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One of the longest running disputes at the intersection of education law and the First Amendment has involved conflict over evolutionary biology in American public schools. Through a century of nearly continuous litigation, creationist legislation and parental demands to exempt students from science instruction have been constrained by longstanding First Amendment doctrines.

That settlement is now unraveling. In Kennedy v. Bremerton School District, the Supreme Court abandoned its prior approach to the Establishment Clause in favor of a history-and-tradition analysis that is ill-suited to questions about modern scientific education. And in Mahmoud v. Taylor, the Court held that students’ compulsory exposure to ideas conflicting with their parents’ faith burdens religious exercise rights and triggers strict scrutiny.

This Essay provides the first comprehensive account of how these twin doctrinal shifts imperil the teaching of evolution. By tracing conflicts over evolution through three different eras—before, during, and after the regime ushered in by Lemon v. Kurtzman—this Essay shows how prior First Amendment doctrine cabined antievolution strategies, which included criminal statutes, “balanced-treatment” mandates, teacher-speech claims, and parental-rights suits. The Essay then evaluates Mahmoud, identifying two doctrinal disruptions: (1) exposure to disfavored ideas now constitutes a burden on religious exercise, and (2) strict scrutiny now reaches a broader swath of curricular challenges. Finally, the Essay forecasts the fallout: a surge in opt-out demands, heightened litigation risk, and an administrative chilling effect likely to erode already fragile scientific instruction.

As the first piece to frame Kennedy and Mahmoud as pivotal developments in the ongoing contest over science education, this Essay illuminates the doctrinal and institutional stakes of the Court’s Religion Clause revisionism. It also offers a roadmap for those seeking to preserve evidence-based curricula in the face of resurgent antievolution advocacy and a decline in the public acceptance of scientific consensus.