Introduction

In Corporation of the Presiding Bishop of The Church of Jesus Christ of Latter-day Saints et al. v. Amos et al., 483 U.S. 327 (1987), the United States Supreme Court addressed the constitutionality of §702 of the Civil Rights Act of 1964. This landmark case scrutinized whether the exemption provided to religious organizations from Title VII's prohibition of religious discrimination in employment violated the Establishment Clause of the First Amendment. The plaintiffs, including Mayson, a former employee of a nonprofit facility run by the Church of Jesus Christ of Latter-day Saints, alleged that their discharge based on religious qualifications constituted unlawful discrimination. The Supreme Court's decision reinforced the legitimacy of §702's exemptions, establishing a significant precedent in the interplay between religious freedom and anti-discrimination laws.

Summary of the Judgment

The Supreme Court held that §702 of the Civil Rights Act, which exempts religious organizations from Title VII's prohibition against employment discrimination based on religion, does not infringe upon the Establishment Clause when applied to secular activities of these organizations. The Court reasoned that §702 serves a legitimate secular purpose—maintaining governmental neutrality towards religion—and its primary effect neither advances nor inhibits religion. Consequently, the Court reversed the District Court's decision, which had found §702 unconstitutional in this context, and remanded the case for further proceedings consistent with its opinion.

Analysis

Precedents Cited

The judgment extensively referenced several pivotal cases to underpin its reasoning:

• LEMON v. KURTZMAN, 403 U.S. 602 (1971): Established the three-part Lemon test to evaluate violations of the Establishment Clause, assessing secular purpose, primary effect, and entanglement.
• Walz v. Tax Comm'n, 397 U.S. 664 (1970): Upheld property tax exemptions for religious organizations, emphasizing non-advancement or inhibition of religion by government action.
• ESTATE OF THORNTON v. CALDOR, INC., 472 U.S. 703 (1985): Demonstrated the Court's willingness to invalidate statutes that require employers to accommodate employees' religious practices if they impose undue burdens.
• BOARD OF EDUCATION v. ALLEN, 392 U.S. 236 (1968): Upheld loans of schoolbooks to religious schools, supporting accommodation without endorsement.
• Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976): Highlighted the importance of autonomy for religious organizations in internal governance.

These precedents collectively illustrate the Court's stance on balancing religious freedom with governmental neutrality, particularly in employment contexts.

Legal Reasoning

The Court's legal reasoning centered on the applicability of the Lemon test to §702. It systematically evaluated each prong of the test:

1. Secular Legislative Purpose: The Court affirmed that §702 serves a legitimate secular purpose by ensuring governmental neutrality and minimizing interference with religious organizations' internal affairs. This aligns with the principle that the government should not promote or inhibit religious activities.
2. Primary Effect: The exemption's primary effect does not advance or inhibit religion. The Court clarified that allowing religious organizations to advance their mission through exemptions is not unconstitutional, provided the government itself does not endorse religious activity.
3. Entanglement: §702 does not create an excessive entanglement between church and state. Instead, it promotes a "benevolent neutrality," allowing religious organizations to operate without undue governmental interference.

Additionally, the Court addressed equal protection arguments, holding that §702 does not require strict scrutiny since it is facially neutral and serves a legitimate purpose without discriminating against secular entities.

Impact

The decision in Church of Jesus Christ of Latter-day Saints v. Amos has profound implications:

• Employment Practices: Religious organizations retain the ability to set employment conditions based on religious qualifications without constituting a constitutional violation.
• Legal Precedent: Reinforces the legitimacy of exemptions that allow religious entities to govern their internal affairs, especially in nonprofit contexts, without breaching the Establishment Clause.
• Future Litigation: Provides a framework for evaluating similar cases where religious exemptions intersect with anti-discrimination laws, emphasizing the importance of secular purpose and primary effect.
• Separation of Church and State: Strengthens the doctrine of separation by affirming that certain accommodations for religious organizations do not equate to government endorsement of religion.

Complex Concepts Simplified

Lemon Test

The Lemon test, derived from LEMON v. KURTZMAN, is a judicial tool to assess whether a law violates the Establishment Clause. It comprises three criteria:

• Secular Purpose: The law must have a non-religious objective.
• Primary Effect: The law's main impact should not advance or inhibit religion.
• Entanglement: The law should not result in excessive government involvement with religious institutions.

For a law to pass the Lemon test, it must satisfy all three criteria, ensuring a balance between religious freedom and governmental neutrality.

Establishment Clause

Part of the First Amendment, the Establishment Clause prohibits the government from making any law "respecting an establishment of religion." This means the government cannot favor one religion over another or religion over non-religion, maintaining a separation between church and state.

§702 of the Civil Rights Act of 1964

This section exempts religious organizations from Title VII's prohibition against employment discrimination based on religion. Specifically, it allows these organizations to employ individuals of a particular religion to perform work connected with their religious activities.

Free Exercise Clause

Also part of the First Amendment, the Free Exercise Clause protects individuals' rights to practice their religion as they please, so long as the practice does not run afoul of public morals or a compelling governmental interest.

Conclusion

The Supreme Court's decision in Church of Jesus Christ of Latter-day Saints v. Amos serves as a pivotal affirmation of religious organizations' autonomy in employment practices, provided such exemptions align with secular legislative purposes and do not advance or inhibit religion. By upholding §702, the Court reinforced the delicate balance between accommodating religious freedoms and maintaining governmental neutrality, particularly within nonprofit settings. This judgment not only clarifies the scope of permissible exemptions but also shapes the landscape for future interactions between religious institutions and civil rights laws, ensuring that the foundational principle of separation of church and state remains intact.