Critics of intelligent design and its movement contend that intelligent design is a specific form of creationism, neo-creationism, a viewpoint rejected by intelligent design advocates. It was bolstered by the 2005 ruling in United States federal court that a public school district requirement for science classes to teach that intelligent design is an alternative to evolution was a violation of the Establishment Clause of the First Amendment to the United States Constitution. In "Kitzmiller v. Dover Area School District", United States District Judge John E. Jones III that intelligent design is not science and is essentially religious in nature.