Reynolds v. United States (98 U.S. 145)
98 U.S. 145 (1878)
Rule of Law:
The First Amendment's Free Exercise Clause protects religious beliefs but does not protect religiously motivated actions that are deemed criminal by a valid and neutral law of general applicability.
Facts:
- George Reynolds was a member of the Church of Jesus Christ of Latter-Day Saints (Mormon Church) in the Territory of Utah.
- An accepted doctrine of the Mormon Church, which Reynolds believed, was that it was the religious duty of male members to practice polygamy.
- The church taught that failure to practice polygamy when circumstances permitted would lead to damnation in the afterlife.
- Reynolds was already married to one woman, Amelia Jane Schofield.
- Believing it was his religious duty, Reynolds received permission from church authorities and married a second woman, Mary Ann Tuddenham.
- The marriage ceremony was performed by Daniel H. Wells, an official with authority in the church, pursuant to the doctrines of the church.
Procedural Posture:
- George Reynolds was indicted for bigamy under a federal statute in the District Court of the third judicial district of the Territory of Utah.
- At trial, Reynolds was convicted.
- Reynolds appealed the conviction to the Supreme Court of the Territory of Utah.
- The territorial Supreme Court affirmed the trial court's judgment.
- Reynolds then brought the case to the Supreme Court of the United States on a writ of error.
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Issue:
Does a federal law prohibiting bigamy violate the First Amendment's Free Exercise Clause when applied to an individual whose religion requires the practice of polygamy?
Opinions:
Majority - Mr. Chief Justice Waite
No, the federal law prohibiting bigamy does not violate the First Amendment's Free Exercise Clause. The Constitution establishes a distinction between religious belief and action; while laws cannot interfere with mere religious belief, they may regulate actions that are contrary to public order and social duties. The First Amendment deprives Congress of legislative power over mere opinion, but leaves it free to reach actions which violate social duties or are subversive of good order. Historically, polygamy has been treated as an offense against society, and marriage is a civil contract regulated by law upon which society is built. To allow a person to be excused from a criminal statute due to religious belief would be to make the professed doctrines of religion superior to the law of the land, effectively permitting every citizen to become a law unto themself. Criminal intent is established when an individual knowingly commits an act prohibited by law, and ignorance of the law, or a belief that the law is wrong, is not a defense.
Concurring - Mr. Justice Field
No, the federal law prohibiting bigamy does not violate the First Amendment, but the court erred on an evidentiary matter. While concurring with the majority's conclusion regarding the constitutionality of the bigamy statute, this opinion disagrees with the decision to admit the prior testimony of Amelia Jane Schofield. The foundation laid for introducing her testimony from a former trial was insufficient.
Analysis:
This landmark decision established the foundational "belief-action" distinction in Free Exercise jurisprudence, which held for nearly a century. By subordinating religiously motivated conduct to neutral, generally applicable laws, the Court significantly limited the scope of the First Amendment's protection. The ruling affirmed the power of the state to regulate conduct it deems harmful to social order and morality, even when that conduct is central to a person's religious practice. This precedent was later modified by cases requiring a compelling state interest to burden religion (Sherbert v. Verner), but the core idea in Reynolds remains influential in debates over religious exemptions from law.
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