Melissa Leo delivers a powerhouse performance as the Austin atheist leader Madalyn Murray O’Hair in director Tommy O’Haver’s “The Most Hated Woman in America.”
As O’Hair, Leo is foul-mouthed, in your face, unapologetic and downright nasty at times as she battles most of the rest of the world in fighting for First Amendment rights. In case you’ve forgotten, O’Hair got the “most hated woman” description after she filed a lawsuit against the Baltimore school system, eventually forcing that district as well as others across the nation to stop having school prayer.
The Supreme Court decision is still be debated today, and O’Hair was at the center of the battle in 1963.

Peter Fonda and Melissa Leo in “The Most Hated Woman In America.” Beth Dubber/Netflix
O’Hair parlayed that fame into setting up an Austin nonprofit called American Atheists. She was a regular on TV talk shows and at one point toured the country debating a televangelist, played in the film by Peter Fonda.
Leo throws herself into the role, donning a fat suit for O’Hair in her later years when her girth widened substantially. And she doesn’t hold back on the anger or bluster. It’s almost shocking to see the early O’Hair, so out of place with her outspokenness and so unapologetic about her personal circumstances.
The movie opens with O’Hair telling her parents that she’s going to have yet another child out of wedlock. She has Bill Murray Jr., and a son named Garth is on the way.
Her deeply religious parents are appalled, of course, but O’Hair doesn’t flinch. And when she accompanies Bill Jr. to school one day and hears a teacher leading the students in the Lord’s Prayer, she starts yelling at the teacher and promising to put a stop to what she sees as a violation of church and state separation.
Nearly every man in O’Hair’s life, except for her youngest son Garth, betrays her. The first betrayals, of course, are from the men who don’t step up to help father their sons. But O’Hair suffers another setback when her oldest son, Bill, decides to become a Christian and disassociate himself from the family.
Then there’s David Waters, played by Josh Lucas, whom O’Hair groomed to take over the family business. Waters and O’Hair had a falling out eventually, and Waters came up with the scheme to kidnap O’Hair, her son Garth and her granddaughter Robin and demand that they turn over assets held in a supposedly secret account in New Zealand.
When the three disappear, a family associate notices their house is empty and that the dogs have been left behind, unattended. So he’s naturally alarmed. But law enforcement officials simply suspect that O’Hair has taken off for New Zealand to enjoy some time away from home. Then the passports are found, and then the family friend contacts a reporter in San Antonio, and finally, people begin to take matters seriously.
Meanwhile, the O’Hair family is still being held captive until a tragic event one night unleashes a fury that will leave all of them dead.
Leo’s final scenes in the film are heartbreaking, as she realizes what is happening. And you almost think that there will be some kind of redemption, some kind of grace, if O’Hair would ever accept such a concept. But Leo plays the scene note-perfect. And you know the tragedy will not be softened.
As Waters, Lucas has the second-strongest role. He captures the quintessential handsomeness and sleaziness that’s necessary. And Fonda is a hoot as a televangelist who challenges O’Hair to accompany him on a road show. It wasn’t O’Hair’s finest hour, ethically, but she did what she had to do, as Leo shows so well.
“The Most Hated Woman in America” premieres on Netflix on March 24. It screens again at SXSW at 11:30 a.m. March 18 at the Zach Theatre.
