Epperson v. Arkansas

Background

Susan Epperson, a trained biology teacher in Little Rock, sued after her school adopted a new textbook that included a chapter on human evolution. Arkansas had a 1928 law making it a crime for public-school teachers to teach that mankind descended from a lower order of animals, with possible fine and dismissal. A parent joined the suit. A state chancery court declared the law unconstitutional, but the Arkansas Supreme Court reversed, and the case was appealed to the United States Supreme Court.

Reasoning

The central question was whether a State may bar teaching a scientific theory because it conflicts with particular religious beliefs. The Court held that it may not. Relying on the First Amendment’s ban on laws establishing religion, applied to the States through the Fourteenth Amendment, the majority found that Arkansas’ law singled out evolution for suppression because it conflicted with a particular religious reading of Genesis. The Court reversed the state high court and declared the statute unconstitutional. The opinion discussed vagueness but did not rest the decision solely on that ground.

Real world impact

The decision invalidates Arkansas’ anti-evolution statute and protects public-school teachers who present evolution from criminal punishment and dismissal under that law. It affirms that states may set curricula but may not adopt laws that favor or suppress teachings for religious reasons. The opinion noted that only Arkansas and Mississippi still had similar laws on the books, highlighting the ruling’s practical effect where such laws remained.

Dissents or concurrances

Several Justices agreed with the result but wrote separately. Justice Black warned the case might not present a live controversy and would have relied on vagueness; Justices Stewart and Harlan also concurred in invalidating the law, with Stewart emphasizing vagueness concerns.