- Date:
- June 24, 1987
- Location:
- United States
Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos
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What was the law case called Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos about?
Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos was a U.S. Supreme Court case about religious discrimination. The Court ruled that organizations affiliated with the Church of Jesus Christ of Latter-day Saints (LDS) did not commit religious discrimination under Title VII of the Civil Rights Act of 1964 when they fired employees who refused or were ineligible to become members of the church.
The case centered on Arthur F. Mayson, who was fired from his job at a nonprofit gymnasium run by the LDS church for not being a member. Mayson claimed this violated Section 703 of Title VII of the Civil Rights Act, which prohibits employers from discriminating based on religion.
In a 9–0 decision, the Supreme Court held that Section 702 of the act did not violate the First Amendment’s establishment clause, which generally prohibits the government from establishing or favoring any religion.
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Who were the main people or groups involved in this case?
The Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos case involved several key parties. The Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints was the defendant, claiming its actions were protected by Section 702 of the Civil Rights Act. Arthur F. Mayson, along with Christine J. Amos and others, were the plaintiffs who alleged religious discrimination after being fired for not being members of the Church of Jesus Christ of Latter-day Saints (LDS). The case ultimately reached the U.S. Supreme Court, which delivered the final ruling.
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Why did this legal dispute happen in the first place?
The legal dispute in Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos arose after Arthur F. Mayson, a building manager at a gymnasium run by the Church of Jesus Christ of Latter-day Saints (LDS), was fired for not being a member of the church. Mayson claimed religious discrimination under Title VII of the Civil Rights Act of 1964, while the church argued that Section 702 of the act protected their actions. This section allows religious organizations to employ individuals of a particular religion. The employees countered that the Section 702 exemption promoted religion, violating the establishment clause of the First Amendment when applied to nonreligious jobs.
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What important question or issue about religion and employment did this case address?
The Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos case addressed whether religious organizations could be exempt from the Civil Rights Act of 1964's Title VII, which prohibits employment discrimination based on religion. Specifically, the case questioned if Section 702 of the act, which allows religious organizations to prioritize employing members of their own religion, violates the First Amendment's establishment clause.
The Supreme Court ruled that the LDS church did not commit religious discrimination when it fired employees who didn't adhere to church membership requirements. The court held that Section 702 did not violate the establishment clause, as it's not unconstitutional for religious organizations to advance their beliefs, only for the government to do so.
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How did the Supreme Court rule in this case, and what reasons did they give?
In Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos, the Supreme Court ruled (9–0) on June 24, 1987, that organizations affiliated with the Church of Jesus Christ of Latter-day Saints (LDS) did not commit religious discrimination under Title VII of the Civil Rights Act of 1964 when they fired employees who were not members of the church.
The Court applied the Lemon test, finding that Section 702 had a secular legislative purpose and did not advance religion, as it was the LDS church, not the government, that fired its employees. The Court held that there was no impermissible entanglement between church and state because it was the LDS church, not the government, that dismissed the employees; thus, their rights were not violated.
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How has this case affected laws or rules about religion and jobs in the United States?
The Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos case centered around whether religious organizations could be exempt from the Civil Rights Act of 1964's Title VII, which prohibits employment discrimination based on religion.
In a unanimous decision, the Supreme Court ruled that the Church of Jesus Christ of Latter-day Saints did not commit religious discrimination when it fired employees who did not meet church membership eligibility requirements. The Court held that Section 702 of the act, which allows religious organizations to favor members of their own religion in employment, did not violate the First Amendment's establishment clause.
This ruling clarified that religious organizations can favor their members in employment, even for non-religious jobs. However, employees may have reasons for not being vaccinated, such as medical conditions or religious beliefs, and may be required to disclose sensitive personal information that could be used against them.
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Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints v. Amos, case in which the U.S. Supreme Court on June 24, 1987, ruled (9–0) that organizations affiliated with the Church of Jesus Christ of Latter-day Saints (LDS) had not committed religious discrimination under Title VII of the Civil Rights Act of 1964 when they fired employees who refused or were ineligible to become members of the church. In its decision the court held that Section 702 of the act did not violate the First Amendment’s establishment clause, which generally prohibits the government from establishing, advancing, or giving favour to any religion.
The case centred on Arthur F. Mayson, a building manager at the Deseret Gymnasium, a nonprofit facility that was run by two organizations affiliated with the LDS church, one of which was the Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints. In 1981, after being employed at the gymnasium for some 16 years, Mayson was fired for not becoming a member of the LDS church. He filed suit, alleging a violation of Section 703 of Title VII of the Civil Rights Act, which prohibits an employer from discriminating on the basis of religion; his case was later combined with one filed by Christine J. Amos and others. The defendants, however, claimed that their actions were protected by Section 702, which states that
The subchapter…shall not apply…to a religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities.
The employees countered that allowing religious employers to be exempt from liability under Section 702 for nonreligious jobs would, in actuality, have promoted religion in violation of the establishment clause.
A federal district court ruled in favour of Mayson. It noted that the gymnasium was “intimately connected to the Church” and that there was no obvious link between the gymnasium’s primary function and the beliefs of the LDS church. In addition, the former employees’ duties were not religious in nature. Thus, the court held that the case centred on “nonreligious activity.” Having made that finding, it addressed the constitutionality of Section 702 by applying the so-called Lemon test, which the Supreme Court had outlined in Lemon v. Kurtzman (1971). The test required that a statute must (a) have “a secular purpose,” (b) “have a primary effect that neither advances nor inhibits religion,” and (c) “avoid[s] excessive government entanglement with religion.” Although the court held that Section 702 met the first requirement, it found that the law advanced religion, a violation of the second prong. The court noted that the section “single[d] out religious entities for a benefit” and that it “burdens the free exercise rights of employees of religious institutions who work in nonreligious jobs.”
On March 31, 1987, the case was argued before the U.S. Supreme Court. The court also applied the Lemon test but reached a different result. It agreed with the lower court’s finding that Section 702 had a “secular legislative purpose.” As to the second prong, however, the court found that the section did not advance religion. The court pointed out that it is not unconstitutional for religious organizations to advance their beliefs. Rather, the court explained, it is only forbidden for the government to advance religion through its influence and activities. Moreover, the court observed that it was the LDS church, not the government, that fired its employees. When considering the third prong, the court held that there was no impermissible entanglement between church and state. In its application of the test, the court was of the view that because it was the LDS church, not the government, that dismissed the employees, their rights were not violated. The decision of the district court was reversed.