Reynolds v. United States was the first significant case in which a litigant raised a constitutional claim to be exempt from criminal law based on a fundamental right to engage in the free exercise of religion. Reynolds had been indicted for bigamy in the territory of Utah, a crime as determined by Congress in their plenary power over the territories. Reynolds claimed a religious duty to engage in polygamy, which he held to be a historic and obligatory practice based on his Mormon religious belief. The Court examined whether religious belief could exempt one from a generally applicable criminal law. The Court distinguished that the historic meaning of religious freedom was that the state should not interfere in private belief or conscience. At the same time, the state was left free to reach actions which were in violation of social duties or subversive of good order. The Court determined that polygamy had always been treated as an offense to the common law and prohibited by statutes. Likewise, since marriage is a legal contract and is the basis by which society is formed, it is an institution that is intrinsically related to the political order and must be protected. Religious beliefs cannot exempt one from complying with these social needs. If such religious exemptions existed, there would in effect be no rule of law possible, since one's professed beliefs would in effect be superior to the law of the land. Thus, while Reynolds was burdened in his free exercise rights, the burden was justified by the compelling social need to stop a practice like bigamy that would undermine the political order.
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