Reynolds v. United States

1. Reynolds v. United States 1870

2. Background Information • The Morrill Anti-bigamy act  was a federal enactment of the United States Congress that was signed into law on July 8, 1862 by President Abraham Lincoln. Sponsored by Justin Smith Morrill of Vermont, the act banned bigamy, or multiple marriages, and limited church and non-profit ownership in any territory of the United States to $50,000. The act targeted the Mormon church, or the Church of the Latter Day Saints. The Mormons simply refused to obey the law, but in subsequent years, the enforcement of the law intensified.

3. Background Information (cont.) • Amid attempts by the U.S. government to indict the leadership of the L.D.S. Church, the church decided to offer a defendant, George Reynolds, to determine the constitutionality of the anti-bigamy law. Reynolds, born in 1842, had two wives and was a secretary to the first presidency  After numerous witnesses confirmed Reynolds's bigamy, he was sentenced on October 23, 1874. In 1875, Reynolds was convicted and sentenced to two years hard labor in prison and a fine of five hundred dollars. till, another appeal was attempted in 1876 with the Utah Territorial Supreme Court, but it upheld the sentence. The case then went to the United States Supreme Court after the Mormon leadership lost all faith in the U.S. attorney, William Carey, to not indict anyone. It was the first freedom of religion case in the Supreme Court.

6. The Question • Does the federal anti-bigamy statute violate the First Amendment's free exercise clause because plural marriage is part of religious practice?

7. Decision • Chief Justice Morrison R. Waite, held that the statute can punish criminal activity without regard to religious belief. The First Amendment protected religious belief, but it did not protect religious practices that weren’t beneficial to society, such as bigamy. Polygamy was lumped together with other abstract religious practices, such as human sacrifice.