Morris v. West Hayden Estates First Addition is a legal case that involves a homeowner who went exceptionally far in expressing his faith on his private property. This dispute ultimately raises significant questions regarding the balance between religious freedom and neighborhood regulations. In 2015 Jeremy Morris, a lawyer and self proclaimed “Christmas Lawyer,” made himself known for displaying an array of Christmas decorations outside of his home in Hayden, Idaho. His exhibit consisted of hundreds of thousands of lights, real animals, and buses full of guests. Upon moving into a new neighborhood, he attempted to repeat the event, at which point the homeowners associations (HOA) objected. Following this was a battle between Morris and the HOA as to whether he was being discriminated against for being a Christian, or if he was simply being held to the same rules and standards that apply to everyone.
Prior to purchasing his home in West Hayden Estates, Morris informed the HOA of his intentions to host a Christmas celebration similar to the year before. The HOA advised him not to, warning that this would likely break the rules involving lighting, noise, and the use of homes in the neighborhood. Morris proceeded anyway and went ahead with the show.
The HOA sent him a formal letter saying the event would likely violate three parts of its community rules, called CC&Rs: 1) using the property for non-residential purposes, 2) creating noise that disturbs neighbors, and 3) using excessive outdoor lighting. In one version of that letter, a board member added that “some of our residents are non-Christians or of another faith,” which Morris took as proof of religious discrimination.
Photo of Jeremy Morris’s 2015 Christmas display, with thousands of visitors. Image via Instagram / @thechristmaslawyer.
After hosting the event anyway in 2015 and again in 2016, with buses, characters, a live scene, and huge crowds, Morris filed a lawsuit claiming the HOA had violated the Fair Housing Act by targeting him because of his Christian beliefs. A jury agreed, awarding him $75,000. But a judge later overturned the decision, saying the issue was not a religious matter, rather, it was a violation of neighborhood rules. As Judge Winmill stated, “the case wasn’t about religious discrimination, but rather the Morris family’s violation of neighborhood rules.”
Morris appealed, and in 2024 the Ninth Circuit Court of Appeals gave a mixed decision. They argued that the HOA had not clearly violated the law in its original letter, but there was still enough evidence to justify a new trial over whether the HOA’s actions were partially motivated by religion.
Now, we must determine the bigger issue in this. Did the HOA’s actions violate the Free Exercise Clause of the First Amendment and the Fair Housing Act by targeting Morris’s religion? Or was the HOA simply enforcing its rules fairly?
A useful comparison is Employment Division v. Smith (1990), where the Supreme Court ruled that neutral, generally applied laws do not violate the Free Exercise Clause, even if they place a burden on someone’s religious practice. In this case, two people were denied unemployment benefits because they used peyote during a religious ceremony. In the end, the Court ruled that the law wasn’t targeting religion, as it applied to everyone. The same idea can be seen in Morris v. West Hayden Estates. The HOA’s rules about lighting, noise, and traffic were applied to all residents, no matter their religion. Just because Morris’s event was religious doesn’t mean he was permitted to break those rules. Similar to Smith, the key question isn’t whether someone was practicing their religion, it’s whether the rules were applied fairly and equally.
Morris asserts that the HOA attempted to cease his Christmas display not because it was size or disruption, but solely because it was Christian. He claims he was unfairly singled out and that other events wouldn’t have received the same treatment. In one Fox News interview, he argued the case is about “the right to celebrate Christmas in accordance with our family’s faith traditions... [and] the right to use our property to express that Christian faith tradition.”
However, the HOA claims it had strong reasons to object. According to court records, the event caused noise, traffic, trash, and even complaints of public urination from visitors. HOA board members were also worried about safety and the disruption to a generally quiet residential neighborhood. As one court document states, “This display/event... will produce in excess of 900 additional vehicles traveling through the neighborhood.” Judge Tashima, who agreed with much of the district court’s ruling, wrote that the HOA was “concerned about the Morrises’ holiday events because of the size and scale of the events, not because of the Morrises’ religion.”
There’s a reasonable argument to be made on Morris’s side. The Ninth Circuit admitted that a jury could find the HOA’s behavior was influenced “at least in part” by the religious nature of the event. The draft of the HOA letter that mentioned “non-Christians” shows that religion may have played some role in their decision. And religious displays, such as Christmas decorations or public nativities, are protected forms of expression, especially when done on private property.
Regardless, there’s a key difference between this instance and others. In Morris’s case, religious expression doesn’t allow someone to break neutral rules that apply to everyone. The HOA would undoubtedly have objected to a secular event of the same size. Nothing in the HOA’s history suggests it treated Morris differently just because of his faith. It is clear that the issue was the crowds, the lights, and the noise, not the nativity scene or the caroling.
All in all, Morris v. West Hayden Estates demonstrates how tricky it can be to draw the line between religious freedom and community rules. Morris sees the HOA’s actions as an attack on his faith. But from the evidence, it seems more like the HOA was simply carrying out its duties, protecting the rights and peace of everyone in the neighborhood. The First Amendment provides all Americans with the right to worship freely. However, it does not give them the right to disrupt an entire community in the process. When religious expression starts to impact hundreds of neighbors, it’s fair to ask whether it’s an issue of faith, or a different matter.
Works Cited:
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/06/17/19-35390.pdf
3 comments:
I agree with your conclusion, he had been informed before buying his house that he wouldn't be able to engage in his usual display. The plight of dealing with one's local homeowners association violations is one which is known far and wide. However, while at times overbearing and unnecessary, these organizations serve a purpose to keep neighborhoods as an orderly and delightful living environment which simply cannot be done with the level of light Morris intends to display. The HOA's goal in restricting Morris' free exercise is not to suppress his faith, but to keep the neighborhood in a state that residents are comfortable with.
This case would have been much easier to decide on if the HOA would not have brought up Morris's religious values. I agree that the HOA should have the authority to regulate what you can display in to limit brightness, noise and traffic. However, they have no right to deny a resident permission to display Christmas decorations because other individuals in the neighborhood have different religious values. Everyone should be free to display their respective religious symbols on their privately owned property and this right is protected by the Free Exercise Clause. That being said, if the bylaws of the HOA do not discriminate on the basis of religion, and simply limit decorations and parties to maintain the safety and comfort of their residents, then the court should uphold their policies. I think this is the case here so I agree with your assessment.
I agree with your argument. The law seems neutral and I do not believe his decorations were denied based on his Christian beliefs. The extravagent display does seem like it would create significant noise and crowds that would disrupt typical neighborhood life. While I know it is hard to question sincerity, I do question his sincerity as the display seems to be a very commercialized version of Christmas spirit. Especially with the self proclaimed "Christmas lawyer" title. His decorations seem to be more a marketing scheme if anything.
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