Background:
In the late 19th and early 20th centuries, The Church of Jesus Christ of Latter-day Saints (LDS Church), commonly known as the Mormon Church, practiced polygamy as part of their religious beliefs. However, the U.S. government began to challenge and prosecute polygamist practices, considering them to be a violation of federal laws against bigamy. Several Mormon leaders and followers faced legal challenges and criminal prosecutions.
The Case:
In 1931, two polygamist Mormon families, William Marbury Hill and his three wives, and Alma A. Waxberg and his three wives, challenged their convictions for practicing polygamy in the federal district court of Utah. The polygamists contended that their religious beliefs protected their actions under the First Amendment, which guarantees the free exercise of religion. They argued that the government was infringing on their religious rights by prosecuting them.
Supreme Court Decision:
The case eventually reached the Supreme Court. In a 6-3 decision, the Supreme Court ruled against the polygamists. Justice Benjamin N. Cardozo wrote the majority opinion, which rejected the argument that the free exercise of religion protected individuals from criminal prosecutions for violating generally applicable laws. The Court held that the government's interest in maintaining social order and public morals justified the restriction on polygamy, despite its religious significance for certain individuals.
Key Points:
1. Free Exercise of Religion: The Supreme Court acknowledged the importance of religious freedom and the First Amendment's protection of religious practices. However, the Court clarified that religious liberty is not absolute and can be limited when conflicting with other compelling state interests.
2. Compelling State Interest: The Court determined that the government's interest in protecting social order and preventing harm to society justified the prohibition of polygamy. It argued that polygamy had potential negative societal impacts, including social instability and the exploitation of women.
3. Hierarchy of Laws: The Supreme Court established that generally applicable criminal laws, such as the ban on polygamy, take precedence over religious practices when there is a conflict between the two. Individuals cannot claim religious exemptions to escape criminal liability for violating laws that are valid and applicable to everyone.
4. Dissenting Opinions: Three Justices dissented from the majority opinion. They expressed concerns about the government's interference with religious practices and argued that the state had not shown a compelling interest sufficient to justify the infringement on religious freedom in this case.
The Hill v. Waxberg decision marked a significant turning point in the legal treatment of religious practices in the United States. It established that the free exercise of religion does not grant immunity from criminal prosecution and reaffirmed the government's authority to regulate conduct in the interest of public order, even when such conduct is religiously motivated.