Murray was known for her role in the landmark 1963 Supreme Court decision in Murray v. Curlett, which, combined with Abington v. Schempp, ended school 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.] "She is probably the best-known Atheist in the world today." Other publications concurred: "Life" magazine described her in 1964 as "anathema to millions of Americans."
Now, ten years after her mysterious disappearance in late August, 1995, which culminated in the discovery years later of her grisly murder by a former employee, the legacy of this controversial activist still influences atheists in America today.
"Madalyn gave legitimacy to the atheist movement," said Ann Rowe Seaman, author of the recent biography, "America's Most Hated Woman: The Life and Gruesome Death of Madalyn Murray O'Hair." "She put it on the map as a viable thing."
"She laid a foundation for atheists coming out of the closet," agreed Wendy Britton, a former acquaintance of the O'Hair family who organized an event for atheists in the Seattle area on August 28 called "Madalyn Murray O'Hair: What She Stood For And Why Her Ideas Matter Today."
Born in 1919 to a poor family in Pittsburgh, she was raised by church-going parents but claimed she became an atheist after reading the complete Bible in her early teen years. Madalyn Murray O'Hair 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 v. Vitale case. Murray v. Curlett, along with Abington v. 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 told Beliefnet 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 (O'Hair 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, were as successful or as notorious as Murray v. 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.
Still, these suits managed to keep O'Hair in the public eye long after the 1963 decision. "Her suits might have failed," said 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--surprisingly among atheists as well as Christians.
Why did O'Hair have enemies among atheists?
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"As time went on, Madalyn got more and more dictatorial, so she made a huge number of enemies in her own camp."
She was a "deeply corrupt, depraved human being," wrote Texas journalist Ted Dracos in an email interview. Dracos researched O'Hair's life for his 2003 book "UnGodly: The Passions, Torments, and Murder of Atheist Madalyn Murray O'Hair."
"As I was, a lot of people were attracted to Madalyn's staunch stances--the goodness of her Jeffersonian ideals when it came to religion and governance," Dracos continued. "Alas, they were taken in by her. Seduced by her brilliance."
Nevertheless, many atheists today credit her with leading the way on the issues that are most important to them. Non-believers in America today--numbering as much as 14.1% of the U.S. population, according to one study--are a diverse group. Ranging from devout atheists and rationalists to secular humanists and other freethinkers, they are united in their vision of complete separation of church and state. Many say O'Hair's activism was the forerunner of current church-state debates, from the current "Under God" controversy to the drive to remove "In God We Trust" from U.S. money to fights over the public display of the Ten Commandments.
"She opened such a Pandora's box," said Seaman. "A lot of the things that are in the news right now are things that Madalyn did long before--like the Pledge case. She filed a lawsuit to get the Ten Commandments removed from a state capital in Austin, and she filed a suit to remove the cross from the city seal of Los Angeles. [These suits] got in the news all the time; they raised the nation's consciousness of the question of what is church-state separation."
Not all agree about her leading role in this process, however. "The constitutional question of separation of church and state has been adjudicated for more than 200 years in this country," Dracos argued.
There are a lot of "people who hate her and who think she's done more harm than good for the cause of atheism," said Marcus Dunavan, 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 two of her family members, son Jon Garth Murray, 40, and granddaughter Robin Murray O'Hair, 30, who was William's estranged daughter. 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 were also missing from the organization. It wasn't until six years later, in early 2001, that their remains were discovered on a 5000-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 or not 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.
"Even though she wasn't liked, she got people talking, and for that she deserves a place in history," said Dunavan. He said she remains an inspiration for atheists today, many of whom still feel alienated in a dominant religious culture.
"We shouldn't deify her for it," agreed Britton, "but we should use what she did to carry forth her cause."
It's a sentiment America's most famous atheist certainly would have agreed with.
