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A. I don't think there is any such thing as a minority scientific theory and I will tell you why. Because by the time a hypothesis reaches the status of a theory, there has to be a preponderance of evidence supporting it. It has to be almost overwhelming. Now at some later date the situation may change so that that theory has to be modified. But in terms of a minority theory, I can't think of any. Sometimes you will get minority hypotheses.
Q. What's the difference between a hypothesis and a theory?
A. Well, a hypothesis basically has less, much less support than a theory and it often encompasses a smaller chunk of something.
For example, I might hypothesize that this table is six feet long and I might perform an experiment to determine whether that hypothesis is correct. But I don't think that would ever become a theory just because I proved the table is six feet long.
So there is a difference in both the weight of evidence, and there's usually a difference in scale.
Q. If you have a hypothesis which rises to the level of a theory, at some point is it possible for the theory to rise to the level of a fact?
A. I don't — well, the way I think of a fact is essentially an observation or a set of observations that
52
are virtually universally accepted. I think, again, a fact would be that this table is six feet long or however long it is. Now, that's kind of a personal definition. Usually in science we use things like hypothesis and theory. Facts are primarily a set of data. That's the way I think of fact.
Q. Well, trying to recall one of the more prominent examples from the history of science. When Copernicus hypothesized, I guess, first that we did not have a geocentric universe. But in fact, the planets revolved around the sun. And then at some point I suppose that was tested. Is that to you today a fact or a theory?
A. Well, I think that is sufficiently a simple concept and has been measured to the degree that I would probably consider that a fact. I don't know of anyone who disputes that.
Q. And that was, at one time, a theory was it not?
A. I presume it was, yes. I don't really know the history of evolution of that particular line of thought as well — well enough to tell you at what point it was a hypothesis and at what point it was a theory. I think today most people would regard the fact that — well, I just used the word didn't I? Would regard that as a fact that the planets go around the sun.
Q. All right. So to take your position that there is
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no such thing as a minority view of scientific theory, at one time the thought that we do have a geocentric universe. The earth is the center around which everything else revolves. Did that hold sway in the scientific community? Are you aware of that?
A. As far as I know, that's correct.
Q. And when Copernicus offered this new theory or hypothesis, whatever you want to term it, it was not immediately and fully accepted within the scientific community. Are you aware of that?
A. That's correct.
Q. So under your view, until such time as the scientific community accepted, by a general consensus, Copernicus' theory, you would not have wanted that to be taught in a public school science classroom.
A. I think that depends on whether I were living in Copernicus' time or whether I were living today. If you asked me that — if that evolution and thought were going on today, I think we would recognize that Copernicus' hypothesis was a reasonable alternative that did not conflict necessarily with any data. And you might hold those two as an alternative hypothesis for a short period of time.
You do have occasionally some overlap when one theory or hypothesis replaces another one. There will be
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a time when it is difficult to decide between the two.
Q. Uh-huh.
A. There is seldom one definitive experiment, one breakthrough that happens at an instant in time so that you switch instantaneously from one theory to another. The theory of plate tectonics, for example in geology took several years to become accepted and replace the old ideas. So there was a brief period of overlap.
Q. Uh-huh.
A. But it only becomes an alternative when it becomes a reasonable explanation and when it doesn't conflict with an overwhelming amount of fact that opposes it or data.
Q. Well, during the time that there was this overlap or when both were being discussed — both being these two theories of the earth and of the universe — would it have been useful for those students who were studying science to study both theories you think?
A. Well, I don't — I don't know. That's difficult because in those days science and philosophy were mixed up together and I think with religion, too. Degrees in science weren't given, I think, until after Darwin graduated.
I don't think you could go to school and study science and get a degree in it when Darwin went to school. So part of the difficulty in answering that question is because I think there's been an evolution in the way
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science operates. It's separated from philosophy and religion in a way that it wasn't in Copernicus' time.
Q. The methods of radiometric dating which you have previously listed, are any of those methods — can two of those methods be used to date some geologic formation or rock or whatever — the same type? I mean can you use more than one method to arrive at a conclusion as to the age of something?
A. Sometimes you can, yes.
Q. Are the methods, to any degree, conflicting?
A. I don't quite understand —
Q. Well, is there a conflict in the methods of radiometric dating?
A. I still don't know what you're —
Q. Can you answer the question? Is there a conflict?
A. Well I don't understand the question. That's why I can't —
MR. WOLFE: I guess I find the question ambiguous as well. I'm not certain whether you mean do the methods they use, are in some sense not the same? Are they conflicting? Or are you asking whether the results arrived at, whether they occasionally give conflicting dates, for instance. I'm afraid I would object to the form of the question as presently posed as ambiguous.
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Q. All right. Let me see if I can rephrase it. Let me ask maybe a different question. Are you aware of generally some of the theories of evolution?
A. Only in the most general sense and primarily as a layman.
Q. All right.
A. I'm not prepared to answer any detailed questions on evolution at all. It is out of my field of expertise.
Q. Are you aware that there is something called the modern synthesis theory of evolution?
A. I'll just have to repeat my previous statement. I'm not an expert on evolution. I'm —
Q. I'm not asking you — I'm asking you as a layman are you aware — a layman in that field are you aware of that?
A. No.
Q. Are you aware of something called the punctuated equilibrium?
A. I have heard about it, yes.
Q. What do you understand that to be?
A. Well, my understanding is that — again, this is a layman's interpretation — is that evolution proceeds by a series of spurts and then long periods of stasis or non-change.
Q. And that is opposed — that theory would be as opposed to a slow gradual change; is that correct?
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A. That's my general understanding, yes.
Q. Do you know as to whether one is held by a majority of people within this field of expertise or not?
A. You'd have to ask a biologist. I don't know that.
Q. Basic mathematics would tell you that both can't be held by a majority. Would you agree with that?
A. Both could be held as alternative explanations, alternative models until such time as there is enough evidence to decide which is which. I'm speaking now in a general sense.
