Larson v. Valente

456 U.S. 228 (1982)

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Nature of the Case

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Facts

The Minnesota Legislature amended its charitable Act so as to include a 'fifty percent rule' in the exemption provision covering religious organizations. This fifty percent rule provided that only those religious organizations that received more than half of their total contributions from members or affiliated organizations would remain exempt from the registration and reporting requirements of the Act. The appellee, Holy Spirit Association for the Unification of World Christianity (Unification Church), was notified that it was required to register under the Act. It responded by bringing the present action in the United States District Court for the District of Minnesota. Appellees sought a declaration that the Act constituted an abridgment of their First Amendment rights of expression and free exercise of religion, as well as a denial of their right to equal protection of the laws, guaranteed by the Fourteenth Amendment; they sought temporary and permanent injunctive relief. After obtaining a preliminary injunction, appellees moved for summary judgment. Appellants sought to distinguish the present case from Murdock v. Pennsylvania. They contend that appellees' solicitations bore no substantial relationship to any religious expression, and that they were therefore outside the protection of the First Amendment and that appellees were not entitled to challenge the Act until they had demonstrated that the Unification Church was a religion and that its fundraising activities were a religious practice. The Magistrate held that the Act was facially unconstitutional with respect to religious organizations, and was therefore entirely void as to such organizations, because it failed the second of the three Establishment Clause 'tests' set forth by this Court in Lemon v. Kurtzman. The District Court entered summary judgment in favor of appellees. The Eighth Circuit affirmed in part and reversed in part. It affirmed the District Court's holding that the 'inexplicable religious classification' embodied in the fifty percent rule violated the Establishment Clause. The court disagreed with the District Court's conclusion that appellees and others should enjoy the religious-organization exemption from the Act merely by claiming to be such organizations: The court held that proof of religious-organization status was required in order to gain the exemption, and left the question of appellees' status 'open . . . for further development.' It vacated the judgment of the District Court and remanded the action for entry of a modified injunction and for further appropriate proceedings.