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Keywords

statuteinjunctionnonprofitappellant
statuteinjunctionappealmotionsummary judgmentwillappellantappelleemotion for summary judgment

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Walz v. Tax Commission of City of New York, 397 U.S. 664, 90 S.Ct. 1409, 25 L.Ed.2d 697

Facts

The appellant, a real estate owner in Richmond County, New York, sought an injunction against the New York City Tax Commission to stop the granting of property tax exemptions to religious organizations for properties used solely for religious worship. The New York Constitution allows for such exemptions under Art. 16, s 1, which states that exemptions may be granted by general laws for properties used exclusively for religious, educational, or charitable purposes. The appellant argued that the tax exemption indirectly required him to contribute to religious bodies, violating the First Amendment's prohibition against the establishment of religion.

Appellant, owner of real estate in Richmond County, New York, sought an injunction in the New York courts to prevent the New York City Tax Commission from granting property tax exemptions to religious organizations for religious properties used solely for religious worship.

Issue

Whether the New York statute exempting property owned by religious organizations from real property tax is unconstitutional under the Establishment Clause of the First Amendment.

Whether the New York statute exempting from real property tax realty owned by association organized exclusively for religious purposes and used exclusively for carrying out such purposes is not unconstitutional as an attempt to establish, sponsor or support religion or as an interference with free exercise of religion.

Rule

The court applied the principle that government actions must not establish, sponsor, or support religion, nor interfere with the free exercise of religion, and that tax exemptions for religious organizations do not constitute such actions.

The general principle deducible from the First Amendment and all that has been said by the Court is this: that we will not tolerate either governmentally established religion or governmental interference with religion.

Analysis

The court analyzed the legislative purpose behind the tax exemption, concluding that it was not aimed at establishing or supporting religion but rather at preventing excessive government entanglement with religious institutions. The court noted that the exemption applied broadly to various nonprofit organizations, not just religious ones, and that it served a beneficial role in the community by fostering moral and mental improvement without favoring any particular religion.

The legislative purpose of a property tax exemption is neither the advancement nor the inhibition of religion; it is neither sponsorship nor hostility.

Conclusion

The court affirmed the lower court's ruling, concluding that the New York statute providing tax exemptions for religious organizations was constitutional and did not violate the Establishment Clause.

We cannot read New York's statute as attempting to establish religion; it is simply sparing the exercise of religion from the burden of property taxation levied on private profit institutions.

Who won?

The New York City Tax Commission prevailed in the case because the court found that the tax exemption did not constitute an establishment of religion and served a legitimate governmental purpose.

Appellee's motion for summary judgment was granted and the Appellate Division of the New York Supreme Court, and the New York Court of Appeals affirmed.

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