Madalyn Murray O'Hair
by Bryan F. Le Beau
New York University Press (New York, 2003). 386 pp., index.
Conrad F. Goeringer
Madalyn Murray O'Hair repeatedly insisted that she wished no biography written
about her before or after her death. The woman who attracted notoriety for her
important role in the historic combined cases of
Murray v. Curlett/Abington Township v. Schempp which helped abolish mandatory,
unison prayer and Bible verse recitation in the public schools was, in crucial
respects, a very private person. She left behind an extensive collection of
writings, however, including an account of that battle which ended at the U.S.
Supreme Court. Her 1995 disappearance and murder, along with son Jon Garth Murray
and granddaughter (adopted daughter) Robin Murray O'Hair, propelled her into
the public spotlight once again more than three decades after her confrontation
over school prayer. The resultant fallout has been a mélange of Internet gossip,
outrageously inaccurate "celebrity journalism" exposes such as a misleading piece
in Vanity Fair, and a crank book complete with psychic visions and other
Bryan F. Le Beau's work The Atheist: Madalyn Murray O'Hair is the first
work out of the literary stable that makes a serious effort to appreciate her
life and ideas, and to locate this amazing female reformer in the context of modern
history. Dogmatic critics of O'Hair will find little grist for their mills here.
There are no "access" exposés or lurid tales. Le Beau takes a surprisingly objective,
even at times sympathetic view toward the person Life magazine glibly branded
"The most hated woman in America." He is certainly no apologists for O'Hair, though,
and reveals what even many of us who admired MMOH already knew - she was a flawed
and temperamental human being, exhibiting traits which played a Janus-like role
throughout her lifelong struggles against mindless social conformity, political
orthodoxy, and especially religion.
Le Beau approaches his task of biographer as an academic, relying extensively on
primary and secondary source materials such as O'Hair's own public writings, her
FBI file, and a partial collection of diaries obtained by an attorney in a tax
auction. He also calls upon news clippings and magazine articles to flesh out
the time line of O'Hair's life, as well as recollections of informants many of
whom once embraced her as a modern day heroine for the Atheist cause.
The introduction tells the casual reader who Madalyn Murray O'Hair was, and places
her within a "freethought" tradition beginning with Socrates ("charged with
disbelieving in the gods of the state and put to death..."), through the various
strains of Unitarian belief and British philosophical though, the Enlightenment,
and the American tradition of intellectual skepticism embraced by Thomas Paine,
Robert Ingersoll, Clarence Darrow, Felix Adler, H. L. Mencken and Octavius Brooks
Frothingham. From there, Le Beau discusses the Humanist movement, and then ventures
into an examination of the cold war, a period of time where public profession of
religion was a considered a badge of political loyalty and wholesomeness. This
latter theme emerges later in the book as an important element in comprehending
O'Hair's place in American history.
Le Beau explores the legal and cultural battle over school prayer and related
First Amendment issues going back to Everson v. Board of Education (1947),
the McCollum (1948) and Zorach (1952) cases, and Roy Torcaso's
historic legal fight to abolish religious oaths as a qualification for holding a
public office. His summary of these and other cases should provide any reader a
workable understanding of the establishment clause, and how it applied to the
legal disputes over classroom prayer. Le Beau articulates the various aspects of
the Engel v. Vitale suit, which examined student recitation of a
"nondenominational" prayer composed by the New York Board of Regents, then segues
neatly into the Murray v. Curlett case and a companion suit filed by the
Schempp family. Unlike many uninformed critics of Mrs. O'Hair, Le Beau does not
marginalize the Murray case. Indeed, he discusses the problems O'Hair encountered,
her tireless work in lining up financial support for the legal trek she faced
and the opprobrium - even violence - the Murray family endured. As elsewhere in
the book, there are comments made by O'Hair, such as her response to an editorial
in Life magazine pronouncing her "the most hated woman in America."
