Most Americans today would have a difficult time naming the man responsible for bringing the recent case to take “Under God” out of the Pledge of Allegiance to the Supreme Court, even though Michael Newdow is arguably America’s most well-known – and most detested – living atheist.
But in the 1960s, no one would have had a hard time remembering the name Madalyn Murray.
Murray was known for her role in the landmark 1963 Supreme Court decision in Murray vs. Curlett, which, combined with Abington vs. Schempp, ended prayer in public schools across the U.S. and turned her into the self-described “most hated woman in America.”
“It is doubtful there is anyone in the United States who does not know the name Madalyn O’Hair,” read the introduction to her 1966 pamphlet, “Why I Am an Atheist.” (O’Hair took the last name of her second husband, Richard O’Hair, when she married him in 1965.)
Life magazine described her in 1964 as “anathema to millions of Americans.”
Today, 10 years after her grisly murder in 1995, the legacy of this controversial activist still influences atheists in America today.
“Madalyn gave legitimacy to the atheist movement,” says Ann Rowe Seaman, author of the recent biography, “America’s Most Hated Woman: The Life and Gruesome Death of Madalyn Murray O’Hair” (Continuum International, 391 pages, $24.95).
“She laid a foundation for atheists coming out of the closet,” agrees Wendy Britton, a former acquaintance of the O’Hair family who organized an August event for atheists in the Seattle area titled “Madalyn Murray O’Hair: What She Stood For and Why Her Ideas Matter Today.”
Born in 1919 to a poor family in Pittsburgh, O’Hair was raised by churchgoing parents but claimed she became an atheist after reading the complete Bible in her early teens.
She became a household name when she contested the required moment of prayer and Bible reading in her son William’s Baltimore-area public school in 1960. The Supreme Court, then under Chief Justice Earl Warren, delivered its 8-1 verdict in favor of O’Hair on June 17, 1963, expanding an earlier school prayer decision in the 1962 Engel vs. Vitale case.
Murray vs. Curlett, along with Abington vs. Schempp, eliminated not only obligatory school prayer but also mandatory Bible readings in public schools. Though the Schempp case got top billing, O’Hair quickly became a hero among secular Americans.
“The Schempps did not want to be in the limelight,” O’Hair biographer and University of Missouri-Kansas City dean Bryan LeBeau said in a 2004 interview.
“Madalyn walked right out to the front of the Supreme Court building, her son by her side, and grabbed the microphone from the press and insisted that this was a major case and she was responsible for it. She took credit and then went on to say that she wasn’t done, that she was going to go on and challenge all kinds of other church-state matters.”
Undeterred by the backlash (she received death threats and was the victim of vandalism long after the 1963 decision), O’Hair continued to insert herself into church and state legal battles as the country’s atheist-in-chief.
“I am an Atheist,” she wrote in the “Why I Am an Atheist” pamphlet. “I am a bit more than that – an Atheist. I am, in fact, the Atheist. The Atheist who made Americans stop to take a little stock of their accepted values.”
Later in 1963, O’Hair founded American Atheists, which remains one of the most activist atheist groups in the U.S. today. She used her platform as president of the organization to launch a number of other separation of church and state cases.
None, however, was as successful or as notorious as Murray vs. Curlett. In late 1963, she unsuccessfully sued the city of Baltimore to eliminate the city’s tax exemptions for churches. She also challenged the school board of Baltimore to remove “Under God” from the Pledge of Allegiance and filed suit over Maryland’s “moment of silence” law, also without success.
“Her suits might have failed,” says biographer Seaman, “but because she was so outrageous, they put her in the spotlight. She was always colorful and good copy for newspapers and TV. She knew how to get people stirred up. She knew how to say outrageous things that would get a furious reaction.”
Her brazen style got her a great deal of press coverage, but also earned her enemies – among atheists as well as Christians.
“I found more animosity among the atheist community toward her (than among Christians),” Seaman says. “They felt like she had a golden opportunity and had blown it.
“She couldn’t delegate authority, she was mean to her followers, she was unappreciative of their sacrifices. They worked for a pittance because they believed in her cause, and she would curse them and write terrible things about them and fire them.”
There are a lot of “people who hate her and who think she’s done more harm than good for the cause of atheism,” says Marcus Donovan, president of Seattle Atheists, an atheist social and activism group. “They see her as the atheist equivalent of a Christian fundamentalist.”
O’Hair’s death was as dramatic and controversial as her life. In August 1995, at age 76, she mysteriously disappeared, along with her son and granddaughter.
When they were first reported missing, many thought the trio had run off with funds stolen from American Atheists; about $500,000 in gold coins was also missing from the organization. It wasn’t until six years later, in early 2001, that their remains were discovered on a 5,000-acre Texas ranch.
The killings were particularly grisly – O’Hair had been dismembered and her body was only identified by matching the serial number on her metal hip replacement.
David Waters, a former employee of O’Hair’s organization, was convicted of the plot to extort and murder them. He died in prison of cancer in early 2003.
Whether O’Hair’s cases had a marked effect on future legal battles, her unabashed atheism in a period marked by religious zeal during the Cold War made nonbelievers feel more at home in the U.S.
Says Donovan: “Even though she wasn’t liked, she got people talking, and for that she deserves a place in history.”
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