Saturday, December 7, 2013

Mueller v. Allen case brief

Mueller v. Allen case brief summary
463 U.S. 388 (1983)

Petitioner taxpayers sought review of a judgment of the United States Court of Appeals for the Eighth Circuit, which upheld Minn. Stat. § 290.09, subd. 22 (1982), against a challenge under the Establishment Clause of the First Amendment. Petitioners claimed that the statute ran afoul of the clause in the tax relief that it afforded to the parents of parochial school children.

Minn. Stat. § 290.09, subd. 22 (1982) provided that parents could deduct tuition, textbook, and transportation expenses of their children in elementary and secondary schools. The deduction primarily benefitted the parents of children attending parochial schools because tuition, textbooks, and transportation were provided free to public school children. The district court and court of appeals both held that the statute did not violate the Establishment Clause.

  • The Court applied a three-part test to determine whether the statute violated the clause. 
  • First it held that the statute had a secular purpose: to advance the education of its populace. 
  • Second, it held that the primary effect of the statute neither advanced nor inhibited religion. 
  • In this regard the Court held that it was important that the statute was a genuine tax deduction, that it was neutral on its face, and that it provided only indirect support to parochial schools through the individual choices of parents to send their children to those schools. 
  • Finally, the Court held that the statute did not foster an excessive government entanglement with religion.

The Court affirmed the decision of the court of appeals upholding the Minnesota statute under the Establishment Clause.

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