We find the Bible to be nauseating, historically inaccurate, replete with the
ravings of commandments. We find God to be sadistic, brutal, and a representation
of hatred, vengeance ... This is not appropriate untouchable dicta to be forced
on adult or child. The business of the public schools, where attendance is compulsory,
is to prepare children to face the problems on earth, not to prepare for heaven -
which is a delusional dream of the unsophisticated minds of the ill-educated
The Atheist is filled with other verbatim comments taken from O'Hair's own
writings, or interviews in the media. Entire chapters are generously peppered with
these quotes including selections from An Atheist Epic which gave her account
of the school prayer case, to other works such as War in Viet Nam,
All About Atheists, An Atheist Speaks, and
What on Earth Is an Atheist! The sheer narrative power of these texts gives
insight into O'Hair's analytic mind, witty reasoning, and compelling style of
writing. Even critics within the freethought movement may see O'Hair in a new and
more favorable light after reading these passages. She was a quick study, keen,
This book is no whitewash of O'Hair, however. Her circle of critics that emerged
over the years, including former employees and associates, receive their fair
hearing, although their attacks on "the most hated woman of America" and her family
focus mostly on issues of personality and management style. One scold who felt
compelled to put her criticisms in book form described O'Hair as "a paranoidal
(sic) type of personality with obsessive, fixed ideas," who was "rebellious
against all existing authority, and tyrannical in conduct in forcing her will and
ideas on others."
Another pundit claimed that "Madalyn Murray has brought more discord to adherents
of the free thought movement, more bad publicity in the press, more hatred by the
public at large toward freethinkers, rationalists, secularists and humanists than
have all the combined theologians from the beginning of man's fight for freedom."
Unfortunately, LeBeau allows such hyperbolic rhetoric to stand unchallenged. One
weakness in his book is a lack of balance regarding the personal assessment of
The Atheist. At times, Mrs. O'Hair is painted as almost a caricature. Those
who knew and admired her will find that her persona is poorly defined in Le Beau's
book despite the access he enjoyed to a sample collection of diaries and other
sources. Biographers, of course, cannot compel witnesses to somebody's life to
speak frankly, and often the lure of playing to critics, however flamboyant they
may be, is a temptation difficult to resist. One senses that Le Beau may have
realized this, and hence relied so heavily on Mrs. O'Hair's own words and writing
in hopes of possibly providing that elusive balance. These make the case for
O'Hair The Atheist and social activist, but the chapters are woefully lacking on
input from those who had less temperamental and belligerent views of O'Hair and
her family, or who found the grande dame of Atheism to often be humorous,
generous to a fault, and a woman of astonishing dedication to her ideals. This,
of course, may be the responsibility of O'Hair's friends and associates who, in
the days following the disappearance and subsequent revelations of the family's
horrific murders, chose - for whatever reason - not to comment and speak out.
What kind of effort Bryan Le Beau made in locating these people is difficult to
say, but it is one omission that tarnishes The Atheist, and deserves inclusion
in future biographical assessments about Mrs. O'Hair whether from Le Beau or other
One also senses that while Le Beau put considerable effort into assembling thousands
of "facts" about O'Hair and the era she lived in, there are still critical parts
of the puzzle of her life that remain missing It would be interesting, for instance,
to know what motivated some of her critics in order to better assess their claims
about The Atheist and her movement. Le Beau and many others attempting to write
an O'Hair biography may fall short in this respect; they compile their
chapters-and-verses essentially as outsiders, and may not be privy to much of the
information known to those closer to the subject of this work. Two cases are worth
Le Beau relies perhaps too weightily on William J. Murray's autobiographical
exploit, My Life Without God. Searching for fragments of truth amidst any
family feud, including the combustible Murrays, is a daunting enterprise. It was
surprising, though, to see Bill Murray's accounts providing so much foundation
for elements of Le Beau's chronology and description of events. Even by his own
account, much of My Life Without God covers events during which William
Murray was nearly comatose thanks to a lifestyle of drug and alcohol abuse. Mrs.
Murray and her other son, Jon, stated that much of the book was riddled with
inaccuracies and fictions. It may have been, and sorting out the truth from the
exaggerations and inventions (whether fueled by cocaine or sheer vindictiveness
and resentment) may prove impossible.