Q. I understand.
A. I don't know about these specific things at all.
Q. Sure. Do you think it would be appropriate in a public school science classroom to study both of these theories?
A. Well, you're really asking me now I think what the — a question that's related to what the present state of biological science is. And I'm not sure enough of what that is. I think that science classes should teach the present state of science as it is perceived by scientists. Now I don't know whether scientists perceive those as being equal or whether more people are in favor of one or the other. So it is difficult for me to answer the question if that's enough of a qualification to explain my difficulty.
Q. Okay. If there is one that is held by more of a
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majority of scientists and one that is held by a minority of scientists, do you think that the minority view should not be discussed in a science classroom?
A. Well, I suppose that depends on why it's a minority. If it's a minority because it's absurd, then I think it should not be discussed in the classroom. If it's a minority simply because there is slightly more evidence for one than the other and perhaps you have 60% of the people thinking that one may be correct and 40% thinking that the other is correct, then I would suggest that those things probably, then, should be both discussed in a classroom.
Q. Doesn't that conflict with your previous answer that there's no such thing as a minority scientific theory?
A. No, it doesn't. I think I said at time of transition when one theory might be replacing another one or when it is difficult to decide between the two, there may be periods of overlap. But I think those are rare. I'm not even sure that either one of those models has the status of a theory.
Q. Why do you say that?
A. Just because of my own ignorance. I'm not saying they don't have that status. What I'm saying is I don't know what the status of punctuated equilibrium versus gradual and continual evolution is. This is out of my
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field.
Q. Was your earlier answer, though, to one of my questions that if a hypothesis is held by only a minority of the scientific community, then it cannot be a scientific theory?
A. Would you repeat that for me again?
Q. Okay. Let me rephrase it. I have it down earlier that you said there's no such thing as a minority view scientific theory.
A. I think I later qualified that to say that at times, perhaps, there might be.
Q. Now how do you define — how does science define when there is an overlap, this transition that you mentioned?
A. Well, usually when there's active debate on both models in the traditional literature then there's an overlap. When science has a difficult time deciding between two models or two hypotheses, that's usually fairly obvious because the literature reflects that disagreement or that uncertainty.
Q. So if there is an overlap, do I understand you to say that you would not, at that point, object to two perhaps conflicting theories being taught in a public school science classroom?
A. No, provided they're both scientific theories or hypotheses and provided they're both substantiated with
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enough fact or observation that they — that both should be taken seriously, at least to a degree. Then I wouldn't object at all.
Q. Well, that last qualification you put on there of — of — could you read that back? That last part of that statement.
[Thereupon the court reporter read back the last answer given by the witness.]
Q. Okay. If there is a debate or publications in the scientific journals on both, would that not be sufficient evidence to you that there is enough facts or evidence for both as you said there?
A. Not necessarily. Every once in awhile a scientist will get an absolutely crazy idea and, publish it in the scientific literature as, uh, "Here's my crazy idea, colleagues. What do you think about it?" Just because that paper appears in the scientific literature does not give it the status of a hypothesis.
I think hypotheses have to be — have to be reasonable. They have to have some reasonable chance of being true before they're worth spending much time on.
Q. How do you define whether they're reasonable?
A. Well, when I think enough scientists look at that and say, "Yeah, that's a possibility." May I use an example?
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Q. Sure
A. I think today if a scientists published a hypothesis that said that the earth was flat, I think we now have enough data and have had enough data for so long that that's absurd. Now you could frame that proposition in terms of a scientific hypothesis. But it really is not because it's absurd and because it is so totally disproved.
Q. Let's go off the record.
[Off the record discussion.]
BY MR. WILLIAMS:
Q. Dr. Dalrymple, do you favor teaching all scientific evidence on theories of origins?
MR. WOLFE: I'll object to the form of the question unless you specify whether it's to high school students, graduate students, whatever.
MR. WILLIAMS: Oh. I really want to find out generally. I think we can qualify it later of if he wants to qualify it, he certainly can. But I want to — let's say generally teaching all scientific evidence.
MR. WOLFE: Well, then I want to object to the question.
Q. Okay. You can answer the question.
A. I guess I need to know before I do that what you mean by origin?
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Q. Talking about theories of origin of the universe, the earth, of life and man.
A. You don't necessarily mean ultimate origin? You see, this is the problem I have. If you ask me how a particular rock originated in its present state, that's a fairly simple question. It might be scientifically complex, but its a fairly simple question. If you're asking me how matter and energy came into being in the beginning, whatever that means then that's a difficult question that I'm not sure is within the realm of science. So that's my difficulty.
Q. Well, please remember that in my question it's a given that we're talking about scientific evidence.
MR. WOLFE: Well, I'll object to the form of the modified or restated question because it may not, in fact, be possible to assume that there is scientific evidence on a — on a, by definition, a non- scientific question.
A. You know, there's scientific evidence that goes back to the "Big Bang" if I can use that phrase. It doesn't go beyond that.
Q. Well, for example the scientific evidence on the Big Bang. Do you think that should be taught or do you favor it being taught?
A. Yes. Yes. Those are scientific observations.
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Q. What is the scientific evidence of which you are aware which supports the Big Bang theory?
A. Well, you're asking a question in astronomy and astrophysics and this is, again, out of my field. So if you want an answer, it would have to be a layman's answer. And as far as I know, the ideas or the data are primarily based on the fact that the galaxies are mutually receding away from each other and away from a common point in the universe.
Q. What happened to your resolution after you drafted it and circulated it?
A. Well, there's been no action on it yet. It has not been introduced to the council. I don't know whether it will be introduced to the council.
