Trinity Lutheran Church of Columbia, Inc. v. Comer
Headline: Court bars Missouri from excluding churches from a playground-resurfacing grant program, ruling the state’s policy unlawful and allowing religious groups to compete for Scrap Tire playground grants.
Holding: The Court held that Missouri’s policy excluding a church from a generally available playground-resurfacing grant solely because it is a church violates the Free Exercise Clause and must be struck down.
- Lets churches compete for state playground-resurfacing grants.
- Limits states’ ability to categorically ban religious groups from public benefits.
- May prompt states to revise rules that bar houses of worship from funding programs.
Summary
Background
Trinity Lutheran Church operates a daycare and a playground and applied for a state Scrap Tire Program grant to resurface the playground. Missouri denied the church’s application based on its State Constitution provision that bars public funds from aiding churches. The Church sued, lower courts ruled against it, and the case reached this Court for review.
Reasoning
The Court focused on the Free Exercise protection against laws that single out religious people or organizations for disfavored treatment. It explained that denying a generally available public benefit solely because an applicant is a church imposes a penalty on religious exercise and demands the strictest judicial review. The Court rejected Missouri’s reliance on an antiestablishment interest and distinguished an earlier scholarship case where the denial turned on the religious use of funds. Because Missouri’s rule excluded the church from competing just for being a church, the Court found that the policy could not survive strict scrutiny and therefore violated the Free Exercise Clause. The Court reversed the Eighth Circuit and sent the case back for further proceedings.
Real world impact
The ruling means qualified religious organizations may no longer be categorically barred from competing for this kind of state playground grant. States that had similar rules will face challenges applying blanket bans on houses of worship. The decision left open some limits and drew separate concurring and dissenting views about how far the rule applies to other programs.
Dissents or concurrances
The dissent argued the decision forces public funds to churches and departs from long history and Establishment Clause concerns; concurrences debated status-versus-use distinctions and narrower scope.
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