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In 1967, in DeKalb v. DeSpain, a court (255 F.Supp. 655. N.D.Ill. 1966.) took a 4-line nursery rhyme used by a K-5 kindergarten class and declared the nursery rhyme unconstitutional. The court explained that although the word 'God' was not contained in this nursery rhyme, if someone were to hear the rhyme, he might think that it was talking about God - and that would be unconstitutional!
