 The view that science can be demarcated from religion in its methodological naturalism is more commonly accepted. For instance, in the Kitzmiller versus Dover trial, the philosopher of science Robert Pennock was called to testify by the plaintiffs on whether Intelligent Design was a form of creationism, and therefore religion. If it were, the Dover school board policy would violate the Establishment Clause of the First Amendment to the United States Constitution. Building on earlier work (e.g., Pennock 1998), Pennock argued that Intelligent Design, in its appeal to supernatural mechanisms, was not methodologically naturalistic, and that methodological naturalism is an essential component of science. 