U.S. v. Ballard (1944)
Supreme Court Decisions on Religious Liberty
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Background Information
Guy Ballard was the leader of the "I Am" Movement and claimed to have had remarkable spiritual experiences - including personal encounters with Saint Germain and even Jesus. As a result of these experiences, he believed that he knew things like the secret of good and even claimed that he could heal incurable diseases.
Ballard and his family sent out mass mailings repeating these claims and soliciting contributions in exchange for his healing services. The government claimed that he 'well knew' that these claims were false and he used them to defraud others of their money - thus, he was convicted of mail fraud. Ballard challenged his conviction by arguing that the government had no right to judge his religious beliefs in this manner.
Court Decision
The question before the court was basically whether the truth or falsity of the Ballards' theology was a material issues - in the initial trial, the jury was told not to consider Ballard's religious beliefs and instead they were instructed to determine whether the defendant believed that he possessed the ability to heal others.
In other words, the constitutional issue was whether or not the courts or the government have the right to evaluate the religious beliefs of a citizen or group. The Supreme Court ruled to the contrary, finding that that it was proper for the jury to base its decision on the sincerity of Ballard's beliefs.
The content of the teachings of the 'I Am' movement were found to be immaterial because the content of religious convictions could not be evaluated as either correct or incorrect - the fact that people have the right to believe what they want means that the government is not permitted to make judgements about the validity of those beliefs. As Justice William O. Douglas stated, writing for the majority:
Freedom of thought, which includes freedom of religious belief, is basic to the society of free men. It embraces the right to maintain theories of life and death of the hereafter which are rank heresy to followers of the orthodox faiths. Heresy trials are foreign to our Constitution. Mean may believe what they cannot prove. They may not be put to the proof of their religious doctrines or beliefs. Religious experiences which are as real as life to some may be incomprehensible to others. Yet the fact that they may be beyond the ken of mortals does not mean that they can be made suspect before the law.
...Man's relationship to his God was made no concern of the state. He was granted the right to worship as he pleased and to answer to no man for the verity of his religious views.
Because of the First Amendment, heresy is not a valid offense in the United States. All that was really at issue was whether Ballard honestly believed that he possessed the powers he claimed.
Significance
This decision prevented juries from being asked to consider whether a person's religious beliefs were ever true. All that mattered was that the person accept them in good faith; no government was allowed to attempt to determine if they are logical, valid, or accurate. This is of particular concern to minority religious faiths and so-called "cults" which are often the target of government action.
This decision did not mean that no religious groups could be prosecuted for fraud - for example, they could not promise to do one thing with donations and then do another. But even such cases, the government must take care not to make any judgements about the group's theological positions.
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