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Reynolds v. United States
 | |
| Reynolds v. United States | |
| Reference: 98 U.S. 145 | |
| Term: 1879 | |
| Important Dates | |
| Argued: Nov 14 - 15, 1878 Decided: Jan 6, 1879 | |
| Outcome | |
| Utah Territorial Supreme Court upheld | |
| Majority | |
| Joseph Bradley • Nathan Clifford • Samuel Freeman Miller • Noah Haynes Swayne • William Strong • Ward Hunt • Morrison Waite | |
| Concurring | |
| Stephen Johnson Field | |
Reynolds v. United States was a case decided by the United States Supreme Court on January 6, 1879, that held that the free exercise clause of the First Amendment did not protect the right to practice bigamy and that a federal law punishing bigamy did not violate the Constitution.[1]
Why it matters: The Supreme Court ruled the Morrill Anti-Bigamy Act constitutional. The court reasoned that under the First Amendment, Congress could not outlaw the belief in bigamy, but could outlaw the practice of bigamy. This case decided that it was Constitutional for Congress and the federal government to pass laws regarding marriage. To learn more about the aftermath of this case click here.[1]
Background
George Reynolds lived in Utah Territory and was a member of The Church of Jesus Christ of Latter-day Saints. Reynolds was already married but married a second wife. When Reynolds married the second woman he was charged with violating the federal Morrill Anti-Bigamy Act.[1]
The Church of Jesus Christ of Latter-day Saints provided Reynolds with counsel to contest the constitutionality of the Morrill Anti-Bigamy Act. Reynolds cooperated with the trial and provided evidence of his marriage to two wives.[2]
A grand jury on October 31, 1874, indicted Reynolds in the District Court for the 3rd Judicial District of the Territory of Utah Reynolds was sentenced to two years of prison with hard labor and a five hundred dollar fine. The Utah Territorial Supreme Court in 1876 upheld the sentence. Reynolds then appealed to the United States Supreme Court.[2]
Oral argument
Oral argument was held on November 14 and 15, 1878. The case was decided on January 6, 1879.[3]
Decision
The Supreme Court unanimously ruled that the federal Morrill-Anti Bigamy Act was constitutional.
Chief Justice Morrison Waite wrote for the majority opinion and was joined by Justices Joseph Bradley, Nathan Clifford, Samuel Freeman Miller, Noah Haynes Swayne, William Strong, John Harlan and Ward Hunt.[1]
Justice Stephen Johnson Field concurred with the majority's judgment and dissented in one point in the case.[1]
Opinion
- See also: Federalism
Majority opinion
Justice Morrison Waite on January 6, 1879, delivered the majority opinion, which upheld Reynolds' sentence and found that the First Amendment does not protect the right to marry multiple women simultaneously.
The majority argued that Congress had the authority to outlaw the practice of bigamy, but not the belief in the correctness of polygamy as a religious doctrine. The Supreme Court ruled that Congress could regulate marriage to maintain social order, but it could not prohibit the expression that polygamy was just:[3]
| “ | Congress cannot pass a law for the government of the Territories which shall prohibit the free exercise of religion. The first amendment to the Constitution expressly forbids such legislation….Congress was deprived of all legislative power over mere opinion, but was left free to reach actions which were in violation of social duties or subversive of good order. | ” |
Concurring opinion
Justice Stephen Johnson Field concurred with the majority's ruling but argued that the admission of Reynolds' second wife's testimony from a different case should not have been introduced into the record.[5]
Aftermath
After the case was decided, the Supreme Court was petitioned to revisit the case to discern whether the sentence of hard labor was constitutional because it did not address that part of Reynolds' sentence in its first ruling. Writing for the Supreme Court, Justice Morrison Waite remanded the case to the district court and instructed it to find an alternative to a hard labor sentence:[5]
| “ | Since our judgment in this case was announced, a petition for rehearing has been filed, in which our attention is called to the fact that the sentence of the court below requires the imprisonment to be at hard labor, when the act of Congress under which the indictment was found provides for punishment by imprisonment only. This was not assigned for error on the former hearing, and we might on that account decline to consider it now; but as the irregularity is one which appears on the face of the record, we vacate our former judgment of affirmance, and reverse the judgment of the court below for the purpose of correcting the only error which appears in the record, to wit, in the form of the sentence. The cause is remanded, with instructions to cause the sentence of the District Court to be set aside and a new one entered on the verdict in all respects like that before imposed, except so far as it requires the imprisonment to be at hard labor. | ” |
See also
External links
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 Oyez, Reynolds v. United States, accessed September 1, 2022
- ↑ 2.0 2.1 MTSU, Reynolds v. United States, accessed September 1, 2022
- ↑ 3.0 3.1 Justia, Reynolds v. United States, accessed September 1, 2022
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 5.0 5.1 Cornell Law, Reynolds v. United States, accessed September 9, 2022
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Category:Federalism court cases
Category:Noteworthy cases, federal cases
Category:Noteworthy cases, SCOTUS
Category:Noteworthy cases, upholding congressional acts and delegations of authority
Category:United States Supreme Court
Category:Historic SCOTUS cases
Category:Decided_SCOTUS_cases
