Edwards v. Aguillard

Brief Fact Summary. This case arose from a parental challenge to the Creation Act (the Act), which called for the teaching of “creation science” alongside evolution in Louisiana schools.

Synopsis of Rule of Law. “Creation Science”, as an alternative to the theory of evolution has religious undertones and the teaching of its doctrine violates the Establishment Clause of the First Amendment of the United States Constitution (Constitution).

Facts. The Respondents, brought suit challenging the constitutionality of the Act in District Court, on the grounds that the Act’s mandate that “Creation Science” be taught alongside the theory of Evolution was facially unconstitutional. The District Court granted summary judgment in favor of the Respondents, which was affirmed by the Fifth Circuit Court of Appeals.

Issue. The issue in this case is whether the Act is facially invalid as a violation of the Establishment Clause of the First Amendment of the Constitution.

Held. Affirmed.
In affirming the opinions of the lower courts, the Supreme Court of the United States held that the State’s interest in providing a more comprehensive science curriculum does not justify the mandate that “Creation Science” be taught alongside Evolution.
The Supreme Court held that if Louisiana’s true purpose were to encourage diverse scientific education, it would have encouraged the teaching of all origin-related theories, rather than mandating that “Creation Science” be taught alongside another theory.
Thus, the Supreme Court held the Act to be an endorsement of religious doctrine in violation of the Establishment Clause.

Dissent. Justice Antonin Scalia (J. Scalia) dissented, noting that he would remand for further consideration as to what “Creation Science” is, because a question of material fact exists.
Concurrence. Justice Lewis Powell (J. Powell) concurred, noting that the theory of Creationism stemmed from biblical scripture and was, on-its-face, an abridgment of the Establishment Clause, were it to be taught in public schools.

Discussion. When dealing with the Establishment Clause, it is important to understand that there is little room for interpretation. If a statute facially requires respect of any religious institution, it will not be upheld against constitutional scrutiny.