Reynolds v. United States
Reynolds v. United States is a significant Supreme Court case from 1878 that addressed the conflict between religious practice and federal law. The case involved George Reynolds, a member of the Church of Jesus Christ of Latter-day Saints, who was convicted of bigamy under a federal statute, as Mormon doctrine permitted plural marriage. The Supreme Court, led by Chief Justice Morrison R. Waite, ruled unanimously that Reynolds's conviction did not violate the First Amendment's free exercise clause. The opinion notably distinguished between belief and conduct, asserting that while individuals are free to hold any religious belief, actions that violate social norms, such as bigamy, can be regulated by law. This case is considered a landmark decision as it was one of the first to clarify the limits of religious freedom in the context of unconventional practices. It established that the government could impose restrictions on certain actions, even if they stem from religious beliefs, to uphold societal order and morality. The ruling laid important groundwork for future cases involving the balance between religious liberty and legal standards.
Reynolds v. United States
Date: May 5, 1879
Citation: 98 U.S. 145
Issues: Freedom of religion; marriage
Significance: Upholding a congressional prohibition on polygamy, the Supreme Court ruled that the First Amendment protects all religious beliefs but does not protect religiously motivated practices judged harmful to the public interest.
George Reynolds, an active member of the Church of Jesus Christ of Latter-day Saints (Mormons) in the territory of Utah, was convicted of the crime of bigamy, contrary to a federal statute of 1862. All parties agreed that Mormon church doctrine required male members to practice plural marriage when circumstances permitted. The justices of the Supreme Court unanimously ruled that Reynolds’s conviction was not a violation of the free exercise clause of the First Amendment. In the official opinion, Chief Justice Morrison R. Waite made a distinction between beliefs and conduct. Although the U.S. Congress could place no restraint on religious opinions, it had the authority to punish “actions which were in violation of social duties or subversive of good order.” Waite pointed to the long-standing common-law prohibition of bigamy and quoted respected jurists who believed that the practice promoted despotic government and disrespect of women.
Reynolds is considered a landmark because it was the Court’s first major pronouncement on the topic of the free exercise clause in relation to an unconventional religious practice. Waite’s formulation of a belief-conduct distinction was important for later cases, as was his reference to the Jeffersonian metaphor of “a wall of separation between church and state.” Although the opinion recognized that Congress could not prohibit a religious practice without a reasonable basis, it did not demand a very compelling justification. During this period, rights under the First Amendment were not applicable to the states, but Reynolds was in total conformity with state laws on marriage and religion.