The matter of the Pledge's constitutionality simmered for decades below the public eye. In 1992, the Chicago-based Seventh Circuit Court of Appeals decided the first challenge to the constitutionality of the words "under God", ruling in "Sherman v. Community Consolidated School District 21" that the use of the words "under God" in the Pledge did not violate the Establishment Clause. On June 26, 2002, in a case ("Newdow v. United States Congress") brought by an atheist father objecting to the Pledge being taught in his daughter's school, the Ninth Circuit Court of Appeals in San Francisco ruled the addition of "under God" an unconstitutional endorsement of monotheism.