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===Controversy=== Decisions about tax status have been based on whether an organization functions like a church. On the other hand, [[Establishment Clause]] cases turn on whether the ideas or symbols involved are inherently religious. An organization can function like a church while advocating beliefs that are not necessarily inherently religious. Author [[Marci Hamilton]] has pointed out: "Moreover, the debate is not between secularists and the religious. The debate is believers and non-believers on the one side debating believers and non-believers on the other side. You've got citizens who are [...] of faith who believe in the separation of church and state and you have a set of believers who do not believe in the separation of church and state."<ref>[http://www.pointofinquiry.org/ Point of Inquiry] [[podcast]] (17:44), 3 February 2006.</ref> In the 1987 case of ''[[Smith v. Board of School Commissioners of Mobile County]]'' a group of plaintiffs brought a case alleging that the school system was teaching the tenets of an anti-religious religion called "secular humanism" in violation of the Establishment Clause. The complainants asked that 44 different elementary through high school level textbooks (including books on home economics, social science and literature) be removed from the curriculum. Federal judge [[William Brevard Hand]] ruled for the plaintiffs agreeing that the books promoted secular humanism, which he ruled to be a religion. The [[United States Court of Appeals for the Eleventh Circuit|Eleventh Circuit Court]] unanimously reversed him, with Judge Frank stating that Hand held a "misconception of the relationship between church and state mandated by the establishment clause," commenting also that the textbooks did not show "an attitude antagonistic to theistic belief. The message conveyed by these textbooks is one of neutrality: the textbooks neither endorse theistic religion as a system of belief, nor discredit it".<ref>{{cite book|last=Ivers|first=Greg|title=Redefining the First Freedom: The Supreme Court and the Consolidation of State Power, 1980β1990|year=1992|publisher=Transaction Books|isbn=978-1560000549|pages=[https://archive.org/details/redefiningfirstf00iver/page/47 47β48]|url-access=registration|url=https://archive.org/details/redefiningfirstf00iver/page/47}}</ref>
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