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Keywords

statutezoningobjectionappellee

statuteappealzoningdue processappellee

Related Cases

Larkin v. Grendel’s Den, Inc., 459 U.S. 116, 103 S.Ct. 505, 74 L.Ed.2d 297

Facts

The appellee restaurant, located in Harvard Square, Cambridge, applied for a liquor license but was denied due to an objection from the nearby Holy Cross Armenian Catholic Parish, which was only 10 feet away. The Massachusetts statute, § 16C, allowed churches and schools to block liquor licenses within a 500-foot radius by filing a written objection. The restaurant operator claimed that this statute violated the Establishment Clause of the First Amendment, leading to a series of court challenges that culminated in the Supreme Court's ruling.

Appellee operates a restaurant located in the Harvard Square area of Cambridge, Massachusetts. The Holy Cross Armenian Catholic Parish is located adjacent to the restaurant; the back walls of the two buildings are ten feet apart.

Issue

Whether the Massachusetts statute, which allows churches and schools to veto liquor license applications within a 500-foot radius, violates the Establishment Clause of the First Amendment.

The question presented by this appeal is whether a Massachusetts statute, which vests in the governing bodies of churches and schools the power effectively to veto applications for liquor licenses within a five hundred foot radius of the church or school, violates the Establishment Clause of the First Amendment or the Due Process Clause of the Fourteenth Amendment.

Rule

A statute must have a secular legislative purpose, its primary effect must neither advance nor inhibit religion, and it must not foster excessive government entanglement with religion.

This Court has consistently held that a statute must satisfy three criteria to pass muster under the Establishment Clause: First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion …; finally, the statute must not foster 'an excessive government entanglement with religion.'

Analysis

The court determined that § 16C was not merely a zoning law but delegated significant governmental power to private, religious entities, which is contrary to the principles of the Establishment Clause. The statute's effect was to give churches a veto power over liquor licenses, which could be used to promote religious interests, thus breaching the separation of church and state. The court found that the statute's objectives could be achieved through other means that would not involve such entanglement.

However, § 16C is not simply a legislative exercise of zoning power. As the Massachusetts Supreme Judicial Court concluded, § 16C delegates to private, nongovernmental entities power to veto certain liquor license applications, Arno v. Alcoholic Beverages Control Commission, supra, 377 Mass., at 89, 384 N.E.2d 1223.

Conclusion

The Supreme Court affirmed the lower court's ruling that § 16C is unconstitutional under the Establishment Clause, as it improperly enmeshed religious institutions in governmental decision-making.

The judgment of the Court of Appeals is affirmed.

Who won?

The restaurant prevailed in the case because the court found that the Massachusetts statute violated the Establishment Clause by granting churches the power to veto liquor licenses, thus infringing on the separation of church and state.

The District Court held that § 16C is facially unconstitutional under the Establishment Clause, and the Court of Appeals affirmed.

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