1964 that "a renaissance of the [creationist] movement is most unlikely." In 1961, Henry M. Morris and John C. Whitcomb, Jr published a book entitled The Genesis Flood, in an effort to provide a scientific basis for young earth creationism and Flood geology. Morris had published several books previously, but none had the impact that The Genesis Flood did. Its publication resulted in ten like-minded creationists forming the Creation Research Society in 1963, and the Institute for Creation Research in 1972. In 1968, the US Supreme Court ruled in Epperson vs. Arkansas that a 1928 act forbidding the teaching of human evolution violated the Establishment Clause of the US constitution. This clause lays out the Separation of church and state in the United States and states that "Congress shall make no law respecting an establishment of religion or restricting the free exercise thereof." In 1970, creationists in California established the Institute for Creation Research, to "meet the need for an organization devoted to research, publication, and teaching in those fields of science particularly relevant to the study of origins." In 1973, a famous anti-young earth creationist essay by the evolutionary biologist Theodosius Dobzhansky was published in the American Biology Teacher entitled Nothing in Biology Makes Sense Except in the Light of Evolution. He argued that evolution was not incompatible with a belief in God nor a belief in the accuracy of scriptures. In 1975, in Daniel v. Waters, the U.S. Sixth Circuit of Appeals struck down Tennessee's "equal time" law that any biology textbook which discussed human origins must give equal emphasis to the Biblical account. In 1978 the International Council on Biblical Inerrancy developed the Chicago Statement on Biblical Inerrancy, which denies "that scientific hypotheses about earth history may properly be used to overturn the teaching of Scripture on creation and the flood." In 1980, Walt Brown became director of the Center for Scientific Creation. In 1981, the San Diego based fundamentalist group the Creation Science Research Center claimed, in a trial dubbed the "Monkey Trial Replay," that teaching evolution as the sole theory of development violated the rights of children who believed in biblical creation. In his opening statement for the group lawyer Richard Turner argued: It is not a showdown at high noon between creation and evolution. It is not religion versus science. We are not trying to sneak the Bible into the classroom, or any other