Reynolds v. United States, 98 U.S. 145 (1878)

CASE: Man convicted of polygamy appeals jury instruction and trial court's decision to not instruct the jury differently

FACTS: Reynolds, a Mormon living in the Territory of Utah, married a second wife in contravention of applicable Territorial law. He argued that it was his duty to practice polygamy as a member of the Church of Jesus Christ of Latter-Day Saints. He requested the court to instruct the jury that if they found that he had married in pursuance of and conformity with what he believed at the time to be a religious duty, their verdict should be "not guilty". Instead, the court instructed the jury that if Reynolds, under the influence of a religious belief that it was right, had "deliberately married a second time, having a first wife living, the want of consciousness of evil intent—the want of understanding on his part that he was committing crime—did not excuse him, but the law inexorably, in such cases, implies criminal intent."

REYNOLDS ARGUES: Because he was acting in concert with his religious beliefs, punishing Reynolds for polygamy amounts to violating his rights under the Fourth Amendment. Therefore, the law outlawing polygamy is unconstitutional.

COURT SAYS: Court instruction proper.

HOLDING: Court's instruction that a jury need not establish a man's intent to break the law forbidding polygamy in order to find him guilty of the offense did not violate his First Amendment rights to the free exercise of religion; the fact that he broke the law in pursuit of his religious duty offered the man no protection in the eyes of the law.

RATIONALE:

• Because society is built upon the civil contract of marriage, the government can permissibly pass laws regulating marriage.
• Permitting a certain class of people to willfully defy the nation's laws without repurcussions in the name of religious liberty would permit every citizen to become a law unto himself and lead to the existance of a government in name only.
• While laws of the nation cannot interfere with religious beliefs and opinions, they can interfere with religious practices.

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