Edwards v. Aguillard

Brief Fact Summary. The Supreme Court of the United States (Supreme Court) held that Louisiana’s Creationism Act (the Act) that required evolution be taught if “creation science” was taught and vice versa violated the Establishment Clause of the United States Constitution (Constitution).

Synopsis of Rule of Law. While the Court is normally deferential to the state’s articulation of a secular purpose, it is required that the statement of such purpose be sincere and not without a sham. It is clear that requiring schools to teach creation science with evolution does not advance academic freedom.

Facts. The Act forbids the teaching of evolution in public schools unless accompanied by instruction in “creation science.” No school is required to teach evolution or creation science. If either is taught however, the other must be taught. The Appellees, Aguillard and other parents of children attending Louisiana public schools, Louisiana teachers, and religious leaders (Appellees) challenged the constitutionality of the Act. The District Court held that the Act violated the Establishment Clause of the Constitution either because it prohibited the teaching of evolution or because it required the teaching of creation science with the purpose of advancing a particular religious doctrine. The Court of Appeals affirmed.

Issue. Whether the Act violates the Establishment Clause of the Constitution?

Held. Yes. Judgment of the Court of Appeals affirmed. Lemon’s first prong focuses on the purpose of that animated adoption of the Act. In this case, the Appellants, Edwards and others (Appellants), have identified no clear secular purpose for the Act. The goal of providing a more comprehensive science curriculum is not furthered by either outlawing the teaching of evolution or by requiring the teaching of creationism. While the Supreme Court is normally deferential to the state’s articulation of a secular purpose, it is required that the statement of such purpose be sincere and not without a sham. It is clear that requiring schools to teach creation science with evolution does not advance academic freedom. The Act does not grant teachers the flexibility that they did not already possess to supplant the present science curriculum with a presentation of theories besides evolution, about the origin of life. Here, the purpose of the Act was to restructure the science curriculum to confor
m with a particular religious viewpoint. Therefore, the Act violates the Establishment Clause of the Constitution.

Dissent. There is ample evidence that the majority is wrong in holding that the Act is without secular purpose.
Concurrence. Nothing in this Supreme Court’s decision diminishes the traditionally broad discretion accorded state and local school officials in the selection of the public school curriculum.

Discussion. Since this case took place in the context of a public school, the Supreme Court was less tolerant of governmental sponsorship of religious symbolism.