On June 26, 2017, the United States Supreme Court announced that a Missouri policy violated the rights of a preschool and daycare center because the policy denied the center public benefits due to its religious affiliation. Trinity Lutheran Church Child Learning Center, which operates a daycare and preschool on church property, applied for a grant from the Missouri Department of Natural Resources, seeking reimbursement for replacing its playground surface with recycled rubber. The center met all the requirements to receive the grant, and would have received the grant, were it not for its religious affiliation. The MDNR had a policy of automatically denying grants to applicants that were owned or controlled by a religious entity, including a church.
The center sued the MDNR, alleging that the automatic denial was a violation of the First Amendment, which prohibits the government from establishing a religion and protects the rights of individuals to freely exercise whichever religion they choose. The district court dismissed the case and the appellate court agreed. The center appealed to the U.S. Supreme Court, which determined that the MDNR discriminated against the center in violation of the Free Exercise Clause.
The Supreme Court found that the MDNR’s policy expressly discriminated against eligible recipients solely because of their association with a religion. Therefore, the Court applied a strict scrutiny standard of judicial review, which is the most onerous burden for a governmental body, to the MDNR’s decision to exclude religiously affiliated entities. The Court stated that the MDNR requires religious applicants to either renounce their religious character or forfeit their ability to receive a public benefit. The Court pointed out that the policy would result in nothing more than scraped knees, and limited its decision to the funding of playground resurfacing.
Relying on its precedent, the Court determined that the MDNR could not meet the strict scrutiny standard and stated, “But the exclusion of Trinity Lutheran from a public benefit for which it is otherwise qualified, solely because it is a church, is odious to our Constitution all the same, and cannot stand.”