Q. Have you had a meeting of the council?
A. There's been no meeting.
Q. I take it you did get some opposition to your resolution?
A. Basically to the wording. This draft was circulated to try to find out whether there was enough interest in the subject that a resolution in any form should be considered. And this is why I say I'm not sure the resolution will even be introduced.
I think I would also like to say that that is a rough draft. It has the same status as an unfinished
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manuscript and I fully expect that if it goes anywhere, it will be modified. I don't know in what way except that there'll be other people besides myself involved in it. They will have opinions of their own on how such a resolution might be worded.
Q. In some of your letters in here you state that if it should be defeated and not prevail or be defeated, you told the council that that would be, to paraphrase, disastrous. Why is that?
A. Well, I wouldn't use the term disastrous, but my guess is that the creationists would view that as a victory. That a scientific society has considered a resolution against scientific creationism and rejected it. In a sense, whenever you submit a resolution like this you are forcing a group to take a stand either yes or no. There is no in between. This is why I say I'm not even sure it will be introduced because I'm not sure they even want to consider the question. It maybe a subject in which there is not interest. And if that's so, it will be promptly dropped.
Q. Why would there perhaps be no interest in your opinion?
A. There is a — there are some people in the AGU who do not think that the AGU should become heavily involved in any public issues. That it should stick primarily to
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the dissemination of scientific information strictly for the consumption of scientists.
Q. Uh-huh.
A. And I anticipate that might be the major objection of considering such a resolution.
Q. In one of your letters, this one to Dr. Leslie Meredith, you state that "We..." and from the context of the letter-I think that's Carl Sagan and yourself.
A. Uh-huh
Q. "...think that this is appropriate for the AGU to go on record on this issue, particularly as it is primarily a science education issue and not a political one." Could you tell me why you feel it is a science education issue and not a political one?
A. Because I think the issue is really what is going to be taught in science. That's the only issue that concerns me. I'm only concerned with science education. I have no qualms or reservations about teaching creationism as part of a social science curriculum or as part of a religion curriculum or a philosophy curriculum. But I have objections to teaching it as a science curriculum because I sincerely believe it is not science. That's why I think this is primarily an issue of what is science and what is not science.
Q. You wrote a letter, according to Exhibit #3, to
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Dr. James A. Van Allen. Did you ever get a response from him on this?
A. No, I've not yet.
Q. Have you talked with him about it?
A. I've not.
Q. One of the letters that you did receive from someone by the name of C. T. Russell and he says that he thinks that Van Allen will be your main problem. Do you know why he has that opinion?
A. No, I don't.
Q. According to this letter, Van Allen strongly opposed the ERA resolution. And do you know from that — are you aware of that fact?
A. Yes, I'm aware of it. And my understanding of that is that Jim Van Allen is opposed to the AGU taking stances on public and political issues. And whether he would consider a resolution on creationism to be one of those or not, I will not know until I hear back from him or have. a chance to talk to him in person about it. The letter by Russell is obviously speculation based on what, I don't know.
Q. Let's mark this as Defendant's Exhibit #4 please.
[Thereupon State's Exhibit #4 was marked for the record.]
Q. I'd like to show you Exhibit #4 to your deposition
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which is a letter to you from someone and your letter to a Sister Neal I think it is.
A. Noel.
Q. Noel? Excuse me. Do you recall writing that letter?
A. Yes. I recall writing one of the letters. I think she wrote the other one.
Q. Why did you write the letter to Sister Noel Riley?
A. She had written a column in a Southern California newspaper. I believe it was the Los Angeles Times but I'm not sure. I thought it was very well done and I wrote to her to tell her essentially that. She wrote back telling me basically that she appreciated my letter.
Q. All right.
A. I often do that when people have done things I like. I will often write them and say, "Congratulations" or "I think that was fine." "I appreciate what you've done" and so forth. I try to make that a regular habit.
Q. You stated in your letter to her that "Fortunately the number of scientists who draw religious inferences from physical data and the number of religious leaders who use the Bible as a science text are very small minority."
A. Yes.
Q. Who are the scientists of which you are aware who draw religious inferences from physical data?
A. I'm not aware of any in my personal knowledge. Those
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were phrases taken out of her column. I don't personally know any who do.
Q. Do you know of any who do?
A. I do not know of any who do and the reason I phrased it the way I did is I'm perfectly willing to admit that there may be some. She, as I recall, said there were and I'm quite willing to grant that possibility. But from my experience they must be a very small minority because I don't know any of them.
Q. Do you recall what she was talking about and what kind of inferences, religious inferences scientists were trying to draw from physical data?
A. I don't recall the details of the column at all.
Q. Do you have an opinion as to whether religion can be based on science?
A. I'm not sure I have any opinion on that one way or the other. Let me think about that a minute. I guess the answer to that might depend on how religion was defined.
Q. How do you define religion?
A. Well, my — I guess my personal definition is belief in a supreme deity of some sort, or deities.
Q. Do you think it's necessary to have a supreme being or God in order to have a religion?
A. Well, within my upbringing in western culture, I guess the answer to that would be yes.
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Q. You mentioned western culture. Would you acknowledge that there are religions, particularly some of the eastern mystic religions which don't have a God in a sense. Are you aware of that?
A. No, I'm not aware of that, but I'm willing to take your word for it if you say it's so.
Q. Okay.
A. I'm not a student of religion.
Q. You also used the phrase "religious leaders who use the Bible as a science text."
A. Yes.
Q. Does your reading of Act 590 indicate to you that the Bible could be used as a science text under this law?
A. May I look at this?
Q. Certainly.
A. Well, it says that the teaching must not include any religious instruction or references to religious writings. And I would presume that would preclude using the Bible as a text.
Q. Mark this Exhibit #5 please.
[Thereupon State's Exhibit #5 was marked for the record.]
Q. Let me show you Exhibit #5 which is a letter dated June 4, 1981 to Niles Eldredge from you and I believe there is another letter attached as part of that exhibit which
70
is from Niles Eldredge to you.
