The Myth of Neutrality: Carl F.H. Henry’s Case for Prayer in Public School

Few arenas today expose the myth of a “secular” or “neutral” public square more than America’s public schools. As classrooms have become battlegrounds over everything from gender identity, to pronouns, to Critical Race Theory, each movement has presented itself as a comprehensive moral system, necessary for inclusion and justice. The roots of today’s turmoil stretch back to the mid-twentieth century, when the Supreme Court expelled prayer and Bible reading from public schools in the name of “separation” and “neutrality.” In removing public acknowledgment of God, however, the Court created a vacuum, which has been filled in recent years by “woke” ideology.

Over seventy-five years ago, Carl F.H. Henry recognized the inevitability of worldview formation in his The Uneasy Conscience of Modern Fundamentalism. Henry’s influential work appeared the same year as the Supreme Court’s landmark ruling, Everson v. Board of Education, set out an ambitious agenda of achieving a separation of church and state—beginning with public school classrooms. Each subsequent legal, cultural, and political battle during the past three quarters of a century has confirmed what Carl F. H. Henry laid out clearly. When divine revelation is banished from education, some rival authority inevitably takes its place. The question is not whether a faith will shape the moral imagination of the next generation, but which faith.

This essay traces that exchange of faiths by setting today’s educational and cultural conflicts within its historical and theological context. It begins with the postwar crisis of conviction among evangelicals, focusing on Carl F. H. Henry’s response to two Supreme Court decisions that effectively secularized public education. Henry rightly diagnosed the impossibility and undesirability of moral neutrality in education and the peril of severing divine authority from divine revelation. Dark as the picture was in Henry’s own day, however, the current Supreme Court has begun reversing course. Henry’s warnings appear increasingly vindicated, as modern “woke” ideologies in education reveal themselves not as neutral systems but as rival faiths contending for cultural dominance.

A Crisis of Conviction

The debate was lively that Sunday morning in the pastor’s study of Metropolitan Baptist Church (today Capitol Hill Baptist Church) in Washington, DC. For three weeks during the summer of 1962, a hand-selected group of religious leaders, intellectuals, government officials, and military officers convened by Carl F. H. Henry—including, Senator Strom Thurmond of South Carolina, and Senator A. Willis Robertson of Virginia—had been debating the Supreme Court’s explosive decision in Engel v. Vitale.^[1] The Court had struck down the long-standing practice of opening each school day in New York with a brief, non-denominational prayer written by the State Board of Regents: “Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, our teachers and our Country.” Writing for the majority, Justice Hugo Black declared that “it is no part of the business of government to compose official prayers for any group of the American people to recite as a part of a religious program carried on by government.”^[2]

Like many evangelicals, the group of Baptists gathered on Capitol Hill were sharply divided on the decision. As Baptists, they agreed that government had no business telling Christians how to pray. Yet as American citizens, the purging of public education of every vestige—not simply of Christianity but even of theism—seemed to portend disaster.

Metropolitan’s pastor, R. B. Culbreth, however, saw that an even greater danger loomed. Preaching the following Sunday, in a sermon titled ‘What Makes America Great?,’ he argued that the real crisis lay not in the recitation of a state-written prayer, but in the growing effort to purge God’s truth from education altogether. “It is the duty of the public schools to teach truth—all truth,” he insisted. “The Bible in the public schools is part of the great body of truth and should be taught as any other book that reveals truth.”^[3] The issue was not compulsion but conviction—whether a nation once founded upon divine revelation would now embrace an education system that pretended truth could be taught apart from God.

3. Culbreth, R. B. “What Makes America Great.” Sermon preached July 1, 1962. Congressional Record. 87th Cong., 2nd sess., vol. 108, pt. 10 (July 2, 1962), 12048.

