REYNOLDS v. UNITED STATES

Legal Principle at Issue

Whether a conviction for bigamy violated the First Amendment rights of a member of the Church of Jesus Christ of Latter-Day Saints, who asserted that faithful practice of his religion required him to engage in polygamy.

Action

Affirmed (includes modified). Petitioning party did not receive a favorable disposition.

Facts/Syllabus

George Reynolds, a member of the Church of Jesus Christ of Latter-Day Saints, more commonly known as the Mormon Church, was convicted by a jury in the Utah Territory of bigamy for engaging in a plural marriage. Reynolds raised several assignments of error, some related to evidence law and criminal procedure, and including an assertion that his conviction for bigamy violated his right to freely exercise his religion as guaranteed by the First Amendment. Reynolds contended that his religion encouraged and in some circumstances mandated plural marriage, and offered testimony in support of this. Nonetheless, he was convicted. The Supreme Court upheld his conviction, stating that to hold otherwise would allow absurd results and permit religious beliefs to rise above the law. Allowing Reynolds's religious defense would, according to the Court, "permit every citizen to become a law unto himself. Government could only exist in name under such circumstances." Reynolds v. United States, 98 U.S. 145, 167 (1878).

Importance of Case

Religious beliefs do not rise above the law; to allow Reynolds to escape conviction as a result of his faith could, in the Court's view, also allow human sacrifice in the name of religion as well. Reynolds, 98 U.S. at 166. Such a result is untenable.