 Several American atheists have used court challenges to address discrimination against atheists.Michael Newdow challenged inclusion of the phrase "under God" in the United States Pledge of Allegiance on behalf of his daughter, claiming that the phrase amounted to government endorsement of discrimination against atheists.He won the case at an initial stage, but the Supreme Court dismissed his claim, ruling that Newdow did not have standing to bring his case, thus disposing of the case without ruling on the constitutionality of the pledge.