McGowan v. Maryland
Headline: Courts upheld Maryland's Sunday closing laws, rejecting equal protection, vagueness, and establishment challenges and leaving Sunday sales restrictions and exemptions in place for retailers and their employees.
Holding: The Court affirmed convictions under Maryland’s Sunday sales law, holding the statutory exemptions rational, the challenged provision not unconstitutionally vague, and the law not an unlawful establishment of religion.
- Allows states to enforce Sunday sales bans with specified exemptions.
- Permits local variations in Sunday business rules affecting retailers and employees.
- Limits vagueness and equal protection attacks on similar day-of-rest laws.
Summary
Background
Seven employees of a large discount department store in Anne Arundel County were prosecuted for selling ordinary merchandise on Sunday under Maryland law. The Maryland statutes generally barred Sunday commercial activity but listed many exceptions (tobacco, candy, milk, newspapers, gasoline, drugs, and broader exceptions in Anne Arundel County for foodstuffs, boating accessories, souvenirs, and small shops). The employees were convicted, fined five dollars and costs, and state courts affirmed before the case reached this Court.
Reasoning
The Court considered three main challenges: that the classifications in the law violated equal protection, that some exemptions were unconstitutionally vague, and that the law violated religious liberty by effectively establishing religion. The Justices concluded the exemptions could be rationally related to health, recreation, and enforcement concerns, so the equal protection claim failed. The Court held the county exemption was not unconstitutionally vague for ordinary businesspeople. On religion, the Court found the challengers lacked standing to press a free-exercise claim based only on economic injury but had standing to assert an establishment claim; after reviewing history and the statutes’ present text and effect, the majority concluded the modern purpose and operation are secular: providing a general day of rest and recreation, not coercing or officially aiding religion.
Real world impact
The ruling permits Maryland to keep its detailed Sunday sales rules and county exceptions in force. Retailers and employees remain subject to different legal treatment on Sundays depending on products sold and local exceptions. The decision recognizes state flexibility to pick a common day of rest and to tailor exceptions for local conditions.
Dissents or concurrances
A separate opinion by Mr. Justice Frankfurter emphasized historical study and urged limited further proceedings in one related case; Justice Douglas dissented, arguing the laws coerce conformity with majority religious practice and burden religious minorities.
Opinions in this case:
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