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United States v. Ballard

Supreme Court of the United States · 1944 · Constitutional Law

Constitutional LawFirst AmendmentFree Exercise of ReligionMail FraudFirst Amendmentfree exercisereligious beliefreligious doctrine

Facts

The indictment charged respondents with a mail-fraud scheme based on numerous allegedly false representations connected with the I Am movement, including claims that Guy Ballard and other respondents were divine messengers and had supernatural healing powers. During trial, the district court, with acquiescence of both sides, removed from the jury any inquiry into whether respondents' religious doctrines or beliefs were true or false. Instead, the jury was told the central issue was whether respondents honestly and in good faith believed the representations set out in the indictment. Respondents were convicted, and the court of appeals reversed on the view that falsity of at least some representations had to be submitted to the jury.

Issue

Does the First Amendment permit a jury in a fraud prosecution to decide the truth or falsity of a defendant's religious doctrines or beliefs? Also, were respondents barred from arguing otherwise because they acquiesced in the district court's withdrawal of that issue from the jury?

Rule

The First Amendment precludes courts and juries from trying the truth or verity of religious doctrines or beliefs. Freedom of religious belief is absolute, and persons may not be put to proof of their religious views before a jury charged with determining whether those teachings are true or false.

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

In Phoenix, a federal prosecutor charges Maya Nolen, founder of the Radiant Path Fellowship, with mail fraud after she mailed donation letters stating that angels had revealed to her a method for cleansing souls and curing despair. At trial, the government asks the judge to let the jury decide whether angels actually communicated with Maya and whether her spiritual method really works.

Should the judge allow the jury to determine the truth of those religious claims?

Explanation. The majority held that the First Amendment places the truth or verity of religious doctrines and beliefs beyond the competence of courts and juries. Even in a fraud case, a tribunal may not conduct a heresy trial by asking whether revelations, miracles, or spiritual powers are actually true. The protection is not limited to conventional religions.