Since then, critics have challenged the existence of the phrase in the Pledge. In 2004, Michael Newdow, an ordained atheist minister of the Universal Life Church challenged a Californian law which required students to recite the pledge. He said the law violated his daughter's right to free speech. The Supreme Court ruled in favor of the school system in "Elk Grove Unified School District v. Newdow", mainly due to the fact that the father could not claim sufficient custody of the child over his ex-wife who was the legal guardian and had opposed the lawsuit. Additionally, the Supreme Court stated that teachers leading students in the pledge was constitutional, and therefore the pledge should stay the same.