Summary of Edwards v. Aguillard, 482 U.S. 578 (1987)
Facts: The Law defines both creationism and evolution, and provides that if either is taught in LA’s public schools, then so to the other.
Issue(s): Whether LA’s law requiring balanced treatment of Creationism and Evolution in public schools violates the Est Cl?
Holding: Yes, Act advances a religious doctrine by requiring exclusion of Evolutionary science or presentation of a religious viewpoint that reject evolution completely. Its primary purpose is to chg the scientific curriculum of public schools to further a particular religious doctrine over evolutionary science, this constitutes an impermissible endorsement of Est Cl. b/c it seeks to use symbolic and financial support of Govt to achieve a religious purpose.
Procedure: Parents, teachers, and religious leaders challenged law in D.Ct, which granted them Summary Judgment. Ct of App Affirmed. U.S.S.Ct Affirmed.
Rule(s): 1st Amend and Lemon Test
Rationale: State action must pass all three prongs of Lemon. Ct increases its attention when regulation pertains to elementary or secondary schools b/c students w/i are impressionable and their attendance is mandatory.
Lemon: If a law was passed for the purpose of endorsing religion, then there is no reason to consider the 2nd and 3rd prongs. Here, no clear secular purpose was identified. Ct of App C: the law was not designed to further the freedom of teachers to teach what they want. Providing a more comprehensive science curriculum does not mean excluding the teaching of evolution or requiring the teaching of creation.
Govt articulation of secular purpose must be sincere before deference is given. During the legis hx the purpose of this law was to narrow the science curriculum. Requiring schools to teach creationism w/ evolution does not advance academic freedom.
Ct of App found that LA did not ban the teaching of any scientific theory. Fairness is not the goal of this law. It establishes a preference for creationism b/c there are no guidelines for evolution, only for creationism; research services are provided only for creationism; only creation scientists are allowed to served on resource panel; and prohibits schools from discriminating only against creationsim, and fails to protect evolutionist or other non-creation theories.
If the purpose was to maximize the educational value within the scientific instruction all scientific theories would have received a lift. It doesn’t even ensure that creation is taught, it provides a guarantee only if evolution is taught.
DISSENT: Legislative Motive or some religious purpose, where secular purpose exists as well, is not enough to invalidate a law under Est Cl