‘The Most Hated Woman in America’: Melissa Leo on the Murder of Atheist Madalyn Murray O’Hair

Madalyn Murray O’Hair took on the Supreme Court to get prayer out of schools, started a culture war, and was murdered for it. A Netflix film finally tells her story.

Beth Dubber/Netflix

In 1964, Madalyn Murray O’Hair appeared in Life magazine, her infamy warranting a headline branding her “The Most Hated Woman in America.” Five decades later, America seems to have moved on. Murray O’Hair, despite her notoriety and celebrity status during the culture wars, is no longer a household name—something a new Netflix film about the controversial activist and, ultimately, murder victim hopes to remedy.

Oscar-winner Melissa Leo stars as Murray O’Hair in the story so wild—and yet, so true—that it’s astounding that it hasn’t been turned into a film before.

In 1960, in the midst of a career as a social worker and civil rights activist, Murray O’Hair filed a landmark lawsuit against the Baltimore City Public School System on behalf of her older son, William, arguing that it was unconstitutional to force him to participate in Bible readings while attending public school. The lawsuit eventually reached the Supreme Court in 1963, with an 8-1 ruling in her favor.

She would later move to Austin, Texas, where her on-screen portrayer, Leo, is sitting down with The Daily Beast after the film’s SXSW festival premiere.

It was in Texas that she founded the American Atheists organization and became the outspoken public face of its mission to work for the true separation of church and state, even if it meant traducing believers for her cause.

It was also in Texas that Murray O’Hair, her son Jon, and her granddaughter Robin were kidnapped and brutally murdered by a disgruntled former American Atheists employee, after coworkers, family members, and authorities refused to believe suspicions that foul play was involved in the family’s sudden disappearance.

“It’s really interesting that you could do something that would have such a reverberating effect and yet not be known, disappear,” Leo says about Murray O’Hair’s Supreme Court crusade. “In fact, in her own lifetime disappear, which is how she ends up dead in the end.”

In recent years Leo has been on her own smaller crusade, of sorts: the one to get The Most Hated Woman in America made.

Writer-director Tommy O’Haver had his script finished two years before even sending it to Leo, whose Hollywood pull had grown considerably following her breakout turn in the 2008 indie Frozen River.

In the last decade, Leo has been one of the industry’s most prolific actors with over 60 credits in the time frame, including her Oscar-winning role in The Fighter, an Emmy-winning turn in Louie, and memorable performances in The Big Short, Mildred Pierce, All the Way, Treme, Broad City, Snowden, Flight, and more.

Leo helped O’Haver shepherd the film to co-producer Elizabeth Banks. It would be five more years until Netflix finally funded its limited-budget, 18-day shoot.

The actress admits that prior to receiving O’Haver’s script, she hadn’t heard of Murray O’Hair. In fact, in talking about the project over the years, she’s found a clear delineation: those who lived in Texas and remember the investigation into Murray O’Hair’s sordid kidnapping and murder back in 1995, and, essentially the rest of us.

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How could it be, she wondered, that a person who made such a mark on history and the fabric of our culture—not to mention whose public presence was so incendiary—not be the kind of trailblazer that everybody knows?

The answer she arrived at is simple and, sadly, predictable.

“I don’t know that the same story would have happened with a man bringing it to the Supreme Court,” Leo says. “It has to do with the fact that she’s female.”

That doesn’t just apply to Murray O’Hair not receiving the credit for accomplishing what she did, but the fact that her very public activism during her life led her to be the subject of so much hatred and attacking.

As Leo so entertainingly captures in The Most Hated Woman in America, Murray O’Hair wasn’t demure in her fight on behalf of atheists. One of her first lines in the film is a retort to a man who tells her to shut up: “You tell me to shut up? You don’t know what weeds you’re pissing in, buddy.”

When pleading her case in public forums, be it on Phil Donahue or Johnny Carson’s talk shows, or in a televised debate with Preacher Bob Harrington, she attacked the religious, ridiculed their beliefs, and provoked with a mischievous glee. At one point in the film, Leo’s Murray O’Hair claimed that the Bible was written by “faggots,” saying that, “Jesus was as queer as a $3 bill.”

“If she had been terribly polite and quiet about it, I don’t know that she would’ve been heard,” Leo says. “So then she’s abrasive, perhaps. Loud, perhaps. Foul-mouthed, for sure. Does that help her cause? Not really! But it gets her heard.”

What’s that saying? Well-behaved women seldom make history?

“It is absolutely true,” Leo stresses. “We have all kinds of men through our history—abrasive assholes that become kings and heroes, and soft-spoken gentlemen who are regarded with respect. I don’t know that I can understand that, but I know that I’ve been a woman in the United States of America all my life and it remains as difficult today as then. Maybe more so because there’s the delusion that things have changed.”

More, in the case of Madalyn Murray O’Hair, here is a woman who literally made history, but who still is written out of the record.

Forget the implausibility that a woman could be so notorious in her lifetime to be branded “The Most Hated Woman in America,” and then entirely unknown in the years since her death. Forget about the fact that any progress that has been made in society as far as the normalization of atheism in a historically Christian society and the removal of religion from government and schools is owed to her.

There’s the simple matter that her story has yet to be told. How is it possible that this is the first time a film has been made about her, when stories don’t get more cinematic than this one?

The David vs. Goliath fight of the single mom with no means taking on the Supreme Court. Her larger-than-life personality and way of speaking. And then, macabre as it is, the dramatic and violent way that she died—kidnapping, mystery, ransom, and grisly murder.

“The first obvious answer, again, is that she’s a woman,” Leo says.

Suddenly panicked that she sounds like a broken record, she goes on. “I’ve said it before: I’m no feminist. I wish we could all get to just being human beings together. But that’s not the climate out there. It’s shocking.”

It’s shocking, but Leo is also a realist. She looks at Murray O’Hair’s accomplishments—the Supreme Court decision, the conversations started by American Atheists, the civil rights work, the social work—and sees that, as with the Life magazine cover, all mention of her focuses on the hatred she endured, invited, and, yes, even spewed.

“When I raise my voice in my own industry in a work situation, and I’m making a suggestion—‘Let’s not do it this way, but this way…’—everybody only hears when I said, ‘Not this way.’ Nobody hears all the agreement, the collusion, the, ‘Oh yeah I can do it that way,’” she says. “All they hear is the one time I say, ‘Oh yeah, that’s not going to work.’”

To that regard, Leo says, “It was very attractive to play Madalyn Murray O’Hair. Whether or not Melissa Leo needs ‘most hated woman’ as her credit will remain to be seen.”