Physical education has been in decline because of the mistaken belief that the body and mind are separate and thus PE does not have much to contribute to mental function (Landers, Maxwell, Butler, & Fagan, 2001). Landers et al. theorized that sports and games present opportunities to develop thinking and reasoning skills because children are naturally inventive (inventing is a high form of thinking) and creative (modifying games to meet circumstances demonstrates a natural creativity).Without adult interference, children formulate rules and strategies, choose sides, and adjudicate disputes. "They learn to cooperate and get along with teammates to optimize team performance, they learn agreed-upon rules and sometimes learn 'set plays' of their own creation or out of a play book" (Landers et al., p. 343). Such unstructured activities make students literate in PE as they construct meaning in social contexts. Landers et al. contended that physical educators need to bear in mind this natural inclination of children when planning the PE curriculum; they also suggested activities that can be used to develop children's multiple intelligences. Skills learned in physical education, they said, "can be generalized beyond physical education and sport examples so that students realize their applicability in other academic subjects and other areas of their lives" (p. 349). PE can then begin to have an impact on students' lives so they can become lifelong learners and lifelong "movers" (Buell & Whittaker, 2001).