## Facts

- Utah law authorized “religious officials” and other specified persons to solemnize marriages.
- Universal Life Church (ULC) ordained ministers broadly, including via mail and the Internet, and authorized them to perform religious rites such as weddings.
- J.P. Pace was ordained by ULC by mail in 1993 and performed marriages in Utah.
- Utah enacted Utah Code Ann. § 30-1-6.1, providing that any “certification, licensure, ordination, or other endorsement” obtained “through application over the Internet or by mail” conferring “religious authority” was not valid to qualify a person as a religious official for purposes of solemnizing marriages.
- The statute did not disqualify ordinations obtained by other methods (e.g., in person, telephone, or fax).
- Utah law imposed potential criminal liability for purporting to solemnize a marriage without legal authority.
- ULC and Pace sued under 42 U.S.C. § 1983, seeking declaratory and injunctive relief; both sides moved for summary judgment.

## Issues

1. Whether Utah Code Ann. § 30-1-6.1 violated the Free Exercise Clause by disqualifying religious authority based on the method of ordination (mail/Internet).
2. Whether the statute violated the Establishment Clause by favoring certain forms of religious ordination and requiring government judgments about religious authority.
3. Whether the statute violated the Equal Protection Clause by irrationally distinguishing between religious officials based solely on the medium used to obtain ordination.

## Decision

- Plaintiffs’ motion for summary judgment was granted; defendants’ motion was denied.
- The court held Utah Code Ann. § 30-1-6.1 unconstitutional and unenforceable.
- The court issued declaratory relief and enjoined enforcement of the statute.

## Legal Principles

- A law that explicitly targets religious practice or is not neutral and generally applicable triggers heightened scrutiny under the Free Exercise Clause and must be justified by sufficiently weighty interests pursued through appropriately tailored means.
- Government action that favors some forms of religious authority over others, or that forces the state to assess the validity of religious ordinations, creates impermissible Establishment Clause concerns, including excessive entanglement.
- Equal Protection forbids classifications lacking a rational relationship to legitimate governmental interests; underinclusive and overinclusive distinctions can show that a classification is irrational.
- A state may regulate the civil incidents of marriage through neutral, secular requirements, but it may not condition marriage solemnization authority on state-approved methods of religious ordination.

## Conclusion

The court invalidated Utah’s exclusion of mail- and Internet-based ordinations from marriage solemnization authority, concluding that the statute singled out religious authority based on ordination method, improperly favored certain religious forms, and lacked a rational basis for its discriminatory classification.


Universal Life Church v. Utah, 189 F. Supp. 2d 1302 (D. Utah 2002)