The First Amendment to the United States Constitution states, “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.” Few Constitutional tenets have proved to be more controversial.

On February 26, 1963, the United States Supreme Court was required to apply the principles of the amendment to a challenge brought to them by the most famous American atheist of the twentieth century, Madalyn Murray O’Hair. The Court’s decision on whether to uphold Murray’s plea to ban the required reading of biblical passages or prayers in public schools would have significant repercussions for millions of American families.

Context: Communism and Atheism in Cold War America

Following the end of the Second World War and the growth of tensions between the United States and the Soviet Union, American propaganda sought to shape the average citizen’s view of the communist threat. One of the most successful ways this was achieved was to make communism synonymous with atheism, and specifically with an immoral, radical brand of unbelief. Atheism at once became something foreign and dangerous to the faith-based sensibilities of believing Americans. Senator Joseph McCarthy spearheaded activities and public policies that resulted in a simple equation: true Christianity necessitated patriotism and anticommunism.  Although zealous anticommunism had declined slightly by the early 1960s, Madalyn Murray O’Hair was still operating in a society in which atheism was seen as having a poisonous affect on traditional American culture.

Sowing the Seeds of Atheism

Murray was born in Pittsburgh, Pennsylvania, on April 13, 1919. While she was brought up within the Presbyterian Church, she soon began to question the truth and morality of faith-based beliefs. Ted Dracos, one of her biographers, describes an “antiepiphany” she experienced in 1945 during a severe thunderstorm. Pregnant with her first child, Murray declared to her family that she was going outside to “challenge God to strike me and this child dead with one of those lightning bolts.” She took pleasure in the fact that she was not struck down, despite violently cursing and bating God.  This event set a precedent for numerous dramatic and attention-seeking decisions she would make later in her life, nearly all of which were facilitated by her abhorrence of religion.

Murray v. Baltimore School Board

The recitation of religious texts had strong historical precedents in the public schools of the United States, evidenced most clearly by the writings of Horace Mann in the 1840s, the earliest and most successful supporter of public schools. Although Mann suggested that his educational model was a secular one, he in fact argued strongly for the use of the Bible as a foundational text for students. For Mann, religious instruction in schools was only undesirable “when a teacher has no knowledge of the wonderful works of God, and of the benevolence of the design in which they were created; when he has no power of explaining and applying the beautiful incidents in the lives of prophets and apostles, and, especially, the perfect example which is given to men in the life of Jesus Christ.”  For Mann, religious instruction should therefore provide a central part of a child’s education, so long as the teacher is sufficiently knowledgeable of Biblical texts. In his 1844 report, Mann noted that, out of the 308 towns in Massachusetts, only three did not generally use Scriptures in their schools.

It was this deeply rooted educational practice that Murray was ardently attempting to demolish. Murray herself most clearly spelled out her beliefs and aims in a letter to her supporters:

“We are Atheists. As such, we are foes of any and all religions. We want the Bible out of school because we do not accept it as being either holy or an accurate historical document. We want the Lord’s prayer out of school because we doubt the historicity of Jesus Christ and also we do not believe in the efficacy of prayer.”

The regulation of the Baltimore School Board stated, “Each school, either collectively or in classes, shall be opened by the reading, without comment, of a chapter in the Holy Bible and/or the use of the Lord’s Prayer.” Despite the fact that, in 1960, the parents of schoolchildren were granted the write of excusing their child from this reading by providing written permission, Murray continued to take offense at the still pervasive practice of group prayer.

Although she lost her initial battle in the Maryland courts, she won the right to take her appeal to the Supreme Court. There had been previous court hearings concerning religious practices in schools but, thanks to Murray, none had commanded the same level of public interest and press coverage.

On June 17, 1963, the Supreme Court issued its ruling which upheld Murray’s appeal against Maryland’s educational system, with huge consequences. Despite public sympathy with the sentiment, “The Bible Better in School than in Court,” the Justices ruled that mandatory religious practices in public schools were unconstitutional. More than forty percent of school districts in the United States were now required to make significant alterations to their long-standing daily routines.  Although the Murray case was joined with a similar case from Pennsylvania, issued by a Unitarian family, Murray was able to direct all of the attention that resulted from the ruling to herself and her family.

The Oral Arguments from the Pennsylvania case, Abington v. Schempp, can be heard here.

She publicized her victory as a triumph against the oppressive hegemony of the church in Christian society. Unsurprisingly, she achieved celebrity status, though much of the attention was violently antagonistic. Life Magazine would later describe Murray as “The Most Hated Woman in America,” a title which she relished.

Other Legal Battles

Murray, through her various court appearances and public speeches, had become a savant at shaping her public image. She was the first guest on the Phil Donahue Show, and was combative from the start. In an audience made up primarily of middle-class women, she provoked angry rebukes with her antitheist barbs.

The full show can be seen here.

