Daniel v. Waters
Encyclopedia
Daniel v. Waters was a 1975 legal case in which the United States Court of Appeals for the Sixth Circuit
struck down Tennessee
's law regarding the teaching of "equal time" of evolution
and creationism
in public school science
classes because it violated the Establishment clause of the US Constitution.
The plaintiffs were school teachers supported by the National Association of Biology Teachers
.
, which established that such laws were to be held in violation of the constitutional separation of Church and State
. The creationist movement reacted to the decision by turning to the promotion of the teaching of creationism in school science classes as equal to evolutionary theory.
Following this ruling, creationism was stripped of all overt biblical references and was then renamed creation science
. Several states then passed new legislation which required that this be given equal time with teaching of evolution. This came to court as McLean v. Arkansas
(1982), which resulted in a detailed ruling that it was similarly unconstitutional to teach this in public school science classes. This was a District level ruling and, while setting a persuasive precedent
, it was only a binding precedent
in the relevant district. It was not until Edwards v. Aguillard
(1987), a similar case in Louisiana, was appealed to the U.S. Supreme Court that creation science was ruled unconstitutional at the federal level, which resulted in its removal from public school science classes nationwide. The reaction from the creationist forces would be to create the new concept of intelligent design
specifically in order to circumvent this ruling.
United States Court of Appeals for the Sixth Circuit
The United States Court of Appeals for the Sixth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Kentucky* Western District of Kentucky...
struck down Tennessee
Tennessee
Tennessee is a U.S. state located in the Southeastern United States. It has a population of 6,346,105, making it the nation's 17th-largest state by population, and covers , making it the 36th-largest by total land area...
's law regarding the teaching of "equal time" of evolution
Evolution
Evolution is any change across successive generations in the heritable characteristics of biological populations. Evolutionary processes give rise to diversity at every level of biological organisation, including species, individual organisms and molecules such as DNA and proteins.Life on Earth...
and creationism
Creationism
Creationism is the religious beliefthat humanity, life, the Earth, and the universe are the creation of a supernatural being, most often referring to the Abrahamic god. As science developed from the 18th century onwards, various views developed which aimed to reconcile science with the Genesis...
in public school science
Science
Science is a systematic enterprise that builds and organizes knowledge in the form of testable explanations and predictions about the universe...
classes because it violated the Establishment clause of the US Constitution.
The plaintiffs were school teachers supported by the National Association of Biology Teachers
National Association of Biology Teachers
The National Association of Biology Teachers is an American-based scholarly society that "empowers educators to provide the best possible biology and life science education for all students."...
.
Background
Various state laws prohibiting the teaching of evolution had been introduced during the 1920s. These laws were challenged in 1968 in the case Epperson v. ArkansasEpperson v. Arkansas
Epperson v. Arkansas, 393 U.S. 97 , was a United States Supreme Court case that invalidated an Arkansas statute that prohibited the teaching of human evolution in the public schools...
, which established that such laws were to be held in violation of the constitutional separation of Church and State
Separation of church and state
The concept of the separation of church and state refers to the distance in the relationship between organized religion and the nation state....
. The creationist movement reacted to the decision by turning to the promotion of the teaching of creationism in school science classes as equal to evolutionary theory.
The act
The Tennessee law stated, "Any biology textbook used for teaching in the public schools, which expresses an opinion of, or relates a theory about origins or creation of man and his world shall [give] . . . an equal amount of emphasis on . . . the Genesis account in the Bible." (Public Acts of Tennessee, 1973, Chapter 377, cited in LaFollette, 1983, p. 80)The ruling
The Federal District Court ruling was that the Tennessee law was "a clearly defined preferential position for the Biblical version of creation as opposed to any account of the development of man based on scientific research and reasoning. For a state to seek to enforce such preference by law is to seek to accomplish the very establishment of religion which the First Amendment to the Constitution of the United States squarely forbids." (US District Court, Daniel v Waters, 1975)Effect of the ruling
The ruling did not prevent the Bible from being taught in public schools in an appropriate way. The Court stated (quoting from a prior decision): "While study of religions and of the Bible from a literary and historic viewpoint, presented objectively as part of a secular program of education, need not collide with the First Amendment's prohibition, the State may not adopt programs or practices in its public schools or colleges which "aid or oppose" any religion."Following this ruling, creationism was stripped of all overt biblical references and was then renamed creation science
Creation science
Creation Science or scientific creationism is a branch of creationism that attempts to provide scientific support for the Genesis creation narrative in the Book of Genesis and disprove generally accepted scientific facts, theories and scientific paradigms about the history of the Earth, cosmology...
