Trinity Lutheran Church of Columbia, Inc. v. Comer

Following is the case brief for Trinity Lutheran Church of Columbia, Inc. v. Comer, 137 S. Ct. 2012 (2017)

Case Summary of Trinity Lutheran Church of Columbia, Inc. v. Comer:

  • Trinity Lutheran Church has a Child Learning Center with a playground.
  • It sought to resurface the playground with rubber by obtaining a grant through the State of Missouri’s Scrap Tire Program, which resurfaces property using recycled tires.
  • The State’s Department of Natural Resources denied the grant because the State Constitution does not allow public funds to be given directly to a church.
  • The Center sued in federal court.
  • The District Court dismissed the suit based on the Court’s decision in Locke v. Davey, and the Eighth Circuit affirmed.
  • The U.S. Supreme Court reversed.  It held that denying a public benefit solely because of an entity’s status as a church violates the Free Exercise Clause of the First Amendment.

Trinity Lutheran Church of Columbia, Inc. v. Comer Case Brief

Statement of the Facts:

Trinity Lutheran Church Child Learning Center is a Missouri pre-school and daycare center that operates a playground on church property.  The Center applied for a State grant through the Missouri Scrap Tire Program, which would provide a rubber surface to the playground using recycled tires.

The State’s Department of Natural Resources, which administers the selective grants, denied the Center’s grant request.  The denial was based on its policy of denying grants to churches or other religious entities, because the Missouri Constitution does not allow financial assistance to be given directly to a church.  The Center sued in federal court, claiming a violation of the First Amendment’s Free Exercise Clause.

Procedural History:

  • The District Court dismissed the Center’s suit. Relying on Locke v. Davey, the District Court held that the Free Exercise Clause prohibits outlawing the exercise of religious practice, but does not prohibit withholding an affirmative benefit based on religion.
  • The Eighth Circuit affirmed.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Did Missouri’s denial of the Scrap Tire Program grant to the Trinity Church Center violate the Free Exercise Clause of the First Amendment?  Yes.

Judgment:

The decision of the Eighth Circuit Court of Appeals is reversed and remanded.

Rule of Law or Legal Principle Applied:

Withholding an otherwise available public benefit on account of its religious status violates the Free Exercise Clause of the First Amendment.

Reasoning:

The denial of a generally available benefit solely based on religion is a penalty on the free exercise of religion.  In McDaniel v. Paty, the Court struck down a State law that prohibited ministers from serving as delegates to the State’s constitutional convention because a benefit was denied solely because of a person’s status as a minister.

The Missouri policy here does the same thing – denies a public benefit solely because of an entity’s religious character.  Further, Locke v. Davey is distinguishable because the scholarship denial in that case was based on what the scholarship recipient proposed to do – study religion.  Here, the Center is being discriminated against because of what it is – a church, not what it proposes to do.  Thus, the Center is being improperly forced, under Missouri’s policy, of choosing between being a church and receiving a government benefit.

Concurring and Dissenting Opinions:

Concurring Opinion (Thomas):

The Court should have expressly overruled Locke v. Davey.

Concurring Opinion (Gorsuch):

The line between discrimination based on religious status and religious use is a tough one to enforce.  Thus, Locke is called into question.  Also, this case should have broad application – not just limited to playgrounds.

Concurring Opinion (Breyer):

The benefit here is similar to the public benefit of fire or police protection.  Therefore, the fact that the Center is attached to a church is of no moment.

Dissenting Opinion (Sotomayor):

This case is not just about a playground.  Rather, it is about the relationship between religious entities and the civil government.  The Court’s decision profoundly changes that relationship by holding – for the first time – that the Constitution requires the government to provide public funds directly to a church.  That decision offends the Court’s history, its precedents, and the separation of church and state itself.

In this case, the Center, including its playground, is being used to spread specific religious views.  The Court’s opinion ignores precedent, and history, and barely mentions the Establishment Clause, in finding it required that the taxpayers should give money directly to a church.  The Court’s amnesia of the Establishment Clause demonstrates either its misunderstanding of the facts or a startling departure from precedent.

Plainly stated, the government may not directly fund religious exercise, based on Everson v. Board of Ed. of Ewing.  Here, the Court is allowing funds to flow directly from the public treasury to a house of worship.

Significance:

Trinity Lutheran Church of Columbia, Inc. v. Comer is a significant decision because it has the troubling implication of, as Justice Sotomayor states, taking public taxpayer money and giving it directly to a church – which endangers the separation of church and state.  The majority opinion appears to rest on semantics and tricky turns of phrase (religious status vs. religious use) to try to distinguish clear Court precedents like Locke v. Davey in order to arrive at its conclusion.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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