A new study says that a single county policy spawned at least 65 bills to promote creationism in American public schools. Nicholas J. Matzke, a phylogeneticist based at the Australian National University, traced the bills back to a 2006 Ouachita Parish, La., curriculum policy that encouraged teachers “to help students understand, analyze, critique and review in an objective manner the scientific strengths and weaknesses of existing scientific theories.”

Considered out of context, Ouachita Parish’s policy sounds innocuous. But Matzke argues that it opened a door that had been ostensibly shut by Judge John E. Jones’ 2005 verdict in Kitzmiller v. Dover. That case, brought by Americans United in conjunction with the American Civil Liberties Union of Pennsylvania, the National Center for Science Education (NCSE) and the law firm of Pepper Hamilton, determined that the Dover, Pa., school district had violated the First Amendment by teaching intelligent design (ID) in science classes.

It was a significant setback for creationists, who’d argued that ID had real scientific evidence to support it and therefore belonged in public schools. Matzke’s study showed that despite the loss, creationists wasted little time adapting their tactics. The Ouachita Parish was the first so-called “academic freedom” law to respond to Dover, and despite its name it unquestionably had religious roots.

The “creationist origins of modern antievolution strategies are clear,” he wrote, as quoted by Los Angeles Times.

“This tactic appears to be an attempt to circumvent earlier legal decisions suggesting that targeting evolution alone is prima facie evidence of religious motivation and, thus, unconstitutional,” Matzke added. “An additional motivation may be the dislike of climate change research by economic and religious conservatives.”

In an interview with Vox, Matzke said state legislatures directly copied the Ouachita Parish policy, sometimes word-for-word. “You can make a more specific analogy to diseases,” he explained. “We know that microbes evolve. They evolve to get around the immune system. They evolve to become sneakier. Animals evolving camouflage to avoid predators and stuff like that. We’re really seeing that happen with these creationist bills. The more obvious forms of these bills got shot down.”

Matzke applied statistical phylogenesis to organize the bills into a sort of legislative “family tree.” It’s an innovative approach, and his results, which were published last Thursday in Science, support the argument that “academic freedom” bills are really intended to create a loophole that can be exploited by educators sympathetic to creationism. Matzke knows all about this, of course: He once worked for the NCSE.   

It’s fitting that Matzke published his findings last week, days before we marked the 10th anniversary of the Dover ruling. That verdict endures as a real victory for religious freedom and science education advocates. But followers of the Religious Right have proven repeatedly that they’re able to adjust as necessary. This is true of their campaign to advance creationism, and it’s true of other “culture war” fights, too.

Consider marriage. The U.S. Supreme Court overturned bans on marriage equality, but the Religious Right has hardly given up the fight. Instead, its leaders have focused their energies on obstructing anti-discrimination laws that protect LGBT people.

Their determination shouldn’t be a surprise. To religious fundamentalists, these issues are really matters of doctrine; they believe they are advancing absolute truths. The Constitution, of course, flatly prohibits legislators from basing policy on dogma – whether the subject is marriage or science education.

That’s simple enough to understand. Matzke’s study makes it clear that some legislators just don’t intend to concede. In the face of a defeat, they (ironically) evolve and come up with a new strategy.