Mueller v. Allen Case Brief

Why is the case important?

This case involves an appeal alleging that a Minnesota statute, which allows parents to deduct school related expenses pertaining to both private and public schools, violates the Establishment Clause of the First Amendment of the United States Constitution (Constitution).

Facts of the case

A Minnesota law allowed taxpayers to deduct from their state income tax expenses incurred in providing tuition, textbooks, and transportation for their children’s elementary or secondary school education. Parents who sent their children to parochial school also qualified for the deductions.

Question

Whether a Minnesota income tax deduction available for expenses incurred in sending children to public as well as non-public schools violates the Establishment Clause of the Constitution.

Answer

Affirmed. The statute does not violate the Establishment Clause of the First Amendment of the Constitution.

Conclusion

“The United States Supreme Court held that Minn. Stat. § 290.09, subd. 22 (1982) did not violate the Establishment Clause because it satisfied all elements of f the “”three-part”” test laid down in Lemon v. Kurtzman , 403 U.S. 602, that must be met for such a statute to be upheld under the Clause. The “three-part test” were as follows: 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. In the case at bar, the Court held that the tax deduction in question has the secular purpose of ensuring that the State’s citizenry was well-educated as well as of assuring the continued financial health of private schools, both sectarian and nonsectarian. Moreover, the deduction did not have the primary effect of advancing the sectarian aims of non-public schools. In this regard the Court held that it was important that the statute was a genuine tax deduction, that it was neutral on its face, and that it provided only indirect support to parochial schools through the individual choices of parents to send their children to those schools. Finally, the Court held that the statute did not foster an excessive government entanglement with religion.”
    • Case Brief: 1983
    • Petitioner: Mueller
    • Respondent: Allen
    • Decided by: Burger Court

    Citation: 463 US 388 (1983)
    Argued: Apr 18, 1983
    Decided: Jun 29, 1983