Landmark Supreme Court Case: Reynolds v. United States (1879)
Reynolds v. United States (1879) is the 22nd landmark Supreme Court, and first in the Religion module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Reynolds v. United States (1879)
The LDS Church, believing that the law unconstitutionally deprived its members of their First Amendment right to freely practice their religion as it required them to marry multiple women, chose to challenge the Morrill Anti-Bigamy using George Reynolds, a secretary in the office of the president of the church, who provided the U.S. Attorney with numerous witnesses who could testify of his being married to two wives. He was indicted for bigamy by a grand jury on October 31, 1874
Reynolds tried to have the jury instructed that if they found he committed bigamy with the only intention of following his religion, then he must be found not guilty. The trial court refused this request and instructed the jury that if they found that Reynolds, under religious influence:
deliberately married a second time, having a first wife living, the want of consciousness of evil intent—the want of understanding on his part that he was committing crime—did not excuse him, but the law inexorably, in such cases, implies criminal intent.
Reynolds was convicted and sentenced to two years hard labor in prison and a fine of five hundred dollars in 1875. In 1876 the Utah Territorial Supreme Court upheld the sentence.
Reynolds Legal Questions and Answers
Q: Is religious duty or belief a defense to criminal indictment?
A: No. Religious duty is not a defense to a criminal indictment.
Unanimous decision ruling the federal anti-bigamy statute does not violate the religious Free Exercise Clause of the First Amendment as it protects the right to hold any religious belief, but not the right to engage in any religious activity whatsoever. The First Amendment forbade Congress from legislating against opinion, but allowed it to legislate against action. Supreme Court of Utah affirmed.
The Court recognized that under the First Amendment, the Congress cannot pass a law that prohibits the free exercise of religion. However it held that the law prohibiting bigamy did not meet that standard. The principle that a person could only be married singly, not plurally, existed since the times of King James I of England in English law, upon which United States law was based.
Reynolds was the first Supreme Court opinion to address the First Amendment’s protection of religious liberties, impartial juries and the Confrontation Clauses of the Sixth Amendment. It established marriage as regulated by law in most civilized nations in spite of its sacred obligation.
The Court ruled polygamy should be criminalized for it was:
odious among the northern and western nations of Europe, and, until the establishment of the Mormon Church, almost exclusively a feature of the life of Asiatic and of African people.
If polygamy was allowed, someone might eventually argue that human sacrifice or bride burning was a necessary part of their religion and:
to permit this would be to make the professed doctrines of religious belief superior to the law of the land, and in effect to permit every citizen to become a law unto himself.
Quoting Thomas Jefferson, the Reynolds court highlights the distinction between religious belief and action that flowed from religious belief. The former “lies solely between man and his God,” therefore “the legislative powers of the government reach actions only, and not opinions.”
Next Religion Case: Cantwell v. Connecticut (1940)
Next Case: Strauder v. West Virginia (1880)
Previous Case: Munn v. Illinois (1877)