Supreme Court Sets Precedent on Establishment Clause: Louisiana's Creationism Act Found Unconstitutional

Supreme Court Sets Precedent on Establishment Clause: Louisiana's Creationism Act Found Unconstitutional

Introduction

In Edwards v. Aguillard, 482 U.S. 578 (1987), the United States Supreme Court addressed the constitutionality of Louisiana's "Creationism Act." This Act mandated that if the theory of evolution was taught in public schools, it must be accompanied by instruction in "creation science." The key issue revolved around whether the Act violated the Establishment Clause of the First Amendment by endorsing a particular religious viewpoint. The parties involved included Louisiana state officials as appellants and a coalition of parents, teachers, and religious leaders as appellees challenging the statute.

Summary of the Judgment

The Supreme Court affirmed the decision of the Fifth Circuit Court of Appeals, holding that Louisiana's Creationism Act was facially invalid under the Establishment Clause of the First Amendment. The Court found that the Act lacked a clear secular purpose and instead advanced a particular religious doctrine. By requiring the teaching of creation science alongside evolution, the Act effectively endorsed a specific religious belief, thereby violating constitutional principles separating church and state.

Analysis

Precedents Cited

The Court heavily relied on precedents that reinforce the separation of church and state, notably:

  • LEMON v. KURTZMAN, 403 U.S. 602 (1971): Established the Lemon test, a three-pronged evaluation to determine Establishment Clause violations.
  • EPPERSON v. ARKANSAS, 393 U.S. 97 (1968): Struck down an Arkansas statute banning the teaching of evolution, emphasizing the preservation of a secular curriculum.
  • Abington School District v. Schempp, 374 U.S. 203 (1963): Invalidated mandatory Bible readings in public schools.
  • WALLACE v. JAFFREE, 472 U.S. 38 (1985): Reinforced the requirement for a clear secular purpose in laws affecting public education.

These cases collectively underscore the judiciary's role in maintaining religious neutrality in public institutions, especially in education.

Legal Reasoning

The Court applied the Lemon test, assessing the Act on three criteria:

  • Secular Purpose: The Act's stated purpose was to "protect academic freedom." However, the Court found that the legislative history revealed an ulterior motive to discredit evolution by promoting creation science, a belief tied to specific religious doctrines.
  • Principal Effect: The Act advanced religion by mandating the teaching of creation science alongside evolution, thereby endorsing a particular religious viewpoint.
  • Excessive Entanglement: The Act required the involvement of creation scientists in developing curriculum guides, entangling the state with religious institutions.

The combination of these factors led the Court to conclude that the Act violated the Establishment Clause, as it neither served a genuine secular purpose nor maintained necessary separation between church and state.

Impact

This landmark decision reinforced the judiciary's vigilance in preventing religious doctrines from influencing public education. It set a clear precedent that laws mandating the teaching of religiously motivated theories in public schools are unconstitutional. The ruling has significant implications for future cases where educational curricula intersect with religious beliefs, ensuring that public education remains secular and unbiased.

Complex Concepts Simplified

The Establishment Clause

The Establishment Clause is part of the First Amendment, prohibiting the government from establishing an official religion or favoring one religion over others. In essence, it ensures government neutrality in religious matters.

The Lemon Test

Derived from LEMON v. KURTZMAN, the Lemon test comprises three criteria to evaluate whether a law violates the Establishment Clause:

  • Secular Purpose: The law must have a genuine non-religious objective.
  • Principal Effect: The law's primary impact should neither advance nor inhibit religion.
  • Excessive Entanglement: The law should not create undue government involvement with religious institutions.

All three prongs must be satisfied for a law to be constitutionally valid under the Establishment Clause.

Conclusion

The Supreme Court's decision in Edwards v. Aguillard serves as a pivotal reinforcement of the Establishment Clause's intent to maintain a secular public education system. By identifying the Creationism Act as unconstitutional, the Court emphasized the necessity for clear secular purposes in legislation affecting education and upheld the principle that public institutions must remain neutral regarding religious doctrines. This ruling not only curtails attempts to intertwine religion with public education but also safeguards the academic integrity and unbiased dissemination of scientific knowledge in schools.

Case Details

Year: 1987
Court: U.S. Supreme Court

Judge(s)

Lewis Franklin PowellAntonin ScaliaSandra Day O'Connor

Attorney(S)

Wendell R. Bird, Special Assistant Attorney General of Georgia, argued the cause for appellants. With him on the briefs were A. Morgan Brian, Jr., and Thomas T. Anderson, Special Assistant Attorneys General, Kendall L. Vick, and Patricia Nalley Bowers, Assistant Attorney General of Louisiana. Jay Topkis argued the cause for appellees. With him on the brief was John DiGiulio, Samuel I. Rosenberg, Allen Blumstein, Gerard E. Harper, Jack D. Novik, Burt Neuborne, Norman Dorsen, John Sexton, and Ron Wilson. Briefs of amici curiae urging reversal were filed for the Catholic League for Religious and Civil Rights by Steven Frederick McDowell; for the Christian Legal Society et al. by Michael J. Woodruff, Kimberlee W. Colby, Samuel E. Ericsson, and Forest D. Montgomery; and for Concerned Women for America by Michael P. Farris and Jordan W. Lorence. Briefs of amici curiae urging affirmance were filed for the State of New York et al. by Robert Abrams, Attorney General of New York, O. Peter Sherwood, Solicitor General, Paul M. Glickman, Jane Levine, Suzanne Lynn, and Marla Tepper, Assistant Attorneys General, and Neil F. Hartigan, Attorney General of Illinois; for the American Association of University Professors et al. by Ann H. Franke, Jacqueline W. Mintz, and Sheldon E. Steinbach; for the American Federation of Teachers, AFL-CIO, by Bruce A. Miller and Stuart M. Israel; for the American Jewish Congress et al. by Marvin E. Frankel, Marc D. Stern, and Ronald A. Krauss; for Americans United for Separation of Church and State et al. by Lee Boothby, Samuel Rabinove, Richard T. Foltin, and James M. Parker; for the Anti-Defamation League of B'nai B'rith et al. by Ruti G. Teitel, Justin J. Finger, Jeffrey P. Sinensky, and Steven M. Freeman; for the National Academy of Sciences by Barry H. Garfinkel and Mark Herlihy; for the New York Committee for Public Education and Religious Liberty by Leo Pfeffer; for People for the American Way et al. by Timothy B. Dyk, A. Douglas Melamed, and Kerry W. Kircher; for the Spartacist League et al. by Rachel H. Wolkenstein; and for 72 Nobel Laureates et al. by Walter B. Slocombe. Briefs of amici curiae were filed for the Rabbinical Alliance of America et al. by John W. Whitehead and Larry L. Crain; and for Reverend Bill McLean et al. by Philip E. Kaplan.

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