The other involves some of the critics who were informants for Le Beau and whose
own record of truthfulness may need to be questioned more critically. In the era
of the "whistleblower," of course, it is de rigueur to smear and undermine
anyone who calls attention to organizational abuse, excess, and other wrong-doing.
But the O'Hairs rarely resorted to attacking their numerous critics in public,
although they made an exception in the case of David Waters, the man eventually
unmasked as the mastermind behind the family's 1995 kidnapping, extortion, and
murder. Again, not being an "insider" and perhaps not talking to the right people
or having access to complete records, Le Beau is put in the position of having to
regurgitate statements unflattering to Mrs. O'Hair, and leaving their veracity
for the reader to ponder without benefit of further information. One ex-staffer,
for instance, quoted in The Atheist was noted for making outrageous and
unsubstantiated claims of financial impropriety by Mrs. O'Hair, including charges
that her alleged pilfering of the organizations' accounts was on a scale even greater
that the Jim Bakker-PTL scandal. Only in death were the O'Hairs exonerated of these
sorts of lurid claims, a fact not widely acknowledged in the press. Since the
recovery of the O'Hair family remains, in fact, even critics acknowledge that the
tales of overstated wealth may well have contributed to the violent deaths.
Le Beau does take a surprisingly objective tack in assessing the role and impact
of Madalyn O'Hair's "crusade." He includes the quote from Time magazine in
1997 that noted, "what became a sideshow for the public remained a vital issue for
the small groups of people whose isolation she had broken."
O'Hair's outspoken critics who broke ranks with her over any number of issues,
should even grudgingly admit that she was a force of nature. One writer speaks of
her "role in history," and another tells of how O'Hair seemed able to connect with
those disparate Atheists and other heretically minded people throughout the years.
"It reassured them that they weren't the only ones on earth to feel this way."
Said another, admitting that while O'Hair had her share of faults, "What she's
accomplished is more than any of her critics have ... Maybe she isn't the best
leader for atheists any longer, but let's see if someone more qualified steps
And what did O'Hair have to say about her fellow Atheists?
In his chapter "Why I Am an Atheist" (borrowed from the title of one of O'Hair's
books), Le Beau does a credible job in excavating how O'Hair perceived the
Atheist-materialist philosophy. He cites that famous quote from the
Murray v. Curlett case: "An Atheist loves his fellow man instead of a god.
An Atheist believes that heaven is something for which we should work now, here
on earth, for all men together to enjoy..."
The reader is also given an insightful summary of how O'Hair viewed the different
"kinds" of Atheists, from the sectarian "who flourished only in bitter internecine
warfare and factional strife" and whose entire energy was devoted to attacking
other Atheist groups, and was therefore "destructive to our cause," to the Opinion
Atheist "who made his opinions known at every opportunity, whether he was well
informed or not, and whether it was appropriate or not."
"Freddy the Free Loader Atheist," utilized the services of the movement but would
not contribute financial or other support. And there was the "Messiah Atheist,"
whom Le Beau describes accurately as "those who following without question the
teachings of Isaac Asimov, Carl Sagan, and others."
In addition, there are primitive, discreet, philosophic and practical Atheists,
all with their strengths and shortcomings. This section alone should be a rewarding
read for any nonbeliever, whether critic or supporter of Mrs. O'Hair.
Le Beau goes on to cover Mrs. O'Hair's career following the historic school prayer
decision. He provides a concise history of the subsequent legal battles she and
American Atheists fought in the wake of the Murray v. Curlett decision,
such as the effort to challenge the federal "In God We Trust" motto, end
government-sponsored religious displays like nativity crèches, and the fight
against religious oaths for jurors. Other cases involved challenging prayer at
city council meetings, tax exemptions on property held by religious groups
(Andrews v. Monson, 1980), and prayer at high school graduations.
There are also sections on how O'Hair surveyed the political and cultural
landscape in America following the tempestuous 1960s and early 70s. She had been
"critical" of Presidents Ford and Carter, but considered Ronald Reagan as the
most dangerous threat against "the premises upon which our nation is founded."