She also continued to fight religion in the courts. In 1969, Murray asked Federal courts to stop United States astronauts from reading the Bible in space. A New York Times article, “Faith in Space,” expressed the popular opinion that Murray was arguing on an issue that “impresses us as least a matter for earthly decree.”  In the judgement of the newspaper, a federal mandate supporting or banning the reading of the Bible in space “would breach the constitutional separation of church and state, not reinforce it.”  Although she would not win this court case, her unending fight against religious influence in the public sphere of American society would keep her in the news. Why, then, have modern atheist movements largely ignored her?

O’Hair and Atheism in American History

On November 19, 2011, Republican candidate Newt Gingrich was asked in a primary debate in Des Moines, Iowa, whether he thought that an atheist could ever occupy the White House.

“No,” he replied, “if you said to me that we were electing somebody who believed that they by themselves were strong enough to be President of the United States, I would tell you that person terrifies me because they completely misunderstand how weak and how limited any human being is.”

A month later, when asked a similar question in a debate in Las Vegas, Gingrich answered: “How can you have judgement if you have no faith? How can I trust you with power if you don’t pray?” The resounding applause that greeted both of these statements highlights the uncomfortable – often-hostile – relationship between modern American politics and anti-religious thought. Indeed, this tension has been quantified in recent national surveys, demonstrating to a remarkable extent the disdain with which a majority of Americans hold atheists in their society. A PEW Research poll in June 2011 showed that, for those surveyed, atheists were approximately as trustworthy as rapists were.  Atheist history, largely as a result of these stereotypical views of the atheist as immoral, faces the same problems as, to give a contemporary example, gay history. The taboo surrounding these subjects – particularly within the United States – has provided cultural obstacles to the construction of comprehensive histories of these often prosecuted groups.

The growth of the “New Atheism” movement in the twenty first century has sought to rectify these historiographical problems, by seeking to illustrate the historical roots of atheistic organization. Yet, considering her very public role as the figurehead of American Atheism over a period of decades, Murray has been almost exclusively omitted from celebrations of atheist movements in America. She is, for example, conspicuous only by her absence in a recent collection of the work of prominent female freethinkers.

Madalyn Murray O’Hair’s abrasive and aggressive brand of public atheism represented a departure both from her predecessors and successors in the atheist movement in the United States. Robert Ingersoll, the “Great Agnostic” of the late nineteenth century, was a highly respected lawyer who sought to facilitate polite discourse with his opponents. Similarly, the “New Atheist” movement is spearheaded by a group of authors, scientists, and philosophers attempting to strengthen the role of atheism through intellectual arguments and debates.

Four leading public intellectuals head the “New Atheism” Movement.

In this context, Murray represents something of an anomaly, a mis-fit in the wider history of American atheism. Yet, she deserves to be acknowledged. If her constant legal wrangling and penchant for public controversy did little for the public image of organized atheism, it at least raised public consciousness of anti-religious thought, perhaps laying the foundations to the growth of atheism today.


It is perhaps a shame that Murray is remembered most due to the nature of her death. In August, 1977, Murray, her son and her granddaughter all disappeared from their home in Austin, Texas. It would be weeks before the police discovered their brutally deformed remains in a nearby ranch. Despite this grisly conclusion to her life, Murray remained strong to her principles and beliefs, and fully utilized the democratic justice system in the United States to achieve what she saw as constitutional equality in the face of almost complete public antipathy.

For more information:

  1. Bryan F. Le Beau, The Atheist: Madalyn Murray O’Hair (New York: New York University Press, 2003), 62 
  2. For a study of how Americans perceived the Cold War as a religious war, in which “God had called the United States to defend liberty in the world,” see William Inboden, Religion and American Foreign Policy, 1945-1960: The Soul of Containment (New York: Cambridge University Press, 2008).
  3. Ted Dracos, Ungodly: The Passions, Torments, and Murder of Atheist Madalyn Murray O’Hair (New York: Free Press, 2003), 14-15 
  4. Horace Mann, “Annual Report on Education, 1843” in Mann, Annual Reports of the Secretary of the Board of Education of Massachusetts for the Years 1839-1844 (Boston: Lee and Shepard Publishers, 1891), 344-345 
  5. Le Beau, The Atheist, 76
  6. New York Times, October 9, 1962
  7. Dracos, Ungodly, 56 
  8. New York Times, August 7, 1969 
  9. New York Times, August 20, 1969. 
  10. This survey was cited in numerous newspapers. See, for example, “Are Atheists Worse than Rapists?”, Chicago Sun-Times, June 29, 2012. Accessed November 14, 2012. The study itself is of course circumstantial, and it would be dangerous to apply these conclusions to American society as a whole. However, the results do strongly indicate the pervasive distaste with which much of American society views the atheistic position. 
  11. A. L. Gaylor (ed.), Women Without Superstition: “No Gods – No Masters” (Madison, WI.: Freedom From Religion Press, 1997).

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