Edwards v. Aguillard

Background

The dispute involved a Louisiana law that required public schools to give "balanced treatment" to "creation science" whenever evolution was taught. The law did not force schools to teach either theory, but conditioned teaching evolution on also teaching creation science. Parents, teachers, and religious leaders sued, and lower federal courts found the law unconstitutional and entered summary judgment against the State. Louisiana officials defended the law as protecting academic freedom.

Reasoning

The Supreme Court applied the three-part Lemon test used in past Establishment Clause cases, focusing on whether the legislature adopted the law with a secular purpose. The Court reviewed the statute’s text, contemporaneous legislative history, and related materials and found the legislative sponsor and witnesses equated "creation science" with belief in a supernatural creator. The statute provided special supports for creation science and limited protections for teachers favoring it. The Court concluded the Act's primary purpose was to advance a particular religious belief, so it violated the First Amendment and affirmed the lower courts’ summary judgment.

Real world impact

The ruling prevents Louisiana from using public-school classrooms to require teaching a religious view as science. Public school officials, teachers, and students are affected because the State may not condition teaching evolution on teaching a theory tied to particular religious doctrines. The Court noted that legitimate teaching of different scientific theories is possible if done with a clear secular intent and not designed to advance religion. State officials had already agreed not to implement the law while the case proceeded.

Dissents or concurrances

Some Justices agreed with the result but emphasized different points. Justice Powell (joined by Justice O'Connor) and Justice White accepted the conclusion based on the record but noted deference to local school decisionmaking and legislative history. Justice Scalia (joined by the Chief Justice) dissented, arguing the record showed a sincere secular purpose to protect students from indoctrination and criticizing the Court’s reliance on legislative motive.