Larson v. Valente

Supreme Court of United States
456 U.S. 228 (1982)

ELI5:

Rule of Law:

A law that imposes registration and reporting requirements only on those religious organizations that receive less than half of their contributions from members is a denominational preference that violates the Establishment Clause of the First Amendment unless it is closely fitted to serve a compelling governmental interest.

Facts:

From 1961 to 1978, Minnesota's charitable solicitations Act exempted all 'religious organizations' from its registration and reporting requirements.
The Holy Spirit Association for the Unification of World Christianity (Unification Church) engages in public proselytizing and solicitation of funds, and operated in Minnesota as an exempt religious organization prior to 1978.
In 1978, the Minnesota Legislature amended the Act to include a 'fifty per cent rule,' which limited the religious exemption to organizations that received more than half of their contributions from members or affiliated organizations.
The Unification Church received a substantial portion of its funding from non-members through public solicitation.
Following the amendment, Minnesota state officials notified the Unification Church that, because of the new rule, it was no longer exempt and was required to register and file detailed reports under the Act.

Procedural Posture:

Followers of the Unification Church sued Minnesota state officials in the U.S. District Court for the District of Minnesota.
The Unification Church was later joined as a plaintiff in the action.
The District Court granted summary judgment for the Unification Church, declaring the 'fifty per cent rule' unconstitutional under the Establishment Clause and enjoining its enforcement against all religious organizations.
The state officials, as appellants, appealed to the U.S. Court of Appeals for the Eighth Circuit.
The Court of Appeals affirmed the finding that the rule was unconstitutional but held that the exemption should apply to all religious organizations and remanded the case for further proceedings.
The U.S. Supreme Court granted Minnesota's petition for a writ of certiorari.

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Issue:

Does a Minnesota statute that exempts from its registration and reporting requirements only those religious organizations that receive more than fifty percent of their contributions from members violate the Establishment Clause of the First Amendment?

Opinions:

Majority - Justice Brennan

Yes. A state law that creates a denominational preference by exempting only certain religious organizations from registration requirements violates the Establishment Clause. The clearest command of the Establishment Clause is governmental neutrality among religious denominations. Laws granting denominational preferences are subject to strict scrutiny and must be closely fitted to a compelling governmental interest. The fifty percent rule fails this test because it creates a clear preference for well-established churches funded by members over newer, less conventional churches that rely on public solicitation. The state's asserted interest in protecting against fraudulent solicitation is not closely fitted to the rule, as there is no evidence that member control is an effective safeguard or that the percentage of non-member contributions is the correct metric for fraud risk. Furthermore, the legislative history reveals an intent to target specific unpopular groups, constituting 'religious gerrymandering' and fostering the excessive government entanglement with religion that the Constitution forbids.

Dissenting - Justice White

No. The Minnesota statute's fifty percent rule does not violate the Establishment Clause. The rule is not a deliberate denominational preference but rather a facially neutral, secular criterion based on funding sources, which happens to have a disparate impact among religious groups. The state has a valid and compelling secular interest in preventing fraudulent solicitation. It is reasonable for the legislature to conclude that organizations primarily funded by their own members have internal safeguards against abuse, justifying an exemption that is not extended to groups that solicit heavily from the general public. The Court should defer to this legislative judgment rather than substituting its own.

Dissenting - Justice Rehnquist

The Court should not decide this issue because the appellees lack Article III standing. To have standing, a party must show that their injury is caused by the challenged law and will be redressed by a favorable decision. Here, the Unification Church has not yet proven in court that it is a 'religious organization' under the Minnesota Act. Therefore, even if the fifty percent rule is struck down, the Church may not qualify for the religious exemption at all and could still be required to register as a general 'charitable organization.' Because a favorable ruling would not guarantee relief from their injury, the Court's decision is essentially an advisory opinion, which federal courts are powerless to issue.

Concurring - Justice Stevens

Yes. The Minnesota statute's fifty percent rule violates the Establishment Clause, and the Unification Church has standing to challenge it. The rule causes a clear injury by creating a simple, direct method for the state to compel the Church to register. Without the rule, the state would face the 'considerable burden' of proving the Church is not a religious organization, a much more difficult task. Striking down the rule redresses this specific injury. While courts should avoid premature constitutional adjudication, deciding the issue now is proper because litigating the Church's religious status would inevitably raise other, equally complex constitutional questions.

Analysis:

This decision establishes that laws creating facial distinctions between religious denominations are subject to strict scrutiny under the Establishment Clause, a higher standard than the three-part Lemon test. The case solidifies the principle of 'denominational neutrality,' limiting the ability of legislatures to target or burden new or unpopular religions through seemingly neutral criteria that have a discriminatory effect. By labeling the legislative intent as 'religious gerrymandering,' the Court signaled a low tolerance for laws that selectively burden or benefit specific sects. This precedent significantly strengthens protections for minority religions against discriminatory regulation disguised as public interest measures.

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