Jimmy Swaggart Ministries v. Board of Equalization of California

Summary

The Supreme Court held that California's generally applicable sales and use tax could be imposed on a religious organization's distribution of religious materials without violating the Free Exercise or Establishment Clauses of the First Amendment. The Court distinguished flat license taxes that operate as prior restraints from neutral taxes imposed on retail sales. It also concluded that the tax did not create excessive administrative entanglement between the State and the religious organization.

Holdings

1. The Free Exercise Clause does not require California to exempt a religious organization from a generally applicable, neutral sales and use tax on retail sales of tangible personal property.
2. California's imposition and administration of the generally applicable sales and use tax did not create excessive entanglement between church and state.
3. The Court declined to reach the merits of the Ministries' Commerce Clause and Due Process Clause nexus challenge because California law procedurally barred the claim when it was not stated in the administrative refund claim.

Questions Presented

1. Whether the Free Exercise Clause requires California to exempt a religious organization from a generally applicable sales and use tax imposed on its sales of religious materials.
2. Whether application of California's generally applicable sales and use tax to the Ministries' sales of religious materials creates excessive government entanglement with religion in violation of the Establishment Clause.
3. Whether the Ministries' Commerce Clause and Due Process Clause challenge to California's use-tax nexus was properly before the Supreme Court despite the failure to raise that issue in the administrative refund claim.

Disposition

affirmed