On February 27, 2006, the Utah House of Representatives voted down a bill that would have challenged the teaching of evolution in high school science classes. While the bill did not expressly provide an alternative to evolution, it would have required teachers to present a disclaimer that not all scientists agree on the theory of evolution, which would have arguably encouraged the teaching of intelligent design theory. Some states, including Kansas, have adopted laws similar to the one Utah failed to pass that require teachers to discuss criticisms of evolution. In December 2005, a federal judge struck down a Pennsylvania school district's attempt to teach intelligent design as unconstitutional.
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