 Civil rights cases are typically brought in federal courts, so such state provisions are mainly of symbolic importance.In "Elk Grove Unified School District v. Newdow" (2004), after atheist Michael Newdow challenged the phrase "under God" in the United States Pledge of Allegiance, the Ninth Circuit Court of Appeals found the phrase unconstitutional.Although the decision was stayed pending the outcome of an appeal, there was the prospect that the pledge would cease to be legally usable without modification in schools in the western United States, over which the Ninth Circuit has jurisdiction.