Reynolds v. United States

Reynolds v. United States, Supreme Court, 1879

Facts of the Case

George Reynolds, a member of the Church of Jesus Christ of Latter-day Saints (LDS Church), was charged with bigamy under the federal Morrill Anti-Bigamy Act after marrying a second wife. Reynolds argued that his religious duty, as practiced by the LDS Church, required him to engage in polygamy. He claimed that the anti-bigamy law violated his First Amendment right to freely exercise his religion. Reynolds was convicted and appealed the decision, asserting that the law infringed upon his religious freedoms.

Constitutional Question

Did the federal anti-bigamy statute violate the First Amendment’s guarantee of the free exercise of religion because plural marriage is part of religious practice?

Arguments

For Reynolds:

  • The First Amendment guarantees the free exercise of religion, which includes the practice of polygamy as a religious duty for members of the LDS Church.
  • The government should not interfere with religious practices, even if those practices conflict with federal law.
  • Prohibiting polygamy infringes upon individual religious freedoms and discriminates against the LDS Church.

For the United States:

  • The government has the authority to regulate marriage practices, including prohibiting polygamy, to protect societal interests and public morals.
  • The First Amendment protects religious beliefs but does not extend to religious practices that violate social order and legal statutes.
  • Polygamy poses significant social and legal challenges, and the government has a compelling interest in maintaining monogamous marriage as the societal norm.

The Decision

The Supreme Court, in a unanimous decision, upheld Reynolds’ conviction and ruled that the federal anti-bigamy statute did not violate the First Amendment. Chief Justice Morrison Waite, writing for the Court, distinguished between religious beliefs, which are protected by the First Amendment, and religious practices, which may be regulated if they conflict with public morals or laws. The Court concluded that allowing polygamy would be inconsistent with the nation’s history and legal traditions and could lead to societal harm. Therefore, the government could lawfully prohibit polygamy without infringing upon the free exercise of religion.

Significance

Reynolds v. United States was a landmark case that established the principle that religious practices, as opposed to religious beliefs, can be regulated by the government if they conflict with social norms and legal statutes. The decision clarified the limits of the First Amendment’s free exercise clause, emphasizing that individuals cannot use religious duty as a defense against criminal charges. This case set a precedent for future rulings on the balance between religious freedom and government regulation, reinforcing the idea that religious practices must conform to general laws that protect public welfare and order.