Reynolds v. United States was the first US Supreme Court ruling to interpret the First Amendment's Free Exercise Clause. George Reynolds, secretary to Brigham Young, was convicted under an 1862 federal anti-bigamy statute for practicing plural marriage as a matter of Latter Day Saint religious belief. The Court unanimously upheld the conviction in 1879, holding that the Constitution protects religious belief absolutely but not every religiously motivated action, a distinction that shaped American religious liberty law for more than a century afterward.
Facts
The Event
When It HappenedDecided 6 January 1879. 1 Where It HappenedWashington, D.C., the Supreme Court of the United States; the prosecution began in the federal territorial court in Utah Territory. 1 Principal PartiesGeorge Reynolds, secretary to Brigham Young, prepared by the church hierarchy to bring a test case; Chief Justice Morrison Waite, who wrote for a unanimous Court. 1 Scholarship
Where It Is RecordedReported at 98 U.S. 145 (1879) in the United States Reports. 1 How Its Legacy Is ContestedThe opinion's characterization of polygamy has drawn later criticism for its reliance on nineteenth century framing, but the belief-action distinction it announced still structures free exercise doctrine over a century later. 2 Consequences
What It SettledThe Court unanimously upheld Reynolds's conviction, holding that the Constitution protects religious belief absolutely but not every religiously motivated action, a distinction that shaped American religious liberty law for more than a century afterward. 2 Status
Legal StatusEstablished that the First Amendment protects religious belief absolutely but not every religiously motivated practice, upholding Reynolds's conviction under the 1862 federal anti-bigamy statute; a professed religious duty to practice plural marriage was held not to excuse the crime. 1 Cross-Tradition Connections
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