"I consider the government of the U.S. as interdicted by the Constitution from intermeddling with religious institutions, their doctrines, discipline, or exercises."

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This constitution we designate by the word genotype. The word is entirely independent of any hypothesis; it is fact, not hypothesis that different zygotes arising by fertilisation can thereby have different qualities, that, even under quite similar conditions of life, phenotypically diverse individuals can develop.

— Wilhelm Johannsen