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Found v. Morris Cnty. Bd. of Chosen Freeholders

Citations: 181 A.3d 992; 232 N.J. 543Docket: A–71 September Term 2016; 079277

Court: Supreme Court of New Jersey; April 18, 2018; New Jersey; State Supreme Court

Narrative Opinion Summary

The case examines whether Morris County's allocation of $4.6 million in taxpayer funds for church repairs under a historic preservation program violates the Religious Aid Clause of the New Jersey Constitution. This clause prohibits the use of taxpayer money for the construction or maintenance of religious buildings. The Court found the program unconstitutional, asserting that the clause clearly restricts taxpayer funding for church repairs. The County and the churches contended that denying such grants infringed upon Free Exercise rights, referencing the Supreme Court's ruling in Trinity Lutheran Church of Columbia, Inc. v. Comer. However, the Court determined that Trinity Lutheran did not obligate the granting of funds to religious institutions in this context. The trial court's decision was reversed, granting summary judgment in favor of the plaintiffs. Notably, the Court concluded that the Religious Aid Clause does not conflict with the Free Exercise Clause of the First Amendment. The analysis emphasized that the historic preservation intent does not override the constitutional prohibition on taxpayer funding for church repairs. Arguments regarding Equal Protection Clause violations were dismissed, as the defendants failed to provide sufficient legal justification.

Legal Issues Addressed

Equal Protection Clause and Religious Aid

Application: Morris County's argument that excluding churches from grants would violate the Equal Protection Clause was not supported by the Court.

Reasoning: Morris County argued that denying grants to churches would breach the Equal Protection Clause of the Fourteenth Amendment, but the defendants failed to provide convincing legal support.

Federal and State Constitutional Conflict

Application: The analysis concluded that the Religious Aid Clause of the New Jersey Constitution does not conflict with the Free Exercise Clause of the First Amendment.

Reasoning: The analysis, particularly in light of the Supreme Court's decision in Trinity Lutheran, concludes that the Religious Aid Clause does not conflict with the Free Exercise Clause of the First Amendment.

Free Exercise Clause and Trinity Lutheran Precedent

Application: The Court distinguished the current case from the Trinity Lutheran decision, concluding that the denial of funds to churches did not infringe upon Free Exercise rights.

Reasoning: However, the Court determined that Trinity Lutheran did not mandate granting funds to religious institutions in this context.

Historic Preservation and Religious Institutions

Application: The Court clarified that historic preservation grants must adhere to the Religious Aid Clause, prohibiting taxpayer funding for church repairs regardless of the preservation intent.

Reasoning: The County's allocation of $4.6 million for repairs to active churches violates the plain language of the clause, which does not consider the governing body's intent or any historic preservation rationale.

Religious Aid Clause under New Jersey Constitution

Application: The Court determined that Morris County's historic preservation program, which allocated taxpayer funds to repair churches, violated the Religious Aid Clause of the New Jersey Constitution.

Reasoning: The Court found that this clause clearly prohibits taxpayer funding for church repairs, thus Morris County's program was unconstitutional.