|
322 US 78 (1944)
Bill Long
At issue in this case was whether certain representations or belief statements made by someone under the guise of a Free Exercise claim could be evaluated by a jury along with the defendant's assertion that he held these beliefs in good faith. The Court reversed the Circuit Court (5-4) in holding that only the issue of good faith in holding a belief was properly before the jury. Three dissenters thought that all issues should be avaliable for jury consideration; one dissenter would dismiss the indictment completely and have nothing to do with the case.
Facts
Since this case is so heavily fact-dependent, several things need to be mentioned. Defendant organized the "I Am" movement and raised money for it through mail solicitation. He claimed to be Jesus, George Washington and others, and asserted also he was able to heal "diseases, injuries or ailments" because of his high attainment of spirituality in this life. He represented that hundreds of persons had been cured by him, Edna Ballard and Donald Ballard.
After Guy Ballard's death, Edna and Don were indicted and convicted for using or conspiring to use the mails to defraud. Eighteen charges of false representations were made relating to their ability to heal people. Each of the representations enumerated in the indictment was followed by the charge that the Ballard's "well knew" that the representations were false and untrue and made for the purpose of defrauding people.
At trial the judge decided that the issue of the religious beliefs or representations could not be submitted to the jury because the jury had no competence to judge the truth or falsity of those beliefs. Specifically, this meant that no one was going to be able to speculate on the actuality of "the happening of those incidents" (i.e., the healings). Nevertheless, the judge allowed the jury to consider whether the evidence showed that the Ballard's honestly and in good faith believed what they taught/did More specifically, "if these defendants did not believe those things, they did not believe that Jesus came down and dictated...but used the mail for the purposee of getting money, the jury should find them guilty." The issue seemed to turn, then, on the good faith of their beliefs in their healing ministry and not whether healings took place.
The Court of Appeals reversed and held that restricting the issue to good faith alone was error. Inquiry had to be made also into whether the representations themselves, or some of them, were true.
Supreme Court Decision
The Court held that the only issue that should have gone to the jury was the issue of good faith. "But on whichever basis that court (the Circuit Court) rested its action, we do not agree that the truth or verity of respondents' religious doctrines or beliefs should have been submitted to the jury." Quoting an earlier case from 1871, the Court said, "The law knows no heresy, and is committed to the support of no dogma, the establishment of no sect." The religious views of the Ballard's might seem incredible, the Court opined, "but if those doctrines are subject to trial before a jury charged with finding their truth or falsity, then the same can be done with the religious beliefs of any sect."
Chief Justice Stone, speaking also for Justices Frankfurther and Roberts, argued in dissent that he was not "prepared to say that the constitutional guaranty of freedom of religion affords immunity from criminal prosecution for fraudulent procurement of money by false statements as to one's religious experiences, more than it renders polygamy or libel immune from criminal prosecution." The indictment charged that the representations as to the healings were "falsely and fraudulently made." Certainly those statements were within the competence of the jury to investigate. The dissenters thus argued that none of the Ballard's constitutional rights were violated if they were prosecuted for fraudulent procurement of money by false representations as to their beliefs. The state of a person's mind is a fact as capable of fraudulent misrepresentation as is one's physical condition, they contended.
Copyright © 2004-2007 William R. Long |