## Facts

- New York’s Constitution and statutes authorized property-tax exemptions for real property owned by nonprofit organizations and used exclusively for religious, educational, charitable, and similar purposes.
- The statutory scheme exempted houses of religious worship as part of a broader class of nonprofit, quasi-public institutions rather than singling out religion alone.
- Frederick Walz, a New York property owner and taxpayer, sued to enjoin the city Tax Commission from granting exemptions to religious organizations for property used solely for religious worship.
- Walz argued the exemptions compelled taxpayers to support religion and violated the Establishment Clause as incorporated against the states through the Fourteenth Amendment.
- New York courts rejected the challenge and upheld the exemption scheme.

## Issues

1. Whether a state property-tax exemption for religious organizations, granted as part of a broad, neutral exemption scheme for nonprofit uses, violates the Establishment Clause of the First Amendment (as applied through the Fourteenth Amendment).

## Decision

- The Supreme Court affirmed the state court judgment and upheld the exemptions.
- The Court held that granting property-tax exemptions to religious organizations within a broad, neutral nonprofit exemption scheme does not violate the Establishment Clause.
- The Court concluded the exemption created only a minimal and remote relationship between government and religion and lacked a genuine connection to establishing religion.
- The Court reasoned that taxing churches would require valuation and financial scrutiny that would increase church–state involvement more than an exemption would.

## Legal Principles

- The Establishment Clause forbids government sponsorship, financial support, or active involvement in religious activity; not every neutral accommodation of religion constitutes unconstitutional support.
- A property-tax exemption that applies to religion as part of a broad class of nonprofit, quasi-public entities is more likely to be treated as neutral and secular in purpose and effect.
- Longstanding historical practice of exempting religious property may support constitutionality where the practice has not produced an established religion.
- Avoidance of “excessive entanglement” between government and religious institutions is a constitutional objective; exemptions may reduce entanglement compared to taxation that necessitates ongoing oversight.

## Conclusion

New York’s property-tax exemption for religious property, embedded in a general exemption scheme for nonprofit and quasi-public uses, did not amount to an establishment of religion because it was neutral in scope, reflected long historical practice, and reduced rather than increased church–state involvement.


Walz v. Tax Comm’n of City of New York, 397 U.S. 664 (1970)