Reynolds v. United States

Reynolds v. United States
Supreme Court of the United States
Argued November 14–15, 1878 Decided January 6, 1879
Full case name	George Reynolds v. United States
Citations	98 U.S. 145 (more) 25 L. Ed. 244; 1878 U.S. LEXIS 1374; 8 Otto 145
Prior history	Defendant convicted, District Court for the 3rd Judicial District of the Territory of Utah; conviction upheld by Utah Territorial Supreme Court
Holding
Religious duty was not a suitable defense to a criminal indictment.
Court membership
Case opinions
Majority	Waite, joined by Clifford, Swayne, Miller, Strong, Bradley, Hunt, Harlan
Concurrence	Field
Laws applied
Sect. 5352 of the Revised Statutes

Reynolds v. United States, 98 U.S. (8 Otto.) 145 (1878), was a Supreme Court of the United States case that held that religious duty was not a defense to a criminal indictment. Reynolds was the first Supreme Court opinion to address the Impartial Jury and the Confrontation Clauses of the Sixth Amendment.

George Reynolds was a member of The Church of Jesus Christ of Latter-day Saints (LDS Church), charged with bigamy under the Morrill Anti-Bigamy Act after marrying Amelia Jane Schofield while still married to Mary Ann Tuddenham in Utah Territory. He was secretary to Brigham Young and presented himself as a test of the federal government's attempt to outlaw polygamy. An earlier conviction was overturned on technical grounds.

The LDS Church, believing that the law unconstitutionally deprived its members of their First Amendment right to freely practice their religion, chose to ignore the Morrill Anti-Bigamy Act at the time. On the other hand, in subsequent years, efforts had been underway to strengthen the anti-bigamy laws. Eventually, amid the efforts to indict the LDS leadership for bigamy, the First Presidency agreed to furnish a defendant in a test case to be brought before the United States Supreme Court to determine the constitutionality of the anti-bigamy law. Reynolds, a secretary in the office of the president of the church, agreed to serve as the defendant, then provided the United States Attorney with numerous witnesses who could testify of his being married to two wives, and was indicted for bigamy by a grand jury on October 23, 1874. In 1875, Reynolds was convicted and sentenced to two years hard labor in prison and a fine of five hundred dollars. In 1876 the Utah Territorial Supreme Court upheld the sentence.