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Larson v. Valente (1982)
In Larson, the Supreme Court struck down a Minnesota statute regulating solicitation of donations on both Free Exercise and Establishment Clause grounds. The statute imposed certain registration and reporting requirements only on religious organizations that solicit more than half their funds from non-members. The Court held that the statute violated the Free Exercise Clause because it was not religion neutral but rather purported to regulate religious free exercise in a manner that discriminates against religions that choose to evangelize through public solicitations, and that it violated the Establishment Clause because it exempted financially established religions more than small evangelizing religions.
The Court applied a strict scrutiny analysis to the statute and held that while there was a strong State interest in insuring that solicitations for charitable purposes were genuine and not fraudulent, the statute in question did not further that interest in a meaningful manner, let alone by the least restrictive means.
