Although «secular humanism» is a term used
most frequently by Protestant Fundamentalists, it was Justice Hugo Black» in
delivering the opinion of the United States Supreme Court in a 1961 case, Torcaso v. Watkins» who distinguished between «religions based on a belief in the existence of God» and «religions founded on different beliefs,» such as «Buddhism, Taoism,
Ethical Culture, Secular Humanism, and others.»
Though ABA President William C. Hubbard does not mention ethics rule changes in the commission's primary task of identifying the
most innovative practices being used in the U.S. to
deliver legal services, some of those practices have been questioned as possible
ethical breaches.