Trinity Lutheran Church Of Columbia, Inc.v.Comer
Trinity Lutheran Church operated a preschool and daycare whose playground needed a safer surface. Missouri’s Scrap Tire Program offered reimbursement grants to qualifying nonprofits, but the State categorically excluded organizations owned or controlled by churches. Although Trinity Lutheran ranked among the highest-scoring applicants, the Department denied its application solely because the center was operated by a church. The United States Supreme Court held that the exclusion violated the Free Exercise Clause. The policy did not merely decline to fund religious activity; it denied an otherwise available public benefit because of the applicant’s religious character. The Court distinguished programs involving direct funding of religious exercise and held that the State could not impose that condition on participation in a neutral playground-safety program. It reversed and remanded the judgment against Trinity Lutheran. Separate opinions disagreed about the scope of the holding, and Justice Sotomayor dissented.
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