. Several states then passed new legislation which required that this be given equal time with teaching of evolution. This came to court as McLean v. Arkansas
McLean v. Arkansas
McLean v. Arkansas Board of Education, 529 F. Supp. 1255, 1258-1264 , was a 1981 legal case in Arkansas.A lawsuit was filed in the United States District Court for the Eastern District of Arkansas by various parents, religious groups and organizations, biologists, and others who argued that the...
(1982), which resulted in a detailed ruling that it was similarly unconstitutional to teach this in public school science classes. This was a District level ruling and, while setting a persuasive precedent
Persuasive precedent
Persuasive precedent is precedent or other legal writing that is related to the case at hand but is not a binding precedent on the court under common law legal systems such as English law. However, persuasive authority may guide the judge in making the decision in the instant case...
, it was only a binding precedent
Binding precedent
In law, a binding precedent is a precedent which must be followed by all lower courts under common law legal systems. In English law it is usually created by the decision of a higher court, such as the Supreme Court of the United Kingdom, which took over the judicial functions of the House of...
in the relevant district. It was not until Edwards v. Aguillard
Edwards v. Aguillard
Edwards v. Aguillard, was a legal case about the teaching of creationism that was heard by the Supreme Court of the United States in 1987. The Court ruled that a Louisiana law requiring that creation science be taught in public schools, along with evolution, was unconstitutional because the law...
(1987), a similar case in Louisiana, was appealed to the U.S. Supreme Court that creation science was ruled unconstitutional at the federal level, which resulted in its removal from public school science classes nationwide. The reaction from the creationist forces would be to create the new concept of intelligent design
Intelligent design
Intelligent design is the proposition that "certain features of the universe and of living things are best explained by an intelligent cause, not an undirected process such as natural selection." It is a form of creationism and a contemporary adaptation of the traditional teleological argument for...
specifically in order to circumvent this ruling.
Related cases
- Scopes TrialScopes TrialThe Scopes Trial—formally known as The State of Tennessee v. John Thomas Scopes and informally known as the Scopes Monkey Trial—was a landmark American legal case in 1925 in which high school science teacher, John Scopes, was accused of violating Tennessee's Butler Act which made it unlawful to...
- 1925 - Epperson v. ArkansasEpperson v. ArkansasEpperson v. Arkansas, 393 U.S. 97 , was a United States Supreme Court case that invalidated an Arkansas statute that prohibited the teaching of human evolution in the public schools...
- 1968 - Willoughby v. SteverWilloughby v. SteverWilloughby v. Stever was a 1973 American legal decision in a case brought by evangelist William Willoughby against the National Science Foundation director H. Guyford Stever and the Board of Regents of the University of Colorado for using taxpayer money to fund textbooks developed by the Biological...
- 1973 - Hendren v. CampbellHendren v. CampbellHendren et al. v. Campbell et al. was a 1977 ruling by an Indiana state superior court that the young-earth creationist textbook Biology: A Search For Order In Complexity, published by the Creation Research Society and promoted through the Institute for Creation Research, could not be used in...
- 1977 - McLean v. ArkansasMcLean v. ArkansasMcLean v. Arkansas Board of Education, 529 F. Supp. 1255, 1258-1264 , was a 1981 legal case in Arkansas.A lawsuit was filed in the United States District Court for the Eastern District of Arkansas by various parents, religious groups and organizations, biologists, and others who argued that the...
- 1982 - Edwards v. AguillardEdwards v. AguillardEdwards v. Aguillard, was a legal case about the teaching of creationism that was heard by the Supreme Court of the United States in 1987. The Court ruled that a Louisiana law requiring that creation science be taught in public schools, along with evolution, was unconstitutional because the law...
- 1987 - Kitzmiller v. Dover Area School DistrictKitzmiller v. Dover Area School DistrictTammy Kitzmiller, et al. v. Dover Area School District, et al. was the first direct challenge brought in the United States federal courts testing a public school district policy that required the teaching of intelligent design...
- 2005