Huntsman v. Corporation of the President of The Church of Jesus Christ of Latter-day Saints
James Huntsman, a former member of the Church of Jesus Christ of Latter-day Saints, claimed that the Church fraudulently misrepresented how it used tithing funds. Tithing funds are donations that members are religiously or morally obligated to give, typically amounting to ten percent of their income. Huntsman claimed that he had donated millions of dollars over years under the impression that those funds would go only to charitable or religious purposes. However, he alleged that the Church used portions of these funds for profit ventures, including the City Creek Center, a high-end shopping mall in Salt Lake City, and for a bailout of Beneficial Life Insurance Company, which was affiliated with the Church. He argued that the Church repeatedly made statements assuring members that their tithes were used only for religious purposes, and that these statements were knowingly false. Huntsman argued that these actions were fraudulent and sought to recover his donations from the Church for their deception. The Church argued that decisions regarding the management and use of donated funds fall under the Church’s constitutionally protected religious autonomy. The Church found that any attempt by a court to evaluate its financial decisions would violate the Establishment Clause of the First Amendment by interfering with their religious practices. In response, Huntsman filed a lawsuit against the Church in the federal courts of California.
Does allowing a court to evaluate a fraud claim against a religious organization based on its use of donated funds violate the Establishment Clause of the First Amendment by allowing judgement of internal church affairs and use of their funds?
This case dips into both the Establishment Clause and the Free Exercise Clause of the First Amendment, however, the Establishment Clause is the larger issue. The Establishment Clause states that the government cannot establish an official religion or get entangled in religious affairs, in order to create separation of Church and State. A previous case that can be applied to this is Lemon v. Kurtzman which establishes the Lemon Test in helping evaluate Establishment Clause violations. This test has three prongs, there needs to be 1) a secular purpose 2) a primary effect that neither promotes or inhibits religion and 3) does not have excessive government entanglement with religion. In this case, there is a secular purpose to protect individuals from financial harm and deceit from the Church. If the Church is lying about the use of the funds they are collecting, this harms individuals who are donating based on religious obligation. This donation causes individuals who believe they are donating for a good cause to lose about ten percent of their income based on fraudulent statements. Furthermore, the primary purpose of fraud legislation is neutral in effect. This legislation holds every entity accountable for fraudulent actions and claims, regardless of its religious affiliation. The primary effect of this lawsuit is also not directed at their spiritual practices, but at how the Church decides to use the religiously donated funds. The laws are not targeting the Church’s practices, but rather how they are deceiving individuals based on their stated use of the funds. Finally, the last prong of the Lemon Test is whether there would be excessive government entanglement. Determining if the donated funds were used deceitfully would have required the Court to analyze the internal affairs of the Church and its priorities for its tithing funds. Since these funds are religiously obligated, determining how the Church uses them and how it allocates them would require the Court to evaluate every action of the Church. I find this to be the Court overstepping into entanglement with determining whether the use of the funds is a valid religious use or not.
In my opinion, I believe that determining whether the Church has used funds fraudulently would violate the Establishment Clause of the First Amendment. In terms of the Lemon Test, it only passes the secular purpose prong but fails the primary effect and excessive entanglement prongs. Deciding on the validity of donated funds used by the Church, I feel, oversteps too much into the Church’s religious practices and validity. Especially since these funds are donated due to a religious obligation as a member of the Church. In conclusion, I feel this case violates the Establishment Clause.
4 comments:
I would argue the opposite of Natalies opinion in this case. I do not think investigating the allocation of the donations that a private individual provides the church is unconstitutional especially if the church is using the funds in a manner that does not align with the assumed purpose that the private donor had of the funds. I think that in cases like this, what is more important than the debate over the interpretation of the Establishment Clause is the unclear communication of how the church is allocating this donors funds. If the donor is giving funds to the church with the intent of benefitting society through religion but the church is using those funds to make money then the donor should be able to investigate the church.
I agree with Ian. The Establishment Clause is in place to prevent the government's endorsement of religion, not prevent the government from interfering with fraudulent financial practices. By reviewing the church's financial statements and seeing where the money is actually going, the government can ensure that one of its citizens is having his religious convictions properly carried out. That being said, the plaintiff has the freedom to choose another Mormon church to be a part of. But the fact that the fraud already occurred makes me believe he has the right to sue and be compensated in return.
Huntsman argues that this is about fraud, not religion. He was clearly misled about what his money was going toward, and religious groups shouldn’t be exempt from accountability when they deceive donors. The lawsuit doesn’t challenge religious doctrine, rather it challenges the truthfulness of public financial statements. Therefore, I side with Huntsman in this case.
I think that fraud is not a protected religious practice. If a church knowingly misrepresents how it will use tithes, that’s not just a religious issue, it’s a legal one. The court can assess whether statements were intentionally deceptive without questioning doctrine or belief those are completely unrelated. Religious institutions shouldn't be above the law when it comes to financial accountability, especially when it affects people’s livelihoods under the guise of faith.
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