Term: 2016
Docket: 15-577
Trinity Lutheran Church v. Comer, Director, Missouri Department Of Natural Resources
- Pro
15-577 TRINITY LUTHERAN CHURCH V. COMER DECISION BELOW: 788 F.3d 779 CERT. GRANTED 1/15/2016 QUESTION PRESENTED: Trinity Lutheran Church applied for Missouri's Scrap Tire Grant Program so that it could provide a safer playground for children who attend its daycare and for neighborhood children who use the playground after hours--a purely secular matter. But the state denied Trinity's application solely because it is a church. The Eighth Circuit affirmed that denial by equating a grant to resurface Trinity's playground using scrap tire material with funding the devotional training of clergy. The Eighth Circuit's decision was not faithful to this Court's ruling in Locke v. Davey, 540 U.S. 712 (2004), and deepened an existing circuit conflict. Three lower courts--two courts of appeals and one state supreme court--interpret Locke as justifying the exclusion of religion from a neutral aid program where no valid Establishment Clause concern exists. In contrast, two courts of appeals remain faithful to Locke and the unique historical concerns on which it relied. The question presented is: Whether the exclusion of churches from an otherwise neutral and secular aid program violates the Free Exercise and Equal Protection Clauses when the state has no valid Establishment Clause concern. LOWER COURT CASE NUMBER: 14-1382
The Trinity Lutheran Church v. Comer case in 2016 revolved around the issue of religious institutions receiving public funds for non-religious purposes. The Missouri Department of Natural Resources denied a grant to Trinity Lutheran Church that would have been used to resurface their playground, citing a state constitutional provision prohibiting direct government aid to educational institutions with any religious affiliation. The church sued, arguing this violated their rights under the Free Exercise Clause of the First Amendment and Equal Protection Clause of the Fourteenth Amendment. In a 7-2 decision, the Supreme Court ruled in favor of Trinity Lutheran Church stating that excluding churches from such public benefit programs violates their right to free exercise by forcing them to choose between maintaining their religious identity or being eligible for government benefits.
In the dissenting opinion for Trinity Lutheran Church v. Comer, Justice Sonia Sotomayor, joined by Justice Ruth Bader Ginsburg, argued that the Court's decision drastically deviates from precedent and alters the relationship between church and state in a way that threatens religious freedom. They contended that Missouri’s policy did not infringe upon Trinity Lutheran’s right to exercise its religion because it could still run its playground without government funding. The justices emphasized that this case was about public funds being used to support a religious institution - something they believed should be avoided due to potential conflicts with the Establishment Clause of the First Amendment which prohibits government sponsorship of religion. They expressed concern over where this new interpretation might lead as it seemed to open up possibilities for direct state subsidization of religious activities.
