Edwards v. Aguillard

The case is significant because it reaffirmed that the advancing of any religious doctrine violates the Establishment Clause of the First Amendment to the U.S. Constitution.

In June of 1987, the Supreme Court voted to reject a law passed by the state of Louisiana. The rejection of this Louisiana law was to set a precedent in religion and freedom of religion-related cases. The Louisiana law required teachers in the state to teach "creationism." Although some people believe creationism, also known as creation science, to be a fact, others believe it to be a theory--a proposed but unverified explanation. In dealing with the case of Edwards v. Aguillard, the High Court had to deal with many issues including creation science, evolution, religion, and education. In the end, the Supreme Court ruled that the Louisiana law violated the Establishment Clause of the First Amendment to the U.S. Constitution. Because of this violation, the law was found to be unconstitutional.

To understand this case one must first understand the Louisiana law. Then one must come to understand how the Supreme Court justices arrived at their decision. The state of Louisiana passed a law it called "The Creationism Act." Under the Creationism Act teachers were required to teach both the theory of evolution and the theory of creation science.

The theory of evolution states that human beings evolved, or came into being gradually, over time. The theory of creation science disagrees with the theory of evolution. Creation scientists believe the origin of life did not happen over time, and that humans did not evolve from lower life forms. Louisiana's Creationism Act said if one theory is taught to students, then both theories must be presented. Challenging the Creationism Act were Louisiana parents, religious leaders, and teachers. A Federal District Court declared that Louisiana's Creationism Act was unconstitutional and both the court of appeals and the U.S. Supreme Court upheld the Federal District Court's decision.

The U.S. Constitution's Establishment Clause prohibits the passage of any law that takes away an individual's freedom of religion, whether that person selects a religion or decides on no religion at all. The question the Supreme Court asked itself was did the passage by the state of Louisiana of its Creationism Act violate the Establishment Clause. Based on its long history dealing with the religion clauses of the First Amendment, the Supreme Court had developed what became known as the Lemon test. The Lemon test allowed the Supreme Court to decide whether or not a certain piece of legislation violated the Establishment Clause.

The Lemon test itself evolved over time. Many cases, including Everson v. Board of Education, Engel v. Vitale, McGowan v. Maryland, Committee for Public Education and Religious Liberty v. Nyquist, and the case lending the test its name--Lemon v. Kurtzman in 1971--among others, provided precedents on which to build the Lemon test. The Lemon test the Supreme Court used to decide whether or not the act violated the clause included the justices' answers to three separate questions. The justices found that the answers to their questions were: 1) Yes, the legislature passed the law with a non-religious purpose. 2) Yes, the primary effect of the law was to advance or inhibit religion. And, 3) Yes, the law created an excessive meshing of religion with government. So, by answering yes to its three part question concerning the violation of the Establishment Clause, the Supreme Court ruled against the passage of the act.

The Supreme Court, in making its decision, brought to light several points about the Creationism Act that were discriminatory. The act required that teachers develop curriculum guides for creationism but not for evolution. The Supreme Court said this was discrimination. The act forbdale local school boards from discriminating against creation=scientists, but not teachers who taught the theory of evolution. The Supreme Court said this was discrimination. And, the High Court noted, the act endorses the creation-science=held religious belief that a supernatural being created human beings. This, the justices agreed, violates the First Amendment to the Constitution.

By challenging the constitutionality of the act in court, the Louisiana parents, teachers and religious leaders participated in what became a landmark case dealing with freedom of and from religion. After the Supreme Court ruled, Louisiana Governor Edwards along with others involved in the educational system in Louisiana agreed not to implement the Creationism Act. In summary, the case is significant because it reaffirmed that the advancing of any religious doctrine violates the Establishment Clause of the First Amendment to the U.S. Constitution.