Although it overturned the conviction, the Court decided that the Butler Act was not in violation of the Religious Preference provisions of the Tennessee Constitution (Section 3 of Article 1), which stated "that no preference shall ever be given, by law, to any religious establishment or mode of worship". The Court, applying that state constitutional language, held: The interpretation of the Establishment Clause of the United States Constitution up to that time held that the government could not establish a particular religion as the State religion. The Tennessee Supreme Court's decision held in effect that the Butler Act was constitutional under the state Constitution's Religious Preference Clause, because the Act did not establish one religion as the "State religion". As a result of the holding, the teaching of evolution remained illegal in Tennessee, and continued campaigning succeeded in removing evolution from school textbooks throughout the United States. Epperson v. Arkansas (1968) In 1968 the United States Supreme Court invalidated a forty-year-old Arkansas statute that prohibited the teaching of evolution in the public schools. A Little Rock, Arkansas, high-school-biology teacher, Susan Epperson, filed suit, charging that the law violated the federal constitutional prohibition against establishment of religion as set forth in the Establishment Clause. The Little Rock Ministerial Association supported Epperson's challenge, declaring, "to use the Bible to support an irrational and an archaic concept of static and undeveloping creation is not only to misunderstand the meaning of the Book of Genesis, but to do God and religion a disservice by making both enemies of scientific advancement and academic freedom". The Court held that the United States Constitution prohibits a state from requiring, in the words of the majority opinion, "that teaching and learning must be tailored to the principles or prohibitions of any religious sect or dogma". But the Supreme Court decision also suggested that creationism could be taught in addition to evolution. Daniel v. Waters (1975) Daniel v. Waters was a 1975 legal case in which the United States Court of Appeals for the Sixth Circuit struck down Tennessee's law regarding the teaching of "equal time" of evolution and creationism in public-school science classes because it violated the Establishment Clause. Following this ruling, creationism was stripped of overt biblical references and rebranded "Creation Science", and several states passed legislative acts requiring that this be given equal time with the teaching of evolution. Creation science As biologists grew more and