A. Uh-huh.
Q. Do you recall those letters?
A. Yes. I wrote them if that's what you're asking.
Q. What are the geophysical issues as you use that term in here as they relate to science and creationism?
A. Well, creationism has two geological propositions. One is that the earth is approximately 10,000 years old or less and the second is that all the sedimentary rocks in the geologic column were deposited during the great flood which lasted about a year and occurred sometime between 4,500 and 7,000 years ago. Those are the two propositions against which there is a preponderance of geophysical evidence.
Q. I'd like for you to look at Act 590 and tell me where the first of those propositions that the earth is approximately 10,000 years old is found in Act 590 if it is.
A. Well, it's not. But Section 4.(a)6 says, "relatively recent inception of the earth and living kinds." And from reading rather extensively in the scientific creationism literature, all of those writings seem to indicate — or most of them seem to indicate that the earth is less than 10,000 years old. There are numerous statements to that effect.
Q. However, as you personally understand the term
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"relatively recent" given the age which you believe the earth is of some like 4.6 billion years old, "relatively recent" could mean a lot older than 10,000 years old couldn't it?
A. It could but I don't think you would get any scientific creationists to accept that definition. If they would, I've not seen it written down by them.
Q. Is there scientific evidence that the earth is, while older, than 10,000, is younger than 4.6 to 4.8 billion years old?
A. None that I know of.
Q. In Niles Eldredge's letter to you he states, "Your manuscript told me something, with crystal clarity, that (though I knew) I had been sweeping under the table: I have been fond of saying that creation science isn't science — but this is not strictly accurate." And he goes on to talk about that creation-science is science, but it is what he says is "bad" science. Is that your opinion?
A. Well, my opinion is that it's not science because it's religiously based. I think what he was talking about was the kind of treatment I did in here (indicating). In the introduction I said that there were two geological corollaries of what they call their creation model. And we can examine those as if they were hypotheses and see
72
whether they are absurd or whether they are reasonable.
Q. Uh-huh.
A. So often times you can treat things scientifically without them necessarily being science. Now if you look at these as religiously based, it's not science. If you divorce it from the religion, then it only becomes absurd. This is what I think he probably means by "bad" science. If you really want to know what he means in that letter you'd have to ask him.
Q. Well, earlier I think in discussing your draft resolution we talked about what was science and what was a scientific theory. And your resolution made statements about that a theory must be testable, capable of validation, that sort of thing. Now if you look at, for example, the statement that there has been a relatively recent inception of the earth and living kinds. Let's just take the portion dealing with the earth since that's really your area of expertise as I understand it.
A. Yes.
Q. What you are, in effect, I think saying here in this manuscript is that aspect of creation-science is subject to being tested and you have tested it and think it's false.
A. It's been tested. We've known for over 25 years that the earth was 4® billion years old and the solar system. And at this point, to say that it's very young regardless
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of whether you draw that line at 10,000 years or 1,000,000 years or even 10,000,000 years, it is an absurd hypothesis. It is in the class of the flat earth.
You see, when things become absurd they cease to be science. We simply can't afford to waste our time reproving things that are already proven.
Q. Now you've added another qualification I think to what is a scientific theory. That is that it must not be absurd.
A. Well, I think I said before that a theory had a preponderance of evidence to support, even though it was still undergoing tests and may undergo modification. I think what I said earlier was that a hypothesis may not be absurd. I think the same thing holds true of a theory. A theory may not be absurd.
Q. And it goes without saying that if it is absurd, it's not a scientific theory or hypothesis in your mind; correct?
A. I think that's a fair statement, yes.
Q. Who is to determine the absurdity of a theory?
A. Well, that's generally done by a collection of scientists, by consensus. There is no formal procedure for doing that.
Q. So that if someone says — a consensus or majority of scientists say a theory is absurd, then at that point the scientific community can dismiss it and not consider
74
it further as a viable scientific theory?
A. That's basically correct, you see, but that's not just based on an opinion. People would come to the conclusion that it's absurd because they know of an overwhelming amount of evidence against it. That's what makes it absurd. It's not really a matter of opinion. It's a matter of evaluating the evidence.
Q. And you state in your letter to Eldredge that "Hypotheses that are clearly false, like above or a 10,000 year-old earth, are not scientific hypotheses — they're silly and the produce of emotionally and intellectually retarded minds." Is that an accurate representation of your beliefs and your feelings?
A. I wrote that, yes.
Q. So that anyone who believes in an age of the earth which is 10,000 years old is retarded?
MR. WOLFE: I will object to the characterization that counsel has just used. The letter was read into the record. The witness was asked whether he had, in fact, written it. He did say that he had, in fact, written it and I believe that it speaks for itself.
MR. WILLIAMS: The characterization is the witnesses, not counsel's.
MR. WOLFE: No, no. The
75
characterization is clearly that of Mr. Williams. The letter is clearly that of Dr. Dalrymple. And I think the record now is perfectly clear as to that distinction. I suggest that you made an effort to blur that distinction, which I prefer you not to do.
Q. Well, let me make sure that the record is perfectly clear. It is your belief that anyone who thinks that the earth is approximately 10,000 years old has an emotionally and intellectually retarded mind?
A. Well, I wrote that and those terms are used very loosely. This was a personal conversation between two people. If I may rephrase it a little bit, I think that people who attempt to put that proposition over as science rather than a personal belief or a personal religious belief can't be very bright because there is a tremendous amount of scientific evidence. Thousands and thousands and thousands of data which tell us that is not true. It's absurd. And they simply can't understand that. Therefore, there is something wrong with their process of thinking scientifically. I'm only restricting that to scientific reasoning. I have no qualms about what people choose to believe as religion or philosophy or anything else. As a scientific proposition, it's absurd.
