Jones v. City of Opelika (1942)

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Jones v. City of Opelika
Seal of the United States Supreme Court.svg
Argued February 5, April 30, 1942
Decided June 8, 1942
Full case nameJones v. City of Opelika, Bowden et al. v. City of Fort Smith, Ark. Jobin v. State of Arizona
Citations316 U.S. 584 ( more )
62 S. Ct. 1231; 86 L. Ed. 1691; 1942 U.S. LEXIS 447
Court membership
Chief Justice
Harlan F. Stone
Associate Justices
Owen Roberts  · Hugo Black
Stanley F. Reed  · Felix Frankfurter
William O. Douglas  · Frank Murphy
James F. Byrnes  · Robert H. Jackson
Case opinions
MajorityReed, joined by Roberts, Frankfurter, Byrnes, Jackson
DissentStone, joined by Murphy, Black, Douglas
DissentMurphy, joined by Stone, Black, Douglas
Laws applied
U.S. Const. amend. I

Jones v. City of Opelika, 316 U.S. 584 (1942), was a case in which the Supreme Court of the United States held that a statute prohibiting the sale of books without a license was constitutional because it covered not a religious ritual but only individuals who engaged in a commercial activity. [1]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States of America, established pursuant to Article III of the U.S. Constitution in 1789. It has ultimate appellate jurisdiction over all federal and state court cases that involve a point of federal law, and original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. The Court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution. Presidential directives can be struck down by the Court for violating either the Constitution or statutory law. 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 non-justiciable political questions.

Contents

Background

The city of Opelika, Alabama, charged Jones with violating a statute by selling books without a license. All licenses were subject to immediate revocation by the city without requiring advance notice. Jones, a Jehovah's Witness, alleged that his rights to both freedom of the press and freedom of religion were violated.

Opelika, Alabama City in Alabama, United States

Opelika is a city in and the county seat of Lee County in the east central part of the U.S. state of Alabama. It is a principal city of the Auburn-Opelika Metropolitan Area. As of the 2010 census, the population of Opelika was 26,401, and in 2018 the estimated population was 30,555. The Auburn-Opelika, AL MSA with a population of 150,933, along with the Columbus, Georgia metropolitan area, comprises the Greater Columbus combined statistical area, a region home to 501,649 residents.

Freedom of the press or freedom of the media is the principle that communication and expression through various media, including printed and electronic media, especially published materials, should be considered a right to be exercised freely. Such freedom implies the absence of interference from an overreaching state; its preservation may be sought through constitutional or other legal protections.

Freedom of religion freedom practicing of religion

Freedom of religion is a principle that supports the freedom of an individual or community, in public or private, to manifest religion or belief in teaching, practice, worship, and observance. It also includes the freedom to change one's religion or beliefs.

Decision

Majority opinion

Writing for the majority, Justice Reed wrote that individual rights must be balanced against competing rights of the state. He asserted that the fact that a person is engaged in disseminating religious materials does not place his action above regulation by the state. When people choose to use the vending of their religious books and tracts as a source of funds, the financial aspects of their transactions need not be wholly disregarded. To subject any religious or didactic group to a reasonable fee for their money-making activities does not require a finding that the licensed acts are purely commercial. It is enough that money is earned by the sale of articles.

Stanley Forman Reed American judge

Stanley Forman Reed was a noted American attorney who served as United States Solicitor General from 1935 to 1938 and as an Associate Justice of the U.S. Supreme Court from 1938 to 1957.

When traditional means of distribution are used by religious groups, they can be held to the same standards as non-religious groups. The court held that Jones had no standing to challenge that part of the statute because he did not have a license that was revoked arbitrarily by the state.

Dissenting opinions

The two dissenting opinions, by Chief Justice Harlan Stone and Justice Frank Murphy, examined both the unlimited discretion of the authorities in Opelika to withdraw a license as well as the amount of fees charged in order to get a license. The majority had considered that the amount of fees ($25.00 annually in some cases or $2.50 per day in others) was irrelevant because the issue had not been argued earlier, but the dissenters thought the amount to be relevant.

Frank Murphy Associate Justice of the Supreme Court of the United States

William Francis Murphy was a Democratic politician and jurist from Michigan. He was named to the Supreme Court of the United States in 1940 after a political career that included stints as Governor of Michigan and Mayor of Detroit. He also served as the last Governor General of the Philippine Islands and the first High Commissioner of the Philippines.

Effects

The decision forced religious groups to meet the same requirements as nonreligious groups engaged in a similar activity. The fact that they were selling religious materials did not exempt them from statutes regulating commercial acts.

Subsequent history

In the one paragraph per curiam decision Jones v. City of Opelika (II), 319 U.S. 103 (1943), [2] the Court vacated Jones v. City of Opelika (1942) on the basis of the principles articulated in Murdock v. Commonwealth of Pennsylvania ; a state may not prohibit distribution of religious handbills where handbills seek to raise funds in a lawful fashion.

See also

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References

  1. Jones v. City of Opelika , 316 U.S. 584 (1942). PD-icon.svgThis article incorporates text from this source, which is in the public domain.
  2. Jones v. City of Opelika , 319 U.S. 103 (1943). PD-icon.svgThis article incorporates text from this source, which is in the public domain.