Reynolds v. United States

Reynolds v. United States
Litigants	George Reynolds v. United States
Arguedate	January 11–12, 1878
Arguyear	1878
Decidedate	January 6, 1879
Decideyear	1879
Fullname	George Reynolds v. United States
Usvol	98
Uspage	145
Parallelcitations	25 L. Ed. 244; 1879 U.S. LEXIS 1906
Majority	Waite
Lawsapplied	First Amendment to the United States Constitution; Edmunds Act

Reynolds v. United States

Reynolds v. United States was a landmark Supreme Court decision addressing the interplay among the First Amendment to the United States Constitution, federal statute, and religiously motivated conduct. The Court reviewed a prosecution under the Edmunds Act for bigamy against a member of the Church of Jesus Christ of Latter-day Saints and articulated limits on religious exemptions from generally applicable criminal laws. The ruling established a precedent distinguishing beliefs protected by the First Amendment to the United States Constitution from practices subject to regulation by the United States Congress and the federal judiciary.

Background

In the post‑Civil War era, tensions between the United States Congress and the Church of Jesus Christ of Latter-day Saints escalated over polygamy. The Mormon practice of plural marriage had drawn attention from figures in the Senate of the United States, the House of Representatives, the U.S. Department of Justice, and state authorities such as the Utah Territory government. Legislative responses included the Morrill Anti-Bigamy Act and subsequent statutes like the Edmunds Act and the Edmunds–Tucker Act. Debates engaged prominent personalities and institutions including Brigham Young, the Republican Party (United States), the Democratic Party (United States), and agencies like the Federal Judiciary of the United States and the United States Supreme Court itself. Social movements, press organs such as The New York Times, and advocacy groups influenced public opinion during the Gilded Age and the Reconstruction Era.

Case Facts

George Reynolds, a member of the Church of Jesus Christ of Latter-day Saints and private secretary to Brigham Young in earlier decades, was charged under the Edmunds Act with bigamy after a second marriage ceremony. The prosecution involved witnesses from the Salt Lake City community, testimony before territorial courts in Utah Territory, and records from civil registrars. Reynolds’s defense invoked religious liberty principles rooted in the First Amendment to the United States Constitution, citing influences from legal theories advanced in prior cases and commentary by jurists associated with institutions like the Harvard Law School, the Columbia Law School, and the Yale Law School. The case ascended through territorial courts and reached the Supreme Court of the United States on writ of error.

Legal Issues

The Court considered whether the federal criminal statute prohibiting bigamy conflicted with the First Amendment to the United States Constitution guarantee of free exercise of religion. Central questions included: whether a religious duty to perform polygamous marriages could constitute a defense to a criminal indictment under the Edmunds Act; whether Congress possessed authority under the United States Constitution to regulate practices in territories such as Utah Territory; and how precedents from courts including the Kentucky Court of Appeals, the Supreme Judicial Court of Massachusetts, and opinions influenced by scholars at the University of Virginia School of Law bore on the interpretation of free exercise protections. The case implicated separation of powers concepts associated with entities like the United States Congress, the Executive Office of the President, and the Judicial Conference of the United States.

Supreme Court Decision

In a unanimous opinion delivered by Chief Justice Morrison Waite, the Supreme Court of the United States affirmed Reynolds’s conviction, holding that religious belief cannot justify actions criminalized by valid, neutral laws. The Court distinguished belief from action, concluding that while the First Amendment to the United States Constitution protects doctrines and opinions, it does not confer the right to engage in practices judged harmful or illegal under statutes such as the Edmunds Act. The decision referenced constitutional principles including the Supremacy Clause and congressional powers over territories.

Reasoning and Opinions

Chief Justice Morrison Waite reasoned that allowing religious belief to excuse criminal behavior would permit every individual to become "a law unto himself," undermining legislative authority exercised by bodies like the United States Senate and the United States House of Representatives. The opinion surveyed English common law antecedents and cited legal authorities and comparative jurisprudence from courts in jurisdictions such as the Kingdom of England and colonial legal traditions, as well as the work of legal commentators affiliated with institutions like the University of Pennsylvania Carey Law School and the Georgetown University Law Center. Waite emphasized that the First Amendment to the United States Constitution was never intended to protect practices contrary to social order as defined by statutes enacted under constitutional powers. No separate or concurring opinions were filed; the Court’s analysis incorporated principles of statutory interpretation used in federal courts nationwide, including the United States Court of Appeals for the Tenth Circuit in later years.

Impact and Subsequent Jurisprudence

Reynolds established a foundational doctrine distinguishing belief and practice that influenced later free exercise jurisprudence. The ruling shaped cases involving religious exemptions in contexts adjudicated by the United States Court of Appeals, the Supreme Court of the United States, and tribunals interpreting laws such as the Civil Rights Act of 1964, the Religious Freedom Restoration Act, and contemporaneous disputes involving entities like the Federal Trade Commission and the Equal Employment Opportunity Commission. Subsequent pivotal decisions, including cases decided during the eras of Chief Justices Earl Warren and Warren E. Burger, grappled with balancing religious liberty against neutral laws of general applicability, a line of doctrine revisited in modern opinions involving parties like the Becket Fund for Religious Liberty and litigants before the Supreme Court of the United States in the twenty‑first century. The decision remains a touchstone in legal education at schools such as the University of Chicago Law School and the Stanford Law School, and it continues to inform legislative and judicial debates over religious accommodation in American public life.

Category:United States Supreme Court cases