Fellowship of Humanity v. County of Alameda[1] was a 1957 California Courts of Appeal case in the Fellowship of Humanity, an organization of humanists, sought a tax exemption from Alameda County, California on the ground that they used their property "solely and exclusively for religious worship."
This case was cited by Justice Hugo Black in the decision for Torcaso v. Watkins, in an obiter dictum listing "secular humanism" as being among "religions in this country which do not teach what would generally be considered a belief in the existence of God."
Nonetheless, this case was cited by Justice Black to justify the inclusion of Secular Humanism in the list of religions in his note.
Subsequent cases such as Peloza v. Capistrano School District have clarified that "neither the Supreme Court nor this circuit, has ever held that evolutionism or secular humanism are 'religions' for Establishment Clause purposes."
Unlike the question of tax exemption, Establishment Clause issues rest on whether or not ideas themselves are primarily religious.