Turning to Scripture for the nation’s diagnosis, Culbreth quoted Psalm 33:12, warning that America’s future rested on its submission to divine authority:

“God’s statement is: ‘Blessed is the nation whose God is the Lord.’ This is not—blessed is that nation that ignores God, or forgets God, but the nation that makes God its Lord is the one blessed. Is America determined to depart from that which has made her great? Pericles built a civilization upon culture, and it failed; Caesar built a civilization upon power, and it failed; our forefathers founded our Nation upon Christianity, and America will live so long as the Lord is our God.”

The very next day, Culbreth’s sermon was entered into the Congressional Record as part of Senate Concurrent Resolution 81 on ‘Nonsectarian Prayers in Public Schools,’ introduced by Senators Robertson and Thurmond—two members of Henry’s Sunday school class.^[4]

4. Congressional Record. 87th Cong., 2nd sess., vol. 108, pt. 10 (July 2, 1962), 12048.

Yet even as Culbreth thundered from the pulpit, Henry watched from his editor’s desk as many evangelicals wavered. In fact, when the Court went still further the following year, deciding in Abington School District v. Schempp (1963) that even voluntary daily Bible readings and recitations of the Lord’s Prayer in public schools in Pennsylvania and Maryland violated the Establishment Clause of the First Amendment, evangelicals stayed largely silent. “Not a single church group or Christian organization availed itself of the opportunity to file a brief in support,” Henry wrote following Schempp. In fact, he wrote, many evangelicals had come to “countenance and even support the suppression of prayer and Bible reading in public schools.”^[5] How had it come to this?

5. Carl F.H. Henry, “The Meaning of the Supreme Court Decision,” Christianity Today, July 5, 1963.

The Court’s Secular Turn

From the beginning, the American experiment presumed the public importance of religion. The Northwest Ordinance of 1787 declared that “religion, morality, and knowledge” were “necessary to good government and the happiness of mankind,” and therefore that “schools and the means of education shall forever be encouraged.”^[6] Early public schools in the colonies and the new republic routinely taught moral virtue from the Bible, recited prayers, and read Scripture selections as part of the daily curriculum.^[7] As Justice Joseph Story later explained in his 1833 Commentaries on the Constitution, the purpose of the First Amendment was not to exclude religion from public life but “to prevent any national ecclesiastical establishment,” while ensuring that Christianity—through “encouragement from the state”—might continue to inform public virtue and education.^[8]

This consensus endured well into the nineteenth century. Public schools, though “common,” were not secular in the modern sense. They aimed to form the moral character of citizens, assuming that virtue and piety were prerequisites for republican liberty. The First Amendment was understood as ensuring religious liberty and preventing state coercion—not as banishing God from the classroom. Only in the mid–twentieth century did this understanding begin to erode.^[9]

Beginning with Everson v. Board of Education in 1947, the Supreme Court transformed Jefferson’s metaphor of a “wall of separation” into a constitutional mandate.^[10] As Justice Hugo Black wrote in that case, “The First Amendment has erected a wall between church and state. That wall must be kept high and impregnable.”^[11] Crucially, Everson redefined the First Amendment around “neutrality.” As Black explained, “Our public school . . . is organized on the premise that secular education can be isolated from all religious teaching, so that the school can inculcate all needed temporal knowledge and also maintain a strict and lofty neutrality as to religion.”^[12] The writing was on the wall. Rather than an environment that nurtured and encouraged religious instruction, public education would be carefully sanitized from anything spiritual.

From 1947 through much of the twentieth century, the separationist impulse in Everson continued its levelling effects on faith in public schools. The following year, McCollum v. Board of Education (1948) struck down a “released-time” program in Champaign, Illinois, where outside clergy offered voluntary religious instruction on school property. Again writing for the Court, Black invoked Everson to hold that using “tax-supported public school systems to aid religious groups to spread their faith” was unconstitutional.^[13] The principle of neutrality now required not merely government impartiality among faiths but the evacuation of religious activity from public schools altogether. The logic reached its fullest expression in Engel v. Vitale (1962), which invalidated New York’s voluntary, nondenominational prayer on the grounds that “it is no part of the business of government to compose official prayers for any group of the American people to recite as a part of a religious program carried on by government.”^[14]

The next year, in Abington School District v. Schempp (1963), the Court extended this logic to daily Bible readings and recitations of the Lord’s Prayer, striking them down and announcing the “purpose and effect” test: any law must have a secular purpose and a primary effect that neither advances nor inhibits religion.^[15] Henceforth, the public classroom would be cleansed of organized religious expression. Thus, by mid-century, the “wall of separation” once meant to protect the church from state interference had become a legal barrier keeping divine revelation out of the nation’s schools—and to Henry’s chagrin, many evangelicals appeared ambivalent.

