In the case of Sause v. Bauer, 2017, Mary Anne Sause claimed that her First Amendment rights were violated when two police officers in Louisburg, Kansas forced her to stop praying in her own home during an investigation. The officers had been called to investigate a noise complaint and told Ms. Sause they could arrest her for disorderly conduct if she didn't comply with their orders. When she asked why she was being ordered not to pray, one officer allegedly said "because I said so." The U.S District Court dismissed the lawsuit on grounds that the officers were entitled to qualified immunity as government officials performing discretionary functions within their official capacity unless violating clearly established statutory or constitutional rights which a reasonable person would have known about. On appeal by Ms.Sause,the Supreme Court vacated this judgment and remanded it back for further proceedings consistent with its opinion stating that such an order from law enforcement preventing someone from praying at home is obviously unconstitutional.

The Supreme Court did not provide a dissenting opinion for the case of SAUSE v. BAUER, 2017. The court unanimously vacated and remanded the decision of the lower court, which had dismissed Ms. Sause's claim that her First Amendment rights were violated when police officers allegedly mocked her religious practices during an investigation at her home. The Supreme Court stated that it was unclear whether or not the lower courts had properly considered all aspects of Ms. Sause's claims before dismissing them, thus necessitating further review by a lower court.