Larson v. Valente (1982)
Supreme Court Decisions on Religious Liberty
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Background Information
In 1978, Minnesota amended its charitable solicitation law. Before that, organizations soliciting funds in the state were simply required to submit forms explaining the percentage of income spent on administrative costs. If this amount went above 30 percent, organizations would be forbidden to solicit in the state. Religious groups, however, were granted an exception from this requirement. They qualified as "charitable" no matter what percentage of income went to administrative costs.
With the amendment, only those religious groups which solicited more than fifty percent of its contributions from members or affiliated organizations were exempt from registering. Any group which received more than 50 percent of its revenue from nonmembers would have to register with the state, file financial disclosure forms, and be subject to closer state scrutiny.
Right after the law took effect, state officials wrote to the Unification Church, stating that the organization would now be required to register. Several members of the Unification Church claimed that this violated the Establishment Clause and files suit.
Court Decision
With a majority opinion written by Justice Brennan, the Court ruled 5-4 that the Minnesota law was indeed unconstitutional because it placed a burden on certain religions and was not closely enough related to furthering a specific governmental interest.
Although the Court agreed that governments could have a significant interest in protecting its citizens from fraudulent charitable organizations, the Court also found that there was no justified basis in prefering one denomination over another. Therefore, the state had to prove that it had a compelling interest that is being met in passing the legislation.
The State claimed that the fifty percent requirement had the secular purpose of protecting contributors because members who contribute oversee the expenditure of their donations. This claim was rejected because even if the members can supervise the use of money, they do not necessarily have any control over the money.
It was clear to the Court that the law specifically targeted for stricter governmental oversight those religious groups which solicited funds in airports, parks, and other public places as opposed to more traditional groups which received most of their funding through the Sunday morning collection plate.
Minnesota's other claim, that the need for disclosure decreased as the percentage of outside contribution decreased, was also rejected because the importance of oversight should be related to absolute figures. The law violated the Lemon test because it favored certain religions but not others. It imposed a selective burden on certain religious groups.
Significance
This decision prohibits the government from passing laws that may or do favor certain types of religions over more popular or traditional religions. In this case, the state either had to exempt all religions from registering with the Department of Commerce or require that all religions register in order not to violate the Lemon test.
A key point to remember here is that governments are not allowed to impose greater oversight and regulation on minority, non-traditional religious groups.
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