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Mueller v. Allen

    Brief Fact Summary. Minnesota’s law allowing taxpayers, in computing their state income tax, to deduct certain expenses incurred in providing for the education of their children was held by the Supreme Court of the United States (Supreme Court) to not violate the Establishment Clause of the United States Constitution (Constitution).

    Synopsis of Rule of Law. Where as here, aid to parochial schools is available only as a result of decisions of individual parents no “imprimatur of state approval” can be deemed to have been conferred on any particular religion or on religion generally.

    Facts. Minnesota’s income tax law permits taxpayers to deduct from gross income actual expenses incurred for “tuition, textbooks and transportation” for the education of their dependents attending elementary and secondary schools. The deduction is limited to $500.00 per child in primary school and $700.00 per child in secondary school. The Court of Appeals held that the Establishment Clause of the Constitution was not offended by this arrangement.

    Issue. Whether Minnesota’s law allowing taxpayers, in computing their state income tax, to deduct certain expenses incurred in providing for the education of their children violates the Establishment Clause of the Constitution?

    Held. No. Judgment of the Court of Appeals affirmed. Under our prior decisions, governmental assistance programs have consistently survived the inquiry of whether they had secular purposes. A state’s decision to defray the cost of educational expenses incurred by parents, regardless of the type of schools their children attend, evidences a purpose that is both secular and understandable. Minnesota, like other states, could conclude that there is a strong public interest in assuring the continued financial health of private schools, both sectarian and non-sectarian. The Minnesota statute does not have a “primary effect of advancing the sectarian aims of the nonpublic schools.” First, an essential feature of the state’s arrangement is the fact that the provision is only one of many deductions available under the Minnesota tax laws. Second, by channeling whatever assistance it may provide to parochial schools through individual parents, Minnesota has reduced the Establishment Clause obj
    ections to which its actions its action is subject. Thus, the Minnesota tax deduction for educational expenses satisfies the primary effect inquiry prong. Finally, there is no difficulty in concluding that the Minnesota statute does not “excessively entangle” the state in religion. Therefore, Minnesota’s law allowing taxpayers, in computing their state income tax, to deduct certain expenses incurred in providing for the education of their children does not violate the Establishment Clause of the Constitution.

    Dissent. The Establishment Clause of the Constitution forbids a state from subsidizing religious education, whether is does so directly or indirectly. The Minnesota statute violates the Establishment Clause of the Constitution because it has a direct and immediate effect of advancing religion.

    Discussion. The majority has typically found fewer Establishment Clause barriers to financial aid to colleges than to elementary and secondary schools.


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