Lower Court Holding in Trinity Lutheran v. Pauley
Decision of the Eighth Circuit U.S. Court of Appeals
Trinity Church’s complaint alleged that, by denying its grant application solely because it is a church, the Missouri Department of Natural Resources (DNR) violated the Free Exercise Clause of the First Amendment to the U.S. Constitution because it “targeted religion for disparate treatment” without a compelling government interest; violated the Establishment Clause of the First Amendment because the denial “was hostile to religion” and required DNR “to determine what is religious enough” to justify denial; and violated the Equal Protection Clause of the Fourteenth Amendment by discriminating against religious learning centers and daycare organizations without a compelling government interest. Although…