as an alternative to evolution, and their attorney arguing that it did not compel belief in the supernatural and was not a creationist text. After setbacks it focussed efforts "outside the schools" to prompt grass-roots activity from local school boards, teacher's groups and parents. In 1990, law professor Phillip E. Johnson set out his argument that the ground rules of science as presented at Edwards v. Aguillard unfairly disqualified creationist explanations by excluding the supernatural, and in 1991, he brought out a book entitled Darwin on Trial, challenging the principles of naturalism and uniformitarianism in contemporary scientific philosophy. In March 1992, a symposium at Southern Methodist University in Dallas provided the public debut for a small group that included Phillip Johnson, Stephen C. Meyer, William Dembski, and Michael Behe, initiating the wedge strategy that Johnson claims to have worked out by 1991. The 1993 second edition of the school textbook Of Pandas and People added a section by Michael Behe making the argument he later called irreducible complexity. The 1990s saw the rise of intelligent design, which maintains that intelligent intervention was necessary for evolution and in other ways seeks to create doubt about the validity and feasibility of evolution, and to change the scientific method so that supernatural explanations are accepted. In 1994, the court case Peloza v. Capistrano School District was decided against a teacher who claimed that his First Amendment right to free exercise of religion was violated by the school district's requirement to teach evolution. In 1996, the Discovery Institute's Center for Science and Culture (CSC), formerly known as the Center for Renewal of Science and Culture, was founded to promote Intelligent design, and entered public discourse with the publication of Darwin's Black Box by Michael Behe, arguing for evidence of Irreducible complexity. Critics claimed that this was a thinly veiled attempt to promote creationism, particularly in light of Edwards v. Aguillard. The Discovery Institute rejects the term creationism, which it defines narrowly as meaning young earth creationism, though in court intelligent design was found to be creationism. In October 1999 the Michael Polanyi Center was founded in the science faculty of Baylor University, a Baptist college, to study intelligent design. A year later was disbanded amidst faculty complaints that the center had been established without consulting them, and would cause the school to be associated with pseudoscience. In December 2001, the United States Congress passed