國教
The interpretation of the Establishment Clause of the First Amendment up to that time was that Congress could not establish a particular religion as the "State" religion. Consequently, the Court held that the ban on the teaching of evolution did not violate the Establishment Clause, because it did not establish one religion as the "State religion." As a result of the holding, the teaching of evolution remained illegal in Tennessee, and continued campaigning succeeded in removing evolution from school textbooks throughout the United States.