Q. Do you agree or disagree with this statement? This is from Eldredge. "So, when the ACLU says that the
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Arkansas law injects religion into the school curriculum, they're right, but they must avoid asserting that creation- science is pure religion. It's science — bad, bad science."
A. Well, I think there are two ways to look at that. It's hard to say whether I agree exactly with that or not. But scientific creationism is clearly religiously based, and in that sense, it's an introduction of religion into science teaching. On the other hand, if you want to try and divorce that and look at it as science, it is rotten, rotten, science. So there are really sort of two ways to look at it. I don't think we want to teach rotten science.
Q. He goes on to state, "But, unfortunately, it is not unconstitutional to teach bad science." Without asking for a legal judgement, do you agree with that?
MR. WOLFE: I would object to the form of the question. I would like to have some greater specification of whether there is any content to that question that does not call for a legal judgement.
MR. WILLIAMS: Okay. I think that's fair. I think that's probably inherently legal. WITNESS: I was going to say that the Supreme Court has enough trouble with that. I don't know why you're asking a poor geologist.
BY MR. WILLIAMS:
Q. This manuscript which we've previously discussed,
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for purposes of this deposition, why don't I have this marked as Exhibit #6. I don't want to make it an exhibit to the deposition, but just marked for identification. [Thereupon State's Exhibit #6 was marked for identification.]
Q. As I understand it, is Exhibit #6 going to be part of a book or is it going to be published as a book itself?
A. The present intentions are that it will be a chapter of a book.
Q. Who, if you know, are going to be the authors of the other chapters?
A. I'll try to remember who they are. Bill Mayer, Norman Horowitz of Cal Tech, Richard Dickerson of Cal Tech and I believe Tom Jukes of Berkeley, plus myself. There may be others that I've forgotten. There is one more. Everett Olson of UCLA.
Q. And is Mayer going to be the editor?
A. He has taken the responsibility of editing the volume, yes. The scientific editor.
Q. Do you know who he refers to in "our brave little band"?
A. I think he's referring to the people who were supposed to be the scientific witnesses in the Segraves trial for the State of California.
Q. I notice you have in here some correspondence which
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appears to be from Kelley Segraves. How did you come to have this correspondence?
A. That was sent to me by Tom Jukes if I recall correctly. Is there a letter attached to the front? I'm not sure but that came in a — I think that came from Tom Jukes. But I'm not sure.
Q. Do you plan to rely on this in your testimony?
A. No, it was put in there simply because it seemed to fit the description of the material that you asked for.
Q. Mark this please.
[Thereupon State's Exhibit #7 was marked for the record.]
Q. I show you what's been marked as State's Exhibit #7 to your deposition, which is a memorandum dated September 25, 1981 to the Assistant Chief Geologist, Western Region. from the Acting Assistant Director, Western Region.
A. Yes. Uh-huh.
Q. Do you recall receiving this document?
A. Yes.
Q. Was there a document which you sent to — is it Mr. Swinnerton —
A. Swinnerton.
Q. — in which he, in turn, gave you this one? I note Exhibit #7 says, "As requested, you are authorized to testify. . ."
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A. Yes. I wrote him a letter stating that I had been asked to testify by the ACLU, gave him the case number and so forth; and I could not find that letter. But it was a simple standard form request for permission to testify.
Q. Could you tell me what you understand to mean by this, the following language in his memo to you? "You are not authorized to testify on behalf of either party. However, you are authorized to present factual data and furnish records in regards to radiometric dating."
A. What he means by that?
Q. What you understand that to mean, particularly that first sentence.
A. That's basically I'm authorized to appear as an expert witness I think is what that means.
Q. But you can't testify on behalf of either party. What does that mean?
A. I don't really know what that means. I think that means is if you had asked me to come and testify, I would have been just as willing to come and testify at your request as at the ACLU's.
Q. It also says that you are authorized to present factual data and furnish record. Is it your understanding that you are not authorized to give opinions?
A. I think opinions that are within the realm of my
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experience as a scientist are quite appropriate. And what I answer depends on what questions you ask me, so. I should mention that that letter is more or less a standard form reply for request to give testimony in any legal proceedings.
Q. To your knowledge, have you ever reviewed — or have you in the past reviewed articles for publications in refereed journals?
A. Oh, yes. Frequently.
Q. Have you ever reviewed any on the subject of creation-science?
A. No.
Q. Have you ever reviewed any which, to your knowledge, would support the theory of creation-science?
A. No.
Q. What if you were to see one and would be asked to review it by one of the journals which you would review for and — while the scientific data looked competent and good, it did support creation-science.
A. Well, I would apply the same criteria to such a scientific article as I do to all scientific articles. Exactly what my recommendation to the author and the journal would be would depend on the details of the paper. Since that's a hypothetical question, I really can't tell you what my response would be.
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Q. Would you mark this, please, as Exhibit #8?
[Thereupon State's Exhibit #8 was marked for the record.]
Q. Was there a session on creation-science at the fall AGU meeting in San Francisco?
A. Well, the fall meeting will be next week and the answer is no, there will not be.
Q. Why is there not going to be a session — well, first of all. You did write some letters didn't you proposing that there, perhaps, be a session?
A. That was an initial — an initial attempt to see if there was enough interest to have one and I'm not sure yet whether there will be one in future meetings or not. I haven't decided.
Q. Wouldn't it be fair to say, from looking at these documents, that you have been trying to spearhead something within the AGU on the subject of creation-science?
A. That's correct.
Q. You have proposed a resolution. You have also proposed a seminar or some sort of a session on the subject; correct?
A. That's correct.
Q. And to date, at least, your efforts within AGU have not met with success.
A. Well, that's not correct.
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Q. Well, you've already said there's not going to be a session next week on the subject in the meeting. Is there going to be a resolution introduced?
