Trinity Lutheran Church of Columbia, Inc. v. Comer

Trinity Lutheran Church of Columbia, Inc. v. Comer was a United States Supreme Court case decided on June 26, 2017. A Missouri church operated a licensed preschool and applied for a state grant that provided recycled tire material to resurface playgrounds. The Missouri Department of Natural Resources denied the application solely because the church was a religious entity, citing a state constitutional provision prohibiting direct aid to churches. The church sued, arguing that the denial violated the Free Exercise Clause of the First Amendment. The Supreme Court ruled 7-2 in favor of the church, holding that excluding a religious institution from an otherwise generally available public benefit solely because of its religious character is odious to the Constitution and strictly scrutinized under the Free Exercise Clause. The decision required Missouri to allow the church to compete for the grant on equal terms.

The United States Supreme Court reversed the lower court in a 7-2 decision. The majority, led by Chief Justice Roberts, held that Missouri's policy of excluding Trinity Lutheran from the playground resurfacing program solely because it was a church violated the Free Exercise Clause. The case was remanded for further proceedings consistent with the opinion, effectively requiring the state to allow religious entities to participate in the neutral, secular aid program.

Whether denying a religious institution an otherwise generally available public benefit solely because of its religious identity violates the Free Exercise Clause of the First Amendment.

The ruling significantly weakened the force of so-called Blaine Amendments found in many state constitutions, which have historically been used to bar government funds from flowing to religious organizations. It established that while a state need not fund religious activities, it cannot disqualify an organization from a secular aid program simply because of its religious character. The decision was seen as a major victory for religious liberty advocates and influenced subsequent debates over school vouchers, church-state separation, and the eligibility of religious institutions for public grants.