For O'Hair, the Reagan era was Thermidor, an invitation to return the country to
the dark days of the McCarthy era with its congressional witch hunts, intolerance
of dissent and persecution of political radicals. It was in that religiously-charged
cultural climate that O'Hair and her son, Jon Garth Murray, saw the day when the
school prayer decision would be reversed, and the floodgates of American theocracy
In his section "O'Hair Retires," it becomes evident that Le Beau may have taken
on a literary task too ambitious given his resources and the patience of editors.
Once again the voices of critics seem to dominate this section of the book.
Le Beau does note, however, that various "accusations" against Mrs. O'Hair "had
not been proven" (as in parts of the Truth Seeker case, and that concerning
allegations of financial improprieties), "No complete, final and objective
accounting of O'Hair's financing is available. What survives are several unsolicited,
biased, and often erroneous statements and only a few official documents."
The Epilogue is a brief summation of the disappearance and murder of Mrs. O'Hair,
Jon Garth Murray, and Robin Murray-O'Hair. Le Beau might be faulted for not digging
deeper into some of the aspects of the case and thus avoiding more egregious
errors. One example is the IRS "money-laundering probe." This amounted to a
diktat from the IRS, that took advantage of the situation to seize the
family's property following the disappearance supposedly to pay for "back taxes."
In fact, the campaign of harassment by the IRS over the years often resulted in
literally hundreds of charges being dropped for lack of proof. Had they lived, it
is doubtful that the Internal Revenue Service would have prevailed in its latest
shake-down. The O'Hairs simply did not possess the vast fortune some of their
critics recklessly and unfairly accused them of having. Despite the Cadillacs
(they were donated as used vehicles), the Mercedes and Porsche which Jon Murray
and Robin Murray-O'Hair considered among their few "toys," the family lived quite
modestly, and often on a scale well below that of some of their critics.
Regrettably, Le Beau closes his narrative with a word concerning the disposition
of the O'Hairs' remains. William Murray cremated and buried his mother, John Garth
Murray and his daughter Robin Murray in an unmarked grave "in an undisclosed
cemetery in the hills of Central Texas, near Austin." By this time, the leadership
of American Atheists had passed to Ellen Johnson who took legal steps to recover
the bodies. This incident led a professor of religion at Emory University to engage
in totally uninformed speculation, suggesting that this effort was "to transform
O'Hair into a sort of atheist saint..."
It wasn't. Mrs. O'Hair had stipulated that she wished a certain disposition of
her remains, one that William Murray simply did not carry out. It had nothing to
do with religious iconography, "reaffirming community" with some departed "saint,"
or anything else of that nature. Indeed, that type of speculation and fictional
musing seemed to stalk her in life, and even in death. Le Beau's work on Madalyn
Murray O'Hair needs to be read by both friends and critics alike.
The latter must realize that despite her wit, intelligence, ideological integrity
and commitment to ideals, O'Hair was, after all, quite human. Both she and her
family members who carried on following her retirement had difficulties in developing
the sorts of interpersonal skills necessary in making any organization effective.
No one, however, can question their dedication and tenacity, as well as their long
list of remarkable accomplishments. Atheists too often mimic the religious in
inventing heroes and saints to idolize. When these members of a secular pantheon
fall short, they are quickly savaged and transformed into outcasts. In the case
of Mrs. O'Hair and her family, this process occurred all too frequently, and has
discouraged a more dispassionate and insightful assessment of their contributions
to Atheism and the defense of the First Amendment
The Atheist is really the first serious work to place Madalyn Murray O'Hair
in the context of historical and cultural events. She was a both a product and
shaper of her times. In the turbulent era of the 1960s, she epitomized the
confrontational and often outrageous, theatrical style of political activism.
Unlike other icons, she did not forsake her particular cause - converting to religion,
retiring into the comfortable environs of ideological suburbia, or choosing to
market a degree of celebrity cachet and notoriety. She remained, steadfastly,
Conrad F. Goeringer is Director of American Atheists
On-Line Services and a Contributing Editor to American Atheist. He surfs
the Web and writes about the world from his home on the South Jersey Shore.
© 1996, 1997, 1998, 1999, 2000 by American Atheists.