Wednesday, November 6, 2013

Larson v. Valente case brief

Larson v. Valente case brief summary
456 U.S. 228 (1982)

Appellant officials sought review of a judgment of the United States Court of Appeals for the Eighth Circuit, which held that appellees, a church and its followers, had standing to challenge the Minnesota charitable solicitations act (Act), Minn. Stat. §§ 309.50-309.61 (1969 & Supp. 1982) and that the Act was unconstitutional.

The church and its followers contended that the Act constituted an abridgment of their First Amendment rights of expression and free exercise of religion, as well as a denial of their right to equal protection of the laws. The church specifically challenged Minn. Stat. § 309.515(1)(b), which imposed registration and reporting requirements upon only those religious organizations that solicited more than 50 percent of their funds from nonmembers. The district court granted the relief sought by the church. The court of appeals affirmed in part and reversed in part, holding that the church could not enjoy the religious-organization exemption from the Act merely by claiming to be such an organization.


  • The court affirmed, noting first that the church and its followers had standing to challenge the Act. 
  • The court next determined that the Act was unconstitutional because it was not closely fitted to the furtherance of any compelling governmental interest and its enforcement was fraught with the sort of government entanglement forbidden by the Constitution.

The court affirmed the judgment of the court of appeals, holding that the church and its followers had standing to challenge the Act and that the Act violated the Establishment Clause of the First Amendment.

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