McGowan V. Maryland - The Court's Decision

The Court's Decision

The Court held that Maryland's laws did not violate the First Amendment. The plaintiffs claimed only economic injury, not that they had been prevented from the free exercise of their religion. Writing for the Court, Chief Justice Warren concluded:

appellants allege only economic injury to themselves; they do not allege any infringement of their own religious freedoms due to Sunday closing. In fact, the record is silent as to what appellants' religious beliefs are. Since the general rule is that "a litigant may only assert his own constitutional rights or immunities," (United States v. Raines, 362 U.S. 17, 22) we hold that appellants have no standing to raise this contention.

The Court also held that the law did not violate the Fourteenth Amendment. Chief Justice Warren again:

...the Court has held that the Fourteenth Amendment permits the States a wide scope of discretion in enacting laws which affect some groups of citizens differently than others. The constitutional safeguard is offended only if the classification rests on grounds wholly irrelevant to the achievement of the State's objective. State legislatures are presumed to have acted within their constitutional power, in practice, their laws result in some inequality.

In reaching their conclusion, the Court also examined the wider question of whether laws proscribing or limiting Sunday trading were constitutional. They held that such laws did not violate the division between church and state, because - no matter the historical roots of such laws - the laws existed as constituted in order to fulfill a secular objective. In other words, even if Sunday trading laws were originally intended to facilitate and encourage church attendance in the colonial United States, the laws as presently constituted were intended to improve the "health, safety, recreation, and general well-being" of citizens. The present purpose of the laws is to provide a uniform day of rest for all; the fact that this day is of particular significance for one or more religions does not bar the State from achieving its secular goals in this manner.