textbook were changed to refer to intelligent design, which was presented by creationists as a new scientific theory. The Kitzmiller v. Dover (2005) ruling concluded that intelligent design is not science and contravenes the constitutional restriction on teaching religion in public school science classes. In September 2012, Bill Nye ("The Science Guy") expressed his concern that creationist views threaten science education and innovations in the United States. Creation and Modern science In the 15th and 16th centuries, discoveries in new lands brought knowledge of the diversity of life. In 1605, Francis Bacon emphasized that the works of God in nature teach us how to interpret the Bible, and the Baconian method introduced the empirical approach which became central to modern science. Natural theology sought evidence in nature supporting an active role of God, and attempts were made to reconcile new knowledge with the biblical deluge myth and story of Noah's Ark. The development of modern geology in the 18th and 19th centuries found geological strata and fossil sequences indicating a very ancient Earth. The diluvial cosmogonies fell victim to their own success, as the spirit of scientific inquiry they had stimulated, gradually led to discoveries that undercut the biblical premises of flood geology and catastrophism. From around the start of the 19th century, ideas such as Jean-Baptiste Lamarck's concept of transmutation of species had gained supporters in Paris and Edinburgh, mostly amongst anatomists. The anonymous publication of Vestiges of the Natural History of Creation in 1844 aroused wide public interest with support from Quakers and Unitarians, but was strongly criticised by the religious establishment and the scientific community, which called for solidly backed science. In 1859, Charles Darwin's On the Origin of Species provided that evidence from an authoritative and respected source, and within a decade or so convinced scientists that evolution occurs. This view clashed with that of conservative evangelicals in the Church of England, but in 1860 their attention turned to the much greater uproar about Essays and Reviews by liberal Anglican theologians, which introduced "higher criticism", a hermeneutic method re-examining the Bible and questioning literal readings. By 1875 most American naturalists supported ideas of theistic evolution, often involving special creation of human beings. At this time those holding that species had been separately created were generally called "advocates of creation," but they were occasionally called "creationists" in private correspondence between Charles Darwin and his friends. The term