The implication in Justice Black's footnote that Secular Humanism is a religion has been seized upon by religious opponents of the teaching of evolution, who have made the argument that teaching evolution amounts to teaching a religious idea. The claim that Secular Humanism could be considered a religion for legal purposes was examined by the United States Court of Appeals for the Ninth Circuit in Peloza v. Capistrano School District, 37 F.3d 517 (9th Cir. 1994), cert. denied, 515 U.S. 1173 (1995). In this case, a science teacher argued that, by requiring him to teach evolution, his school district was forcing him to teach the "religion" of Secular Humanism. The Court responded, "We reject this claim because neither the Supreme Court, nor this circuit, has ever held that evolutionism or Secular Humanism are 'religions' for Establishment Clause purposes." The Supreme Court refused to review the case.