Davis v. Beason
Davis v. Beason is a significant legal case from 1888 that revolved around voting rights and religious practices in the aftermath of the U.S. Supreme Court's decision in Reynolds v. United States, which upheld a ban on polygamy. Following this ruling, the Idaho territorial legislature enacted a law restricting voting rights for individuals who practiced polygamy or were associated with organizations advocating for it. Samuel Davis, along with other non-polygamous Mormons, challenged this voting restriction after being denied the right to vote in an election.
The case was ultimately decided by the Supreme Court, which upheld the Idaho statute with a unanimous decision. The Court's ruling emphasized a narrow interpretation of religious freedom, positing that while individuals could hold personal beliefs, membership in a church advocating polygamy constituted conduct that could be regulated. This decision reflected a broader cultural context wherein associations with certain practices could lead to the loss of civic privileges, such as voting. Over time, the precedent established in Davis v. Beason has been critiqued and reconsidered, notably in later cases that sought to better balance individual rights and the implications of group affiliations.
Davis v. Beason
Date: February 3, 1890
Citation: 133 U.S. 333
Issues: Freedom of religion; right to vote
Significance: The Supreme Court allowed a territory to deny the vote to members of a religious sect that advocated an illegal practice.
In the landmark 1879 case, Reynolds v. United States, the Supreme Court upheld a federal ban on polygamy, a religious practice of members of the Church of Jesus Christ of Latter-day Saints (Mormons) at the time. Idaho subsequently enacted a territorial statute that denied the right to vote to anyone who practiced polygamy or who belonged to an organization that advocated polygamy. Samuel Davis and other nonpolygamous Mormons sued after they were not allowed to vote in the election of 1888.
By a 9-0 vote, the Court upheld the statute. Taking a very narrow view of both religion and the free exercise clause, Justice Stephen J. Field construed the statute as simply excluding the privilege of voting from those who encouraged and approved of the commission of “odious” crimes. Although persons could not be punished for their beliefs, membership in a church was considered a conduct; therefore membership itself was not protected by the First Amendment. Few people would defend Davis a century later. In Romer v. Evans (1996), Justice Anthony M. Kennedy observed that Davis was no longer good law to the extent that it held that advocacy of a certain practice could be the basis for denying a person the right to vote.