Native American Church of Navajoland, Inc. v. Arizona Corporation Commission

Background

A Native American church in Arizona asked the state Corporation Commission for a certificate of incorporation that described using peyote as a sacrament. The Commission refused because Arizona law makes possession and use of peyote a misdemeanor and regulates it as a dangerous drug. The church sued in federal court, seeking declarations and two injunctions: one to force the Commission to grant the charter and one to stop state officers from enforcing drug laws against the church.

Reasoning

The Court examined whether the church had properly presented a federal constitutional question that would permit the extraordinary relief they sought. The Court focused on two points visible in the complaint: the church did not attack the incorporation statute itself as unconstitutional, and the pleadings did not show that state law officers were actually enforcing the drug laws against the church. Because the complaint looked like a challenge to an administrative decision rather than a direct attack on a statute’s application or enforcement, the Court upheld the lower court’s refusal to grant the requested injunctions.

Real world impact

The decision leaves in place the lower court’s denial of immediate federal protection for the church’s peyote use and its incorporation request. The church remains without a federal injunction against Arizona officials, and the practical barrier to getting the charter or a broad federal ruling on peyote use remains. The opinion also underscores strict pleading and procedural limits when asking federal courts to block state statutes or enforcement.

Dissents or concurrances

Justice Douglas (joined by Justices Stewart and Rehnquist) dissented, arguing a three-judge district court was not required and that this appeal should be dismissed for lack of proper three-judge-court jurisdiction.