The U.S. 9th Circuit Court of Appeals in San Francisco heard oral arguments in two cases on the use of God-related language. In the second case, the Court reviewed a district court's ruling in Newdow v. Carey in which the court permanently prohibited a local school district from leading students in reciting the Pledge of Allegiance. Sacramento physician, aethist, and lawyer Michael Newdow had argued that public schools using the words "under God" in the Pledge of Allegiance violated the Establishment Clause of the First Amendment and was an unconstitutional endorsement of religion. He argued that while reciting the pledge is voluntary, it becomes unconstitutional when students who do not believe in God are forced to hear it.