Becoming the Most Hated Woman in America: Madalyn Murray O'Hair

On December 8, 1960, Madalyn Murray filed suit in the Superior Court of Baltimore, Maryland, asking the Court to rule unconstitutional required Bible reading and recitation of the Lord's prayer in the city's public schools. She claimed that her son William's First Amendment rights were being violated, and that he was being discriminated against because he refused to participate in his school's morning religious exercise. Defeated in the lower courts, she appealed what became Murray v. Curlett to the United States Supreme Court, where it was joined with a similar case out of Pennsylvania, Schempp v. School District of Abington Township. On June 17, 1963, the Court found in favor of the Murrays and the Schempps, and by a margin of eight to one, declared that the Maryland and Pennsylvania laws violated the Establishment Clause of the First Amendment. Although not having occurred without some warning or precedent in the courts [see Engel v. Vitale (1962)], much of the nation was stunned and angry. Whereas the Schempps, who had taken a low profile throughout their case, shunned the limelight, Murray seized it. She took credit for single-handedly banning Bible reading and prayer from the nation's public schools. She overstated the case, but Americans, searching for someone to blame, were only too willing to accept her claim. When she chose to push for the further separation of church and state-challenging the words "under God" in the Pledge of Allegiance, "In God We Trust" on American currency, the taxexempt status of religious organizations, the Pope's performing mass on the Washington mall, and US astronauts' reading the Bible in space-she became the most visible of American atheists. Indeed, she became "the most hated woman in America." The details of the life of Madalyn Murray-who, upon her second marriage in 1968, became better known as Madalyn Murray O'Hair-are fascinating. But even more fascinating is the story of how Americans responded to her. Similarly, her ideas on religion are interesting, but no more interesting than how those ideas related to American culture from the Cold War to the end of the twentieth century. As her son William, who later broke with her over her atheist activities, wrote: "In reality my mother did not create the time, the time created her" (Duggan Cl). Madalyn Murray O'Hair struggled against the cultural and political consensus on many subjects, especially religion. Not being content to personally and quietly reject the idea of belief in God, she launched a crusade against it and brought atheism out of the study and shadows of society to the masses. Nevertheless, Madalyn Murray O'Hair has never been the subject of any comprehensive study. Aside from several vitriolic attacks and a few attempts to defend her, no one has seriously examined her life, her behavior, and the historical context of her actions. In this article, I take up the question: Why did she persist-even glory in-taking on America's religious establishment and mainstream values, when it meant incurring the wrath of the nation? I conclude that it was both a personal and contextual matter. To show that, I make particular use of Madalyn Murray O'Hair's diaries and personal papers, which, though still in private hands, were made available to me. It is the first time that they have been used for this purpose. In order to avoid confusion over her various name changes-Mays, Roths, Murray, O'Hair-I have often referred to her as Madalyn. I have done this for clarity and do not mean to make this formidable figure appear diminutive. The American Atheist Madalyn Murray O'Hair was intelligent and well-educated, both formally and informally. Her use of foul language shocked people, but her message was always accessible to even the minimally educated. And she made effective use of the media. By her personal behavior- somewhat exaggerated by her enemies and the press- she personified what people expected of atheists. …