Reynolds v United States
The Church of Jesus Christ of Latter-day Saints (LDS) held the principle of polygamy, the practice of having multiple spouses, which was illegal. With this conflict regarding freedom to practice religious beliefs, the church decided to form a “test case”, a lawsuit intended to challenge the constitutionality of a law. Specifically, one man in the church would purposely admit to bigamy. This man was George Reynolds, who was initially convicted by the Utah District Court and then the Utah Supreme Court that upheld the conviction. His attorneys appealed the state decision to the Supreme Court, and their main argument was that engaging in a religious practice was not a crime.
Breakdown Verdict.
A unanimous decision upheld the conviction of George Reynolds, claiming that practicing a religion does not excuse ignoring the law. Although the First Amendment (free exercise of religion) protected Reynolds’s religious beliefs, the Court held that it did not exempt religious practices that violated criminal laws. The court pointed out the letter Thomas Jefferson wrote to the Danbury Baptists in 1802: “the legislative powers of the government reach actions only, and not opinions.” In this instance, Reynolds was free to believe in his own religion; however, he could not practice something illegal in the name of such a religion.
Result Going Forward.
The main idea of Reynolds v United States is that religion does not justify illegal activity. Thomas Jefferson’s letter summarizes the Court’s reasoning perfectly, where belief and action are distinct and yield two different outcomes. The ruling also adopted a narrower interpretation of the Free Exercise clause, deeming that it has limitations guided by existing law. The relationship between religious liberty and generally applicable laws remains a recurring constitutional issue, with this case of duty vs law setting the foundation.
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