Did Madalyn Murray O'Hair Get Prayer Out of School?

The outspoken atheist has long been a target of the Religious Right

Teen Praying in Class
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An outspoken atheist, Madalyn Murray O’Hair, has long been an object of hatred and fear for the Religious Right. It is thus not surprising that they placed the blame on her alone for the elimination of state-sponsored prayers and Bible readings in public schools. O’Hair herself certainly didn’t do anything to disabuse people of that notion, and in fact, often encouraged it.

O'Hair's Role in the Demise of School Prayer

The truth of the matter is that her role in the relevant Supreme Court cases really wasn’t that large -- had she never existed or had her case never come up, it is likely that the outcome would have been the same and the Christian Right would have had to find someone else to play the role of their boogeyman.

With regards to school prayer, Madalyn Murray O’Hair played no role at all -- not even a minor one. The decision which prohibited the state from sponsoring specific prayers in public schools was ​Engel v. Vitale, decided in 1962 by an 8-1 vote. The people who challenged the laws establishing such prayers were a mixture of believers and nonbelievers in New Hyde Park, New York, and O’Hair was not among them.

Supreme Court Rulings

One year later, the Supreme Court reached a decision on a related matter; the state-sponsored Bible readings which occurred in many schools. The primary case was Abington School District v. Schempp, but consolidated along with it was another case, Murray v. Curlett. It was this latter case which involved O’Hair, at the time simply Madalyn Murray. Thus, her efforts did play a role preventing the state from deciding what sorts of Bible readings students would have in public schools; but even without her, the Schempp case would still have gone forward, and the Supreme Court likely would have reached the same ruling.

The entire process of removing official religious exercises from public schools started much earlier with the McCollum v. Board of Education case decided on March 8, 1948. At that time, the Supreme Court held that public schools in Champaign, Illinois, violated the separation of church and state by allowing religious groups to teach religious classes to students in the schools during the school day. The decision was defined around the country, and the eminent theologian Reinhold Niebuhr stated that this would lead to public education becoming completely secular.

He was right. There was a time when public education included a strong Protestant flavor, something which made matters very difficult for Catholics, Jews, and members of both minority religions and minority Protestant traditions. The gradual removal of this bias through the latter half of the 20th century has been a very positive development because it has expanded the religious liberty of all public school students.

O'Hair vs. the Christian Right

Madalyn Murray O’Hair played a role in this process, but she was not the sole or even the primary force behind it. Christian Right complaints about O’Hair allows them to attack the various court rulings by associating them with atheists, still one of the most reviled groups in America, without ever having to explain what is wrong with the rulings in the first place.

It is worth noting that, in his failed arguments before the Supreme Court in the case of Lee v. Weisman, U.S. Solicitor General Kenneth Starr openly accepted the validity of the Engel decision. When questioned by the justices, Starr clearly stated that classroom prayer compelled, led, or endorsed by a teacher is inherently coercive and unconstitutional. People who understand the law and the principle of religious liberty realize that the state has no business dictating prayer or readings from any group’s religious scriptures, but much of this hasn’t filtered down to everyone yet.

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Cline, Austin. "Did Madalyn Murray O'Hair Get Prayer Out of School?" Learn Religions, Sep. 4, 2021, learnreligions.com/madalyn-murray-ohair-and-school-prayer-myth-249687. Cline, Austin. (2021, September 4). Did Madalyn Murray O'Hair Get Prayer Out of School? Retrieved from https://www.learnreligions.com/madalyn-murray-ohair-and-school-prayer-myth-249687 Cline, Austin. "Did Madalyn Murray O'Hair Get Prayer Out of School?" Learn Religions. https://www.learnreligions.com/madalyn-murray-ohair-and-school-prayer-myth-249687 (accessed March 29, 2023).