Douglas v. City of Jeannette | |
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Argued March 10–11, 1943 Decided May 3, 1943 | |
Full case name | Douglas v. City of Jeannette |
Citations | 319 U.S. 157 ( more ) 63 S. Ct. 877; 87 L. Ed. 1324; 1943 U.S. LEXIS 712 |
Case history | |
Prior | 39 F. Supp. 32 (W.D. Pa. 1941); 130 F.2d 652 (3d Cir. 1942) |
Holding | |
The ordinance as applied is held to be constitutional. | |
Court membership | |
| |
Case opinions | |
Majority | Stone |
Concurrence | Jackson |
Douglas v. City of Jeannette, 319 U.S. 157 (1943), was a case in which the Supreme Court of the United States held it does not restrain criminal prosecutions made in good faith unless there would be some "irreparable injury." [1] This case is one of four cases collectively known as the "Jehovah's Witnesses Cases", because the Supreme Court handed down rulings on these four cases related to the Jehovah's Witnesses on the same day (May 3, 1943). Although the Supreme Court ruled against the Jehovah's Witnesses in this case, it ruled in favor of them in the other three cases and those represent landmark decisions in the area of First Amendment constitutional law.
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.
The First Amendment to the United States Constitution prevents the government from making laws which respect an establishment of religion, prohibit the free exercise of religion, or abridge the freedom of speech, the freedom of the press, the right to peaceably assemble, or the right to petition the government for redress of grievances. It was adopted on December 15, 1791, as one of the ten amendments that constitute the Bill of Rights.
Constitutional law is a body of law which defines the role, powers, and structure of different entities within a state, namely, the executive, the parliament or legislature, and the judiciary; as well as the basic rights of citizens and, in federal countries such as the United States and Canada, the relationship between the central government and state, provincial, or territorial governments.
The plaintiff in this matter was Robert L. Douglas, a Jehovah's Witness who filed suit against the Pittsburgh suburb of Jeannette, Pennsylvania in 1939. Douglas sought to enjoin against the enforcement of ordinances that prohibited him and other colleagues from distributing religious materials door-to-door without a permit.
Pittsburgh is a city in the Commonwealth of Pennsylvania in the United States, and is the county seat of Allegheny County. A population of about 301,048 residents live within the city limits, making it the 66th-largest city in the U.S. The metropolitan population of 2,324,743 is the largest in both the Ohio Valley and Appalachia, the second-largest in Pennsylvania, and the 27th-largest in the U.S.
Jeannette is a city in Westmoreland County, Pennsylvania, United States. Jeannette was founded in 1888. The city got its name from one of the original city fathers, who wished to honor his wife by giving the new town her first name: Jeannette. The city celebrated its 125th anniversary in July 2013. The population was 9,654 according to the 2010 census.
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Chief Justice Stone delivered the opinion of the Court denying equity relief on the grounds that the Court had no jurisdiction in the matter since no irreparable injury occurred, and that it was necessary to presume good faith by the municipality in reassessing the enforcement of statutes that had been declared unconstitutional. Justice Jackson's concurring opinion, appended to the majority opinion, also touched on the First Amendment issues raised in the case.
West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943), is a landmark decision by the United States Supreme Court holding that the Free Speech Clause of the First Amendment protects students from being forced to salute the American flag or say the Pledge of Allegiance in public school. The Court's 6–3 decision, delivered by Justice Robert H. Jackson, is remembered for its forceful defense of free speech and constitutional rights generally as being placed "beyond the reach of majorities and officials".
Minersville School District v. Gobitis, 310 U.S. 586 (1940), was a decision by the Supreme Court of the United States involving the religious rights of public school students under the First Amendment to the United States Constitution. The Court ruled that public schools could compel students—in this case, Jehovah's Witnesses—to salute the American Flag and recite the Pledge of Allegiance despite the students' religious objections to these practices. This decision led to increased persecution of Witnesses in the United States. The Supreme Court overruled this decision three years later, in West Virginia State Board of Education v. Barnette.
Numerous cases involving Jehovah's Witnesses have been heard by Supreme Courts throughout the world. The cases revolve around three main subjects:
Griswold v. Connecticut, 381 U.S. 479 (1965), is a landmark case in the United States about access to contraception. The case involved a Connecticut "Comstock law" that prohibited any person from using "any drug, medicinal article or instrument for the purpose of preventing conception." The court held that the statute was unconstitutional, and that "the clear effect of [the Connecticut law ...] is to deny disadvantaged citizens ... access to medical assistance and up-to-date information in respect to proper methods of birth control." By a vote of 7–2, the Supreme Court invalidated the law on the grounds that it violated the "right to marital privacy", establishing the basis for the right to privacy with respect to intimate practices. This and other cases view the right to privacy as a right to "protect[ion] from governmental intrusion."
The Free Exercise Clause accompanies the Establishment Clause of the First Amendment to the United States Constitution. The Establishment Clause and the Free Exercise Clause together read:
Goldberg v. Kelly, 397 U.S. 254 (1970), is a case in which the Supreme Court of the United States ruled that the Due Process Clause of the Fourteenth Amendment to the United States Constitution requires an evidentiary hearing before a recipient of certain government welfare benefits can be deprived of such benefits.
