of his day, by the mid-1950s the EPM came under control of schoolmaster/pastor Albert G. Tilney, whose dogmatic and authoritarian style ran the organization "as a one-man band", rejecting flood geology, unwaveringly promoting gap creationism, and reducing the membership to lethargic inactivity. It was renamed the Creation Science Movement (CSM) in 1980, under the chairmanship of David Rosevear, who holds a Ph.D. in organometallic chemistry from the University of Bristol. By the mid-1980s the CSM had formally incorporated flood geology into its "Deed of Trust" (which all officers had to sign) and condemned gap creationism and day-age creationism as unscriptural. United States legal challenges and their consequences In 1925 Tennessee passed a statute, the Butler Act, which prohibited the teaching of the theory of evolution in all schools in the state. Later that year Mississippi passed a similar law, as did Arkansas in 1927. In 1968 the Supreme Court of the United States struck down these "anti-monkey" laws as unconstitutional, "because they established a religious doctrine violating both the First and Fourth Amendments to the United States Constitution." In more recent times religious fundamentalists who accept creationism have struggled to get their rejection of evolution accepted as legitimate science within education institutions in the U.S. A series of important court cases have resulted. Butler Act and the Scopes monkey trial (1925) After 1918, in the aftermath of World War I, the Fundamentalist–Modernist controversy had brought a surge of opposition to the idea of evolution, and following the campaigning of William Jennings Bryan several states introduced legislation prohibiting the teaching of evolution. By 1925, such legislation was being considered in 15 states, and had passed in some states, such as Tennessee. The American Civil Liberties Union offered to defend anyone who wanted to bring a test case against one of these laws. John T. Scopes accepted, and confessed to teaching his Tennessee class evolution in defiance of the Butler Act, using the textbook by George William Hunter: A Civic Biology: Presented in Problems (1914). The trial, widely publicized by H. L. Mencken among others, is commonly referred to as the Scopes Monkey Trial. The court convicted Scopes, but the widespread publicity galvanized proponents of evolution. Following an appeal of the case to the Tennessee Supreme Court, the Court overturned the decision on a technicality (the judge had assessed the minimum $100 fine instead of allowing the jury to assess the fine).