A. I don't know whether it will be or not. I've not seen the agenda for the council meeting. My understanding is that the topic of whether or not the AGU should consider becoming involved in that will come up at the council meeting. But I'm not sure that's on the agenda. The reason there will be no seminar is because I'm the program chairman, and I decided I didn't have time to do it this fall.
Q. According to Exhibit #8, there is something in here entitled "Science and Creationism, Possible Subjects and Speakers." Was that your tentative outline for a proposal
A. That was just a rough —
Q. — for a program?
A. — list of ideas. It's not even what I would call an outline.
Well, you do have some — let's go off the record.
[Lunch break.]
DIRECT EXAMINATION CONTINUED
BY MR. WILLIAMS:
Q. Now before the break we took we were discussing Exhibit #8, which is a series of correspondence. There are several letters in there. Why don't you just generally
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identify what it is.
A. Uh-huh.
Q. Would you describe what it is?
A. That's a series of letters discussing the possibility or the desirability for a symposium or a special session on creationism at some future AGU meeting.
Q. And as part of this there is a proposed schedule or rough draft I think you said on a seminar or session on science and creationism.
A. Well, I think that's a list of possible ideas. I didn't intend it to be an outline.
Q. And there are certain ideas or topics and I notice that there are people referenced in parentheses. For example, "Introduction (Sagan, Dalrymple)" Is that correct?
A. Yes.
Q. These are the people who you were thinking about perhaps....
A. They're possibilities of people that might handle that aspect of the program.
Q. And you are chairman of the program committee?
A. I am program chairman for the VGP section.
Q. All right. And of the names you have on here of people you were thinking about being involved, are any of these people creationists?
A. Let me look at the list. No.
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Q. Is there any particular reason why you, in this tentative list at least, were not going to involve any people who consider themselves to be creation scientists to attend and present their views?
A. Well, my thinking was that this was not a debate on the subject. It was a program to inform people about what the issues — what the issues were.
Q. Really, my question was not whether you were going to have a debate, but it goes to the fact that you were going to try to present kind of what cre — what creation science is and how it might be viewed by the scientific community or at least these people. Why would you not want to have people of the creation-science community if there is such?
A. Well, they would be free to attend if they wished to.
Q. Well, why would you not want to ask them to attend and present some of their views?
A. Well, the way a symposium like this is organized — and this is one of about — this was a possible one of half a dozen or so that I organize for each AGU meeting. Those are held twice a year. The typical format is to have some people who are invited and other people who can apply and I was unsure in my own mind whether or not it would be appropriate to ask creationists to come at all.
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I think when you do that, you're immediately in to a debate. That was not the intention. The intention was to inform the AGU membership.
Q. In another letter to Carl Sagan you state that, "Incidentally, I just discovered (to my horror) that Henry Morris of CRI in San Diego is a member of AGU!"
A. Yes.
Q. Why do you make that comment?
A. I was very surprised that Henry Morris, who is the director of CRI in San Diego, would pay dues to a society, a scientific society that has presented a considerable preponderance of evidence to disprove what the man believes. And yet, he supports this organization through his dues. That, to me,- is surprising.
Q. Why is that "to your horror" though?
A. Well, that's a very loose — again, you're reading a conversation. Surprise might have been a better word to use.
Q. Do you think he could be booted out of the AGU?
A. No. Henry Morris is, by training, a hydrologist as I understand it. There is a section in hydrology. Also, anyone who expresses a sincere interest in science and has at least a Bachelor's degree in science is free and in fact, invited to join the AGU. It's a very open society. No one is precluded and I would be the last one
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to exclude Henry Morris or anyone else.
Q. Could you explain to me what you consider the term "uniformitarianism" to mean?
A. As presently used or in its historical context because the definition has changed considerably over the last 100 years.
Q. All right. Why don't we get both. Let's start with the historical context.
A. Well, this is just the time he took the two notebooks so I couldn't make some quotes.
Q. Oh.
A. Let me try to go from memory. When it was first formulated by Hutton and Lyell it had a variety of meanings. One was that supernaturalistic causes were not permissible explanations in science. One was that the present is the key to the past and that phrase has been interpreted in different ways. Another was that the rates of geologic processes were constant and another was that the physical laws of the universe were constant through time. Those four definitions have been used by different people in different times.
The current way the uniformitarianism is used by geologists has eliminated a good many of those and it boils down to only two propositions. One is that the physical laws are constant through time. And the second,
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which is really a corollary of the first is that supernatural explanations are not acceptable in science to explain physical phenomena or observations.
Q. Could you define for me "catastrophism" as you understand it.
A. Again, catastrophism is a word that sprang up during early days of uniformitarianism when there were two sort of schools of thought. One was that the rates of geologic processes were constant and the other was that the rates were not constant. That things happen in a series of catastrophes or steps. So that's the historical context as taken from the 1800s.
Today the word catastrophism is not really used very much except that I think we realize that geological processes are not constant and they happen in a series of both constant and catastrophic processes. As an example of that, in the oceans the sediments are raining down and being deposited at a rather constant rate over sometimes periods of millions of years. On the other hand, an earthquake is clearly a catastrophic event and so would a flood be. So we recognize that the rates of processes are not constant at all. That's been recognized for many many years.
Q. You said it has been recognized for many years that the rates —
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A. The rates of most geological processes are not the same, are not constant through time. And by that I mean things like sedimentation, erosion, uplift, motion of continents over hundreds of millions of years and so forth. I do not mean the rates of certain kinds of physical processes are not constant. I'd like to make that distinction.
Q. Is there a trend now in geology to discussing catastrophism more than there has been in the past?
A. Well, not since I was a student back in the '50s. Catastrophism in the sense that certain things geologically happen very rapidly has been — was — was a clear concept when I was a student in undergraduate school.
