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Larson v. Valente

United States Supreme Court
456 U.S. 228 (1982)


The Minnesota Charitable Solicitation Act (MCSA) imposed certain registration and reporting requirements upon religious organizations that solicit more than fifty percent of their funds from nonmembers. The MCSA was designed to protect contributing public and charitable beneficiaries from fraud by soliciting organizations. Religious organizations that solicit less than fifty percent of their funds in this way are exempt from the additional registration and reporting requirements. John Larson (defendant), a state official responsible for the enforcement of the MCSA, notified Holy Spirit Association for the Unification of World Christianity (Unification Church) that it was subject to the MCSA’s registration and reporting requirements. Valente and others (plaintiffs), followers of the tenets of the Unification Church, responded by bringing suit in federal district court challenging the requirement as unconstitutional under the Establishment Clause of the First Amendment. The district court granted injunctive relief for Valente’s congregation. The court of appeals affirmed, but vacated the judgment for further consideration on one issue. Larson appealed to the United States Supreme Court.

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