Florida House Bill H-837, also known as HB-837 or The Academic Freedom Bill of Rights, was a proposed bill in 2005 that would have allowed students to establish lawsuits against their professors and university for perceived intolerance of the student's beliefs. The bill could have also required professors to teach concepts that may have contradicted established facts, if the concept was considered a "serious scholarly" theory (such as Holocaust denial). The bill was heavily criticized as an attack on free speech in academia, and raised concerns about potential abuse by those with fringe beliefs. It died on calendar in May 2005. History H-837 was one of many "academic freedom" bills proposed throughout the United States in the early 2000s. At the time, the ideological divide between Democrats and Republicans was widening, and many Democrats were highly critical of President George W. Bush and the wars in Afghanistan and Iraq. Neoconservative activist David Horowitz, believing that the amount of liberal college professors was stifling discussion of conservative beliefs, decided to found Students for Academic Freedom (a subgroup of his Center for the Study of Popular Culture). Referencing a 1940 "academic freedom" document published by the American Association of University Professors, he drafted a "Student Bill of Rights" intending to protect students and faculty from discrimination or retaliation based on their political beliefs. Though the Academic Bill of Rights drew immediate backlash in academia, it spurred nationwide efforts to legislate "academic freedom" laws. In 2004, Florida Representative Dennis Baxley (R-Ocala) began considering an Academic Bill of Rights after listening to Horowitz's speech at a conference. Baxley had attended college in the 1970s, where he felt a professor criticized him for his creationist beliefs. In February 2005, with the support of Horowitz, Baxley proposed H-837, which was closely modeled after Horowitz's Academic Bill of Rights. Proposed legislation H-837 would have amended Florida Statute 1002.21 to guarantee "academic freedom" for students, and add Statute 1004.09, which would have laid out what rights students were granted. Statute 1004.09 would have legally mandated: The right for students to expect "a broad range of scholarly opinion" at their academic institution; institutions should prioritize "the fostering of a plurality of serious scholarly methodologies and perspectives"; Prohibition of retaliation by professors against students with different political beliefs via grading, recommendations, or other measures with academic or professional consequences; Prohibition of professors bringing up controversial subjects with "no relation to