Q. Was a what? Clear —
A. Clear concept, sure. And we observed this by, say, observing floods and earthquakes. Those are clearly catastrophic. In other places like the long slow uplift and ocean basin sedimentation, we realize that at some times for certain periods of time processes of time can become constant.
This will be Exhibit #9.
[Thereupon State's Exhibit #9 was marked for the record.]
Q. I'd like to show you what's been marked as Exhibit #9 to your deposition and ask if you can identify that?
A. Yes. This is a report of a meeting held at LSU at
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Baton Rouge accompanied by some correspondence several months later concerning that meeting. And the report of the meeting and all this occurred in EOS, which is the transactions of the American Geophysical Union. Those are copies.
Q. Is that a referee journal? EOS?
A. No. EOS is really a type of newsletter.
Q. As you understand it, what was this symposium held at LSU?
A. I don't know much about the symposium other than what's contained in that article. I had no involvement in the symposium and I only read about it in EOS sometime ago. The purposes I recall had something to do with engineering and the effect of measuring geologic time on engineering problems. Other than that, I really don't know much about it
Q. Why did you come to have this as a copy of these articles? Why did you keep it?
A. Bruce Ennis and Steve Wolfe and I were discussing Gentry's pleochroic halos and whether or not his evidence for polonium halos was conclusive. And I remembered that Paul Damon had written a letter to EOS surrounding this — excuse me. With regard to that meeting and had voiced some criticism of Gentry's idea. I told him I would see if I could find that article and copy it for them, which
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I did.
Q. Have you reviewed some of the articles that Gentry has written?
A. I've never reviewed any of his articles. As a referee for a journal?
Q. Well, yeah. First of all let me ask you that.
A. No, I've not.
Q. Have you read them?
A. I have read a few.
Q. Do you have an opinion as to the articles that you have read?
A. Um, Gentry's work that appears in the scientific literature seems to be based on very careful measurements and I think it's fairly highly regarded.
Q. Do you consider the work to be scientific? The work which you have seen which has been published in any scientific journals?
A. The work that I have seen which has been published in the scientific journals is scientific, yes.
Q. Do you have an opinion more specifically as to whether you agree or disagree with some of the data that are some of his conclusions.
A. You would have to tell me which conclusions specifically you're speaking of.
Q. Are you familiar with some of his studies of
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coalified wood from uranium bearing sands in the Colorado Plateau?
A. No, I'm not familiar with that at all.
Q. What articles do you recall reading?
A. The only one I read recently was the review article in the "Annual Reviews of Nuclear Science" on pleochroic halos. I should mention that this is a subject that I do not follow very close.
Q. Pleochroic halos you do not follow very closely?
A. That's correct. They are not of much interest to me.
MR. WOLFE: Off the record.
[Off the record discussion]
BY MR. WILLIAMS:
Q. Are you or have you reviewed the letter written by Paul Damon?
A. I read it over, yes.
Q. Do you agree with what he says in there about Gentry's work?
A. I'm inclined to agree with his conclusion that Gentry's assertion that those particular halos were formed by polonium may not be correct. Damon presents a rather convincing argument that that leads to a conclusion that is probably absurd. But again, I'm reading this as someone who is not really an expert at pleochroic halos and I'm trying to decide between two people who are
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debating it between themselves. I'm not involved in that debate.
Q. Would you regard Gentry as an expert on radioactive halos?
A. I think he's considered an expert on radioactive halos; yes.
Q. Do you know Ralph Kazmann — Raphael Kazmann?
A. No, I do not know him.
Q. Have you reviewed his letter in this exhibit?
A. I read through it briefly, yes.
Q. In his letter he says that "The point made by the participants in the symposium is that there are great uncertainties in the time scales used by solar astronomers, cosmologists and geologists. No single one of these uncertainties would be sufficient to affect engineering evaluation. However, all of them taken together, which indicate that we have overestimated the period of time that is required for geologic and cosmologic processes serve as a caution signal." That last sentence, the overestimation of the period of time required for geologic or cosmologic processes. Do you have an opinion on that?
A. I don't know what time he's talking about. If he is saying there, as I think he is, that our esti — our measurement of the age of the earth of between 4.5 and 4.6 billion years is an overestimate, then I would say
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categorically he is wrong.
Q. Do you consider Gentry to be a creation scientist?
A. Based on a couple of statements he made in that letter I would say yes.
Q. Would you mark this as Exhibit #10?
[Thereupon State's Exhibit #10 was marked for the record.]
Q. I show you a document which has been marked as Exhibit #10 to your deposition which you have provided me this morning entitled "Radioactive Halos" by Robert V. Gentry. You'll have to tell me what publication it's from.
A. It's from the "Annual Review of Nuclear Science", volume 23, page 347-362 dated 1973.
Q. That's the article you have previously read?
A. Yes. I've read through that within the last six months.
Q. If — well, first of all. Again, let me make sure I understand. Is this the article you referred to where you felt like his measurements were good and you would say that it was —
A. This is a review article of the state of — as of — well, probably really '71 or '72 considering publication time. This is a review article of the state of research on pleochroic halos.
Q. This is a review article rather than a — it does
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not contain any original research as such?
A. I don't know how much of it's original. But most of it's essentially a review of the state of that particular aspect of the science. This annual review series publishes such things. It's essentially to allow scientists who want to get up to speed on something or determine what the state of a particular field is to do that.
Q. What would be the implications for the dating or — excuse me. The age of the earth, if any, according to the findings in this article.
A. As far as I know there are none with one statement and let me see if I can find that for you. That's based on Gentry's own conclusion. He says, and I quote, "On the other hand, Gentry reference 24 has shown that even exact agreement between halo radii and corresponding CB sizes does not necessarily imply an invariant lambda," Lambda is the decay constant. "and in fact, uncertainties on radius measurements alone preclude establishing the stability of Lambda for 238U to more than 35%." And what I think he's concluding there is that the measurement of radioactive halos don't tell you whether or not decay rates have been constant, And therefore, in terms of radiometric dating, I think the research on pleochroic halos is probably irrelevant.
