evolution is also frequently generalized into a criticism of all science; it is argued that "science is an atheistic religion", on the grounds that its methodological naturalism is as unproven, and thus as "faith-based", as the supernatural and theistic beliefs of creationism. Unfalsifiability A statement is considered falsifiable if there is an observation or a test that could be made that would demonstrate that the statement is false. Statements that are not falsifiable cannot be examined by scientific investigation since they permit no tests that evaluate their accuracy. Creationists such as Henry M. Morris have claimed that any observation can be fitted into the evolutionary framework, so it is impossible to demonstrate that evolution is wrong and therefore evolution is non-scientific. Evolution could be falsified by many conceivable lines of evidence, such as: the fossil record showing no change over time, confirmation that mutations are prevented from accumulating in a population, or observations of organisms being created supernaturally or spontaneously. J. B. S. Haldane, when asked what hypothetical evidence could disprove evolution, replied "fossil rabbits in the Precambrian era." Numerous other potential ways to falsify evolution have also been proposed. For example, the fact that humans have one fewer pair of chromosomes than the great apes offered a testable hypothesis involving the fusion or splitting of chromosomes from a common ancestor. The fusion hypothesis was confirmed in 2005 by discovery that human chromosome 2 is homologous with a fusion of two chromosomes that remain separate in other primates. Extra, inactive telomeres and centromeres remain on human chromosome 2 as a result of the fusion. The assertion of common descent could also have been disproven with the invention of DNA sequencing methods. If true, human DNA should be far more similar to chimpanzees and other