State v. Cameron
100 N.J. 586, 498 A.2d 1217 (1985)
Rule of Law:
A municipal zoning ordinance that uses an undefined phrase like "churches and similar places of worship" is unconstitutionally vague as applied to conduct that does not fall within the term's clear core meaning, especially when the ordinance is quasi-criminal in nature and implicates First Amendment rights.
Facts:
- Robert J. Cameron, a minister in the Reformed Episcopal Church, was the leader of the Mount Carmel Reformed Episcopal Church congregation.
- Due to an increase in rent, the congregation was forced to relocate from the local school building where it previously held services.
- The congregation began meeting temporarily in Cameron's home, which was located in an R-15 residential zone where the Franklin Township zoning ordinance excluded 'churches and similar places of worship'.
- The services were attended by approximately twenty-five people and were conducted once a week for one hour.
- A neighbor complained to the township about hearing the religious service from eighty feet away and about cars parked on the street hindering traffic.
Procedural Posture:
- Franklin Township charged Robert J. Cameron in the Municipal Court of Franklin Township with violating a zoning ordinance.
- The Municipal Court found Cameron guilty and ordered him to cease holding worship services in his home.
- Cameron appealed to the Law Division, which conducted a trial de novo.
- The Law Division affirmed the conviction, holding that Cameron had used his home as a 'church'.
- Cameron, as appellant, appealed to the Appellate Division.
- The Appellate Division affirmed the Law Division's decision, with one judge dissenting on the grounds that the ordinance was unconstitutionally vague.
- Cameron, as appellant, appealed as of right to the Supreme Court of New Jersey.
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Issue:
Does a municipal zoning ordinance that excludes 'churches and similar places of worship' from a residential zone become unconstitutionally vague when applied to prohibit a minister from holding a one-hour weekly religious service in his home for a small congregation?
Opinions:
Majority - Handler, Justice
Yes, the ordinance is unconstitutionally vague as applied to the defendant. The phrase 'churches and similar places of worship' is not defined, admitting a variety of interpretations that fail to provide a person of ordinary intelligence a reasonable opportunity to know what is prohibited. This lack of clarity is particularly egregious because the ordinance is penal in nature and impinges upon constitutionally protected rights, including the free exercise of religion, which demands the utmost clarity. While the term 'church' might have a core meaning related to a special-purpose building, the defendant's single-family home does not fit that definition, and applying a broader, activity-based definition would be subjective and risk arbitrary enforcement.
Dissenting - Garibaldi, Justice
No, the ordinance is not unconstitutionally vague as applied to the defendant. The phrase 'churches and similar places of worship' should be construed according to its commonly-accepted meaning, which focuses on the religious activity, not the structure. The defendant was holding regular, formal, liturgical services for an organized religious body, presided over by an ordained minister; this clearly constitutes the use of the property as a 'church.' As a minister, the defendant should have reasonably known his conduct fell within the ordinance's proscription, and the ordinance itself is a valid time, place, and manner restriction that does not infringe on his religious freedom.
Concurring - Clifford, Justice
Yes, the ordinance is unenforceable against the defendant, but the court's reasoning should go beyond mere vagueness. The fundamental issue is that constitutional considerations of religious freedom and privacy foreclose a municipality from using any ordinance to prohibit a small group from praying, preaching, and singing in a private home. The state has not demonstrated an 'overriding governmental interest' to justify such a substantial infringement on First Amendment rights, especially when less restrictive means like noise or parking ordinances are available to address any actual nuisance. The government should not be in the business of preventing prayer meetings in the privacy of one's home.
Analysis:
This decision reinforces the due process requirement that penal or quasi-penal laws must be clearly defined, especially when they touch upon First Amendment freedoms. By applying a heightened level of scrutiny, the court signals that municipalities cannot use ambiguous zoning terms to regulate religious activities within a private residence. The case sets a precedent requiring local governments to draft regulations that are narrowly tailored to address specific, tangible harms (like traffic or noise) rather than broadly prohibiting uses based on subjective labels, thus protecting both fair notice and religious exercise from the chilling effect of vague laws.
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