Trinity Lutheran Church v. Pauley, No. 14-1382 (8th Cir. 2015)
Annotate this CaseTrinity operates on its church premises a licensed preschool and daycare, the Learning Center, which has an open admissions policy. It teaches a Christian world view and incorporates daily religious instruction in its programs. The Missouri Department of Natural Resources (DNR) offers Playground Scrap Tire Surface Material Grants, a solid waste management program, providing funds for the purchase of recycled tires to resurface playgrounds. In 2012, Trinity applied for a grant, disclosing that the Learning Center was part of Trinity. DNR denied the application, stating that the Missouri Constitution specifically provides that “no money shall ever be taken from the public treasury, directly or indirectly, in aid of any church, section or denomination of religion.” Trinity’s application ranked fifth out of 44 applications and 14 projects were funded. Trinity sued, citing the Equal Protection Clause; its right to free exercise of religion; the Establishment Clause, and its right of free speech. The district court dismissed and declined to reconsider in light of evidence that the DNR had previously given Scrap Tire grants to 15 religious organizations, including churches. The Eighth Circuit affirmed, citing precedent that concluding that Missouri Constitution Article I, section 7 does not conflict with the First Amendment or the Equal Protection Clause of the U.S. Constitution.
Court Description: Loken, Author, with Melloy and Gruender, Circuit Judges] Civil case - Constitutional law. In an action alleging defendant's denial of plaintiff's request to participate in a scrap rubber program violated the church's First and Fourteenth Amendment rights, the district court did not err in dismissing the church's federal constitutional claims for failure to state a claim as Article I, Section 7 of the Missouri Constitution does not conflict with either the First Amendment or the Equal Protection Clause of the Fourteenth Amendment; the district court did not err in dismissing plaintiff's claim that the defendant's actions violated the second clause of Article I, Section 7 as the church's own pleadings demonstrated that approval of their application would provide the church with impermissible aid within the meaning of Missouri law; denial of post-judgment motion to amend the complaint affirmed. Judge Gruender, concurring in part and dissenting in part.
Subsequent History
- Trinity Lutheran Church of Columbia, Inc. v. Comer, No. 15-577 (U.S. Jun. 26, 2017)
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