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It's important to specify the nature of these "certain theories" in order to advance the discussion, because the foundation of the subject is relevant to the Supreme Court ruling. If, for example, "certain theories" means teaching creationism or intelligent design, the Supreme Court would invoke the First Amendment Establishment Clause, because the Court already determined, in Edwards v. Aguillard, (1987), that intelligent design can't be taught in public schools due to its basis in creationism, a religious concept.

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