Cantwell v. Connecticut
Cantwell v. Connecticut was a landmark Supreme Court case decided in 1940 that addressed the intersection of free speech and religious freedom. The case arose when Newton Cantwell, a Jehovah's Witness, was arrested for soliciting donations without a permit, following complaints about his criticisms of the Catholic Church. The Supreme Court unanimously reversed his conviction, highlighting the protection of religious practices, including proselytizing, under the First Amendment. Justice Owen J. Roberts, writing for the Court, asserted that while states can regulate the time, place, and manner of solicitation to prevent disruptions or fraud, they cannot impose broad restrictions that suppress unpopular religious views. The Court found that the Connecticut law allowed for excessive governmental discretion, effectively leading to religious censorship. This decision emphasized the importance of protecting minority religious expressions and contributed to the broader application of the incorporation doctrine, which extends constitutional protections against state infringement. Overall, Cantwell v. Connecticut stands as a significant case in upholding the principles of free exercise of religion and free speech in the United States.
Cantwell v. Connecticut
Date: May 30, 1940
Citation: 310 U.S. 296
Issue: Freedom of religion
Significance: The Supreme Court broadly interpreted the religious exercise clause of the First Amendment and held that the clause was applicable to the states through the Fourteenth Amendment.
Newton Cantwell, an active member of the Jehovah’s Witnesses, went door to door trying to make converts. A few people complained about his diatribes against the Catholic Church. Cantwell was arrested and convicted for violating a state law that required a license for soliciting funds.
By a 9-0 vote, the Supreme Court reversed the conviction and invalidated the law. Justice Owen J. Roberts’s opinion for the Court emphasized that the Constitution protected religious conduct such as proselytizing. He wrote that a state may reasonably regulate the time, place, and manner of activities to prevent fraud or disorder, but it cannot entirely forbid unpopular conduct. The Connecticut law constituted a form of religious censorship because it gave public officials excessive discretion for approving or rejecting applications for licenses.