Henry’s Uneasy Conscience

Ever since the publication of The Uneasy Conscience of Modern Fundamentalism (1947), Henry had been warning that public life—education included—cannot run on “neutral” fumes. Ethics without theology, he argued, inevitably runs out of borrowed capital. Education and politics, no less than culture, must rest on worldview claims. The question is not if they are grounded in theological presuppositions but what those presuppositions are. More than a decade before Engel and Schempp, Henry described how every social order requires transcendent grounding: “The Ten Commandments disclose the only secure foundation for a society without the seeds of dissolution; all cultures, cut loose from these principles, have in them the vitiating leaven of decay.”^[16] For Henry, the issue was never whether the state should compose prayers (it shouldn’t), but whether public institutions could pretend to teach truth apart from reference to God.

16. Carl F.H. Henry, The Uneasy Conscience of Modern Fundamentalism (Grand Rapids, MI: Wm. B. Eerdmans Publishing Company, 1947), 39.

This was no less true for education than for all of society. Henry’s insistence on the myth of any claims to “worldview neutrality” in education sharpened the following year in his Notes on the Doctrine of God (1948). Published in the wake of McCollum v. Board of Education (1948) where the Court struck down released-time religious instruction conducted in public schoolrooms, Henry flagged teacher-training pipelines as crucial culture-shapers. Anticipating how education would become the primary front of culture war, Henry warned that “the theories taught in our schools for teachers will, for the most part, be the views held by the coming generation of youth in our land, unless there are some powerful forces to counteract such influences.”^[17] As Fuller Seminary dean Wilbur M. Smith wrote in the foreword to Henry’s book,

17. Henry, Notes, 8.

“There now comes to the side of rationalism, humanism, and atheism, as a powerful ally, the decision of the United States Supreme Court, to exclude the reading and teaching of the Word of God from our public schools. What this will mean in another thirty years frightens all who have any love for the Lord Jesus, and any conviction that for God to go out of American life spells ultimate disaster for our nation in more ways than one.”^[18]

18. Smith, foreword to Henry, Notes, 8.

Henry would likely not have anticipated the speed with which LGBTQ+ ideology and Critical Race Theory made incursion into public school classrooms during the past decade. Yet in ways that set him apart from many of his peers, Henry understood that removing a distinctly Christian worldview from the classroom was a crucial step toward the ideological turn we’ve witnessed during the past years.

God, Revelation, and Authority

What enabled Henry to see clearly what others missed? Henry understood that beneath every moral and political fight is an epistemological battle. In his six-volume magnum opus, God, Revelation, and Authority (1976–83)^[19] Henry supplied the theological definition of revelation as “a divinely initiated activity, God’s free communication by which he alone turns his personal privacy into a deliberate disclosure of his reality.”^[20] But as Henry saw it, the modern world had replaced that revelation with autonomous reason. The result was not intellectual liberation but a new dogma—the creed of human self-sufficiency. Because “reason is a divinely gifted instrument enabling man to recognize revelation or truth,” to discard revelation was to mutilate reason itself.^[21]

Nor did the secularization of education achieve its desired object of “neutrality.” Every curriculum, Henry insisted, rests on prior metaphysical assumptions about what is real and what can be known. By banishing the Bible as a source of truth, schools did not become neutral; they became catechetical instruments of naturalism. The result was clear: “In many schools,” he observed, “secular humanism has gained a quasi-official status while alternative Christian convictions are not even presented.”^[22] A secularized classroom simply transferred faith from God to man, confidence in revelation to confidence in human reason, and submission to divine authority to self-rule.

