In response to the June 14, 1954 Congressional change of the wording of the Pledge (found in U.S. Code, tit. 36 § 172) to include "under God", a series of lawsuits were filed in the New York State courts by Joseph L. Lewis challenging the constitutionality of the addition of the new phrase. Lewis was a publisher, writer, and co-founder of Freethinkers of America. As the cases involved Joseph Lewis desiring the Court to order the Commissioner of Education of The State of New York, James E. Allen, Jr. to remove the new words from the Pledge, these cases are referred to as the "Matter of Lewis v. Allen".