Q. Are you familiar with any articles he has written
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since 1973 on the subject of radioactive halos?
A. No. Not that I can recall.
Q. Do you know if he's written any?
A. Oh, I just don't know. He may well have. He's a fairly active researcher. I suspect that maybe he has. That's almost ten years ago that this article was written.
Q. Have you reviewed any of his work or any of his writings in preparation for this trial?
A. Just that.
Q. Other than this?
A. No. That plus I read his letter in response to Damon.
Q. Do you have an opinion as to whether the theory of evolution is a valid scientific theory?
MR. WOLFE: I'll object to the form of the question unless you ask whether or specify whether you're asking his opinion as to the validity of the content or whether it is a scientific theory as opposed to non-scientific.
MR. WILLIAMS: As to the validity of the theory as a scientific theory?
MR. WOLFE: Yeah. I think the question was ambiguous as to whether you were saying assume that the theory of evolution is a scientific theory. Is it correct or incorrect?
MR. WILLIAMS: No.
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MR. WOLFE: Or whether the question is is it a scientific theory or not.
Q. The question is is it a scientific theory or not?
A. My understanding of it is that it is.
Q. Do you know how it is testable?
A. Well, you're getting into a biological experiment and, out of my field of expertise. I'm afraid I'm not competent to design experiments in biology.
Q. Do you know if the theory of evolution is falsifiable?
A. I'd have to give you the same answer. That depends on the experimental design and I'm not competent to do that.
Q. Do you think that the earth's geology is explained by uniformitarianism?
A. Well, uniformitarianism doesn't say anything about the earth's geology. It only says that science proceeds on the basis that natural laws have not changed with time.
Q. Proceeds on the basis?
A. Well, uniformitarianism is a tool.
Q. Proceeds on the basis? Is that an assumption?
A. I think it's a necessary assumption of science. That is if we presume otherwise, then we are allowed to change natural laws any time we wished. And therefore we can have no logical development of science. I think it's a necessary condition of science that we presume that there is a set of laws that governs what we see, and that we can
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rationally figure out what those laws are.
Q. You say it is a necessary tool that you — well, on what do you base the assumption? What proof is there for the assumption?
A. Well, you're asking me things like what proof is there that the speed of light is constant, has been constant since the beginning of the universe. And my answer to that, I guess, is that I don't know except again I'll say it's a necessary condition of science. If science is to make any headway at all, we have to assume that we're dealing with rational physical laws that don't change in an irrational manner. That's simply one of the boundary conditions.
Q. Well, if the laws have changed, are you saying there could not be science?
A. I think if — if the fundamental physical laws of the universe have changed randomly or capriciously with time, then there is no physical basis for science at all. And I think the reason that we believe they have not changed is because there is fairly good evidence to think that most of them have been constant and there is absolutely no evidence to lead us to suspect that the physical laws have changed.
Q. What is the evidence that they have been constant that you're aware of?
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A. Well, I think most of it is — a good part of it is theoretical. Part of it, when you're talking about things like radioactive decay, is experimental. So there again, it depends on what physical laws you're talking about. When I say physical laws, I'm thinking of laws of radioactive decay and gravity, speed of light and things like that.
Q. Is it an assumption that radiometric dating methods, that the radioactive decay has been constant through time?
A. That's one of the premises upon which it works and there is evidence for that premise.
Q. What evidence is there for that premise?
A. Well, the first kind of evidence is theoretical. The evidence is that radioactive decay, the type of radioactive decay that is used in radiometric dating arises from the nucleus. And the nucleus is extremely well insulated from its surroundings to such extent that scientists have not been able to change decay rates in the laboratory except by minute, minute percentages even with extremes of temperature and pressure and so forth. So there is — the experimental evidence that we cannot now change decay rates significantly enough to affect any radiometric dating technique. As I say, there are theoretical reasons to believe that those laws should not change. And if you go back in time, there is sufficient
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concordance between dating methods that use different decay rates and different decay constants; and if rates had changed, you would not be able to get that kind of concordance.
Q. Now maybe you just told me, but I'm not sure. What are the theoretical reasons why you feel that there has been a constant rate of decay?
A. Well, as I just said, the radioactive decay arises. from within the nucleus of the atom.
Q. I thought that was the experimental reasons?
A. Well, theory tells us that it should be extremely difficult to influence radioactive decay rates by more than a tiny, tiny fraction because of the insulation of the nucleus from it's external surroundings and because of the very strong nuclear binding in the nucleus. Experimental evidence tells us that that theory is correct. That scientists who have attempted to change decay rates find that they can only do it by very, very small fractions of a percent.
Q. If I understand what you're saying, Dr. Dalrymple, it is that it is possible that the rate of decay has been constant because of these things that you've mentioned?
A. It's very probable —
Q. Probable?
A. — that it's been constant. I would say it's
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probably certain that it's been constant.
Q. All right. Is there proof, has it been proven that there has been a uniform rate of radioactive decay over time?
A. I think to the extent that different-decay schemes give us the same age for things like lunar rocks and meteorites when we apply those different types of radiometric dating tools that have different decays from different elements with different decay constants, sometimes different by an order of magnitude or more, we get the same answer on bodies that have simple history. And that kind of coincidence would not be true if those rates had changed with time because we have clocks ticking at different rates.
For example, the halflife of Rubidium-87 is about 48.8 billion years. And the halflife of Neodymium-147 is about 100 billion years. Those clocks are ticking at different rates and yet, they give us the same time. They give us the same answer. And if those rates had changed, we would not get the same answer. That's the nature of the proof.
Q. Can you envision a scenario where the rates would have — if they have changed, you could still come up with those coincidences that you mentioned?
A. No.