Wolf v. Colorado, 338 U.S. 25 (1949), was a United States Supreme Court case in which the Court held 6-3 that, while the Fourth Amendment was applicable to the states, the exclusionary rule was not a necessary ingredient of the Fourth Amendment's right against warrantless and unreasonable searches and seizures. In Weeks v. United States, 232 U.S. 383 (1914), the Court held that as a matter of judicial implication the exclusionary rule was enforceable in federal courts but not derived from the explicit requirements of the Fourth Amendment. The Wolf Court decided not to incorporate the exclusionary rule as part of the Fourth Amendment in large part because the states which had rejected the Weeks Doctrine had not left the right to privacy without other means of protection. However, because most of the states' rules proved to be ineffective in deterrence, the Court overruled Wolf in Mapp v. Ohio, 367 U.S. 643 (1961). This landmark case made the exclusionary rule enforceable against the states through the Due Process clause of the Fourteenth Amendment to the same extent that it applied against the federal government.
Marsh v. Chambers, 463 U.S. 783 (1983), was a landmark court case in which the Supreme Court of the United States held that government funding for chaplains was constitutional because of the "unique history" of the United States. Three days before the ratification of the First Amendment in 1791, containing the Establishment clause, the federal legislature authorized hiring a chaplain for opening sessions with prayer.
Olin Richmond Moyle (1887–1966) was legal counsel for the Watch Tower Bible and Tract Society from 1935 to 1939. He helped represent Jehovah's Witnesses in two cases before the United States Supreme Court, which set new precedents on First Amendment freedoms. A dispute with Watch Tower Society president J. F. Rutherford led to Moyle's expulsion from the religion. Moyle later sued the Watch Tower Society for libel over an article in its magazine, The Watchtower. In his later years, he became one of the leaders of the United Israel World Union, a movement that sought to convert people, particularly Christians, to Judaism.
Burford v. Sun Oil Co., 319 U.S. 315 (1943), was a United States Supreme Court case in which the Court created a new doctrine of abstention.
Brigham City v. Stuart, 547 U.S. 398 (2006), is a United States Supreme Court case involving the exigent circumstances exception to the Fourth Amendment's warrant requirement. The Court ruled that police may enter a home without a warrant if they have an objectively reasonable basis for believing that an occupant is or is about to be seriously injured.
Lovell v. City of Griffin, 303 U.S. 444 (1938), is a United States Supreme Court case. This case was remarkable in its discussion of the requirement of persons to seek government sanction to distribute religious material. In this particular case, the Supreme Court ruled it was not constitutional for a city to require such sanction.
Martin v. Struthers, 319 U.S. 141 (1943), is a United States Supreme Court case in which the Court held that a law prohibiting the distribution of handbills from door to door violated the First Amendment rights of a Jehovah's Witness, specifically their freedom of speech. The ruling was 5-4 and deemed trespassing laws a better fit for the town imposing the ordinance.
Murdock v. Pennsylvania, 319 U.S. 105 (1943), was a case in which the Supreme Court of the United States held that an ordinance requiring door-to-door salespersons ("solicitors") to purchase a license was an unconstitutional tax on religious exercise.
Fowler v. Rhode Island, 345 U.S. 67 (1953), was a case in which the Supreme Court of the United States held that a municipal ordinance which was used to penalize a minister of Jehovah's Witnesses for preaching at a peaceful religious meeting in a public park, although other religious groups could conduct religious services there with impunity, violated the First and Fourteenth Amendments.
Poulos v. New Hampshire, 345 U.S. 395 (1953), was a case in which the Supreme Court of the United States held that a New Hampshire city ordinance regarding permission to hold a meeting in a public park did not violate the appellant's rights to Free Exercise of Religion even if he and his group were arbitrarily and unlawfully denied a license to hold a religious meeting in that public park.
Tucker v. Texas, 326 U.S. 517 (1946), was a case in which the Supreme Court of the United States held that a state statute making it an offense to distribute literature in a federal government-owned town was an improper restriction on freedom of the press and religion.
Wooley v. Maynard, 430 U.S. 705 (1977), was a case in which the Supreme Court of the United States held that New Hampshire could not constitutionally require citizens to display the state motto upon their license plates when the state motto was offensive to their moral convictions.
Taylor v. Mississippi, 319 U.S. 583 (1943), was a case involving three Jehovah's Witnesses in which the Supreme Court of the United States held that criminal sanction cannot be imposed for communication that has not been shown to have been done with an evil or sinister purpose, to have advocated or incited subversive action against the nation or state, or to have threatened any clear and present danger to our institutions or our government.
Lloyd Corp. v. Tanner, 407 U.S. 551 (1972), was a United States Supreme Court ruling that the passing out of anti-war leaflets at the Lloyd Center in Portland, Oregon was an infringement on property rights. This went against Marsh v. Alabama (1946) which held that United States protected free speech rights on private property when used for public use.
The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.
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