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Bradfield v. Roberts

Supreme Court of the United States · 1899 · Constitutional Law

Constitutional LawEstablishment ClauseCongressional appropriationsCorporate characterEstablishment Clauseappropriationreligious establishmentsectarian corporation

Facts

Congress appropriated $30,000 for two isolating buildings to be constructed, in the Commissioners' discretion, on the grounds of two hospitals and operated as part of those hospitals. Acting under that appropriation, the Commissioners entered into an agreement with Providence Hospital. The bill alleged that Providence Hospital was a private eleemosynary corporation composed of members of a Roman Catholic sisterhood, conducted under the auspices of that church, and that its property was vested in the Sisters of Charity. But the hospital's act of incorporation, enacted by Congress, created it simply as a corporation to open and keep a hospital in Washington for the care of sick and invalid persons, without any religious provision in its charter.

Issue

Whether the agreement implementing Congress's appropriation was invalid under the constitutional prohibition on laws respecting an establishment of religion because Providence Hospital was allegedly a religious or sectarian corporation. More specifically, the question was whether the hospital's alleged Catholic affiliation changed its legal character so that the appropriation amounted to aid to a religious establishment.

Rule

The legal character of a corporation is determined by the statute or charter under which it exists. A corporation incorporated for secular purposes does not become a religious or sectarian body merely because its members belong to a religious order, its management is influenced by a church, or its property is alleged to be associated with religious persons or entities.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress authorizes the District government in Washington, D.C., to contract for new quarantine wards at a private hospital. A taxpayer sues after officials choose Meridian Care Center, alleging that every director is a member of a Baptist fellowship and that local clergy helped recruit the board, but Meridian's federal charter states only that it operates a hospital for any sick or injured persons seeking treatment.

Under the governing rule, which is the strongest basis for rejecting the taxpayer's claim that the contract is unconstitutional because Meridian is a sectarian corporation?

Explanation. The majority opinion measures the corporation's character by the act of incorporation. A charter creating an ordinary hospital for public care remains secular even if all members are adherents of one faith or church figures influence selection of managers. The Court did not hold that hospitals are categorically nonreligious, did not rest on standing, and did not make validity turn on absence of day-to-day control.