22. Henry, God, Revelation, and Authority, 6:439.

This epistemological exchange concerned public schools in the immediate term but had vast social and political consequences. Once biblical revelation was excluded from public discourse, education and law could no longer appeal to an objective moral order grounded in creation and God’s own character. Henry argued that the loss of theological authority inevitably leads to moral relativism and, eventually, to absolutism and tyranny. “Civil law,” he wrote, “has the authority and force of law not simply because it is legislation but ultimately because it interprets and applies the law of God.”^[23] When that transcendent reference point is denied, rights become mere conventions, dependent on power rather than principle. “When tyranny is the basis of human and civil rights,” he warned, “rulers can establish no predictable positive law since any and all laws are resonant with arbitrary powers.”^[24] Removing God from classrooms would not result in intellectual freedom but make American citizens increasingly susceptible to ever-changing ideologies. The theological reckoning in public education, therefore, was not simply a threat to evangelization—it was an existential threat to the viability of the nation. If the next generation were not instructed in a basic theistic worldview, democracy itself would become “a false god,” an idol unable to sustain justice or freedom.

A Live Question Today

Over the past couple decades, the Supreme Court has steadily revisited and reversed the strict separationist logic of Justice Hugo Black’s mid-twentieth-century jurisprudence in ways that Henry could have only dreamed. In contrast to Black’s “high and impregnable wall” between church and state, the Roberts Court seems to have embraced a more accommodationist approach that seeks to harmonize the Establishment and Free Exercise Clauses rather than pit them against one another.

The shift began with Town of Greece v. Galloway (2014), in which the Court upheld the practice of opening municipal meetings with prayer and the justices rejected the idea that public acknowledgment of religion was inherently coercive or unconstitutional.^[25] Then in Trinity Lutheran v. Comer (2017), the court held that excluding an otherwise eligible church from a neutral public benefit program solely because of its religious status violates the Free Exercise Clause.^[26] That logic was extended in Espinoza v. Montana Department of Revenue (2020), where the Court ruled that states cannot exclude religious schools from generally available public benefits simply because of their religious status.^[27]

The trajectory has only continued. For instance, in Kennedy v. Bremerton School District (2022), Justice Neil Gorsuch, writing for the majority, rejected the notion that a public-school football coach’s midfield prayer violated the Constitution, declaring that “there is no conflict between the constitutional commands before us. There is only the ‘mere shadow’ of a conflict, a false choice premised on a misconstruction of the Establishment Clause.”^[28] The trajectory toward extending public funding for religious charter schools seemed to be continuing in Oklahoma Statewide Charter School Board v. Drummond (2025). However, a 4–4 split—occasioned by Justice Barrett’s recusal—left the question unresolved. The deadlock, nonetheless, underscored how close the Court now stands to revisiting the entire logic of the Black Court’s secular-neutral paradigm. Most recently, in Mahmoud v. Taylor (2025), the Court held that public schools may not compel participation in instruction that poses “a very real threat of undermining the religious beliefs” parents seek to impart to their children—further eroding the secular “neutrality” paradigm of the mid-twentieth century.^[29]

As Christian parents, we welcome these changes. We recognize that we have a basic, God-given duty to raise our children according to our beliefs. If prayer, Bible reading, and religious instruction in school reinforces those aims, the fact that these practices involve an acknowledgment of divine revelation should not penalize us from generally available tax-provided assistance or from accommodations that allow for meaningful parental oversight of our children’s education.

As evangelicals, we stand in the footsteps of Carl F.H. Henry in recognizing that God’s revelation is inseparable from God’s authority. God has spoken and we do not have the option to pretend otherwise. God’s revelation shapes every aspect of how we live, including how we approach education. Every curriculum rests upon a creed; every lesson conveys a worldview. The question is which creed, which faith? We welcome, therefore, the intellectual honesty that identifies God as the source of our rights, our duties, and the author of the best path to human flourishing.