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Strayhorn v. Ethical Soc. of Austin, 110 S.W.3d 458

Facts

The Ethical Society of Austin, originally known as the 'Ethical Culture Fellowship of Austin,' organized in 1995 to practice a belief system called 'Ethical Culture.' In 1996, they applied for tax-exempt status, which was initially denied by the Comptroller's office based on the requirement of belief in a 'Supreme Being.' After further review, the Tax Policy Group initially granted the exemption, but this was later revoked following media coverage. The Society challenged the Comptroller's decision, leading to the court's review of the constitutionality of the 'Supreme Being' test.

The Ethical Society challenged the Comptroller's decision. Sitting without a jury, the trial court determined that, by using its formulation of the 'Supreme Being' test as the primary basis for determining which organizations are 'religious' for tax-exemption purposes, the Comptroller had violated the First Amendment.

Issue

Whether the Texas Comptroller's requirement for belief in a 'Supreme Being' to qualify as a religious organization for tax exemption purposes violates the First Amendment.

We must now decide whether a state government may, consistent with the First Amendment to the United States Constitution, require a group to demonstrate its belief in a 'Supreme Being' in order to be considered a religion for statutory purposes.

Rule

The court applied the Malnak test, which assesses whether a belief system addresses fundamental questions about existence and is comprehensive in nature, to determine if the Ethical Society qualifies as a religion under the First Amendment.

The Malnak test gives a court the basis on which to determine whether an unfamiliar religion is entitled to First Amendment protection by comparing it to familiar religions.

Analysis

The court found that the Comptroller's 'Supreme Being' test was unconstitutionally underinclusive, failing to account for the diverse range of belief systems that exist in society. By applying the Malnak test, the court determined that the Ethical Society's beliefs addressed ultimate questions and were comprehensive, thus qualifying as a religion for First Amendment protections.

Because the Comptroller's test fails to include the whole range of belief systems that may, in our diverse and pluralistic society, merit the First Amendment's protection, we will affirm the trial court's judgment.

Conclusion

The court affirmed the trial court's decision, ruling that the Ethical Society was entitled to tax-exempt status as a religious organization under the Malnak test.

Therefore, we hold that the Comptroller's reliance on a Supreme Being litmus test to determine whether an organization qualifies as a religion for purposes of the tax code is constitutionally infirm.

Who won?

The Ethical Society of Austin prevailed in the case because the court found that the Comptroller's 'Supreme Being' test was unconstitutional and that the Society met the criteria for religious status under the First Amendment.

The Ethical Society, joined by various amici curiae, responds that the Comptroller's test too narrowly defines the scope of religion.

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