Edwards v. Aguillard, 482 U.S. 578 (1987), was a landmark legal case in which the Supreme Court of the United States held that a Louisiana statute mandating the teaching of "creation science" alongside evolution in public schools was unconstitutional. The Court determined that the law violated the Establishment Clause of the First Amendment, which prohibits the government from making any law "respecting an establishment of religion."
Background
In 1981, the Louisiana State Legislature passed the "Balanced Treatment for Creation-Science and Evolution-Science in Public School Instruction Act." The Act did not require the teaching of either evolution or creation science, but it stipulated that if one was taught, the other must be taught as well. Supporters of the law argued that it was intended to protect academic freedom and provide students with a comprehensive view of origins.
A group of parents, teachers, and religious leaders filed suit against Louisiana Governor Edwin Edwards, challenging the constitutionality of the Act. They argued that "creation science" was not a scientific theory but rather a religious belief, and that the law was an attempt to advance a particular religious viewpoint in public schools.
The Court's Decision
The case eventually reached the Supreme Court, which issued its ruling on June 19, 1987. In a 7–2 decision, the Court struck down the Louisiana law. Justice William J. Brennan Jr. wrote the majority opinion, applying the three-pronged "Lemon test" established in Lemon v. Kurtzman (1971) to determine if the legislation violated the Establishment Clause.
The Lemon test requires that a law must:
- Have a secular legislative purpose;
- Not have a primary effect that either advances or inhibits religion;
- Not foster excessive government entanglement with religion.
The Court focused on the first prong, concluding that the Act lacked a clear secular purpose. While the state claimed the law was designed to promote academic freedom, the Court found that it actually served to restrict the curriculum by disallowing the teaching of evolution unless creation science was included. The majority held that the primary purpose of the Act was to endorse a religious doctrine by providing "persuasive advantage to a particular religious doctrine."
Dissenting Opinion
Justice Antonin Scalia, joined by Chief Justice William Rehnquist, authored a dissenting opinion. Scalia argued that the Court should accept the state's stated secular purpose of academic freedom at face value. He contended that the term "creation science" could be interpreted as a collection of scientific data and that the legislature's intent was not necessarily to promote religion, but to ensure that students were exposed to alternative theories.
Significance
Edwards v. Aguillard built upon the precedent set in Epperson v. Arkansas (1968), which had overturned a state law prohibiting the teaching of evolution. The ruling in Edwards effectively ended the legal requirement for "balanced treatment" of creationism in public science classrooms across the United States.
The case had a lasting impact on how science curriculum is structured in public education, reinforcing the legal distinction between scientific theory and religious belief. In subsequent decades, the ruling influenced other legal challenges regarding the teaching of "intelligent design," most notably in the federal district court case Kitzmiller v. Dover Area School District (2005).
