Samuel Davis was convicted in an Idaho territorial district court after being charged with falsely taking the voter-registration oath required by Idaho law. The indictment alleged that Davis belonged to the Mormon Church, an organization that taught and counseled its members to commit bigamy and polygamy, while he swore that he did not belong to such an organization.
Idaho law denied voting and officeholding to bigamists, polygamists, persons who advocated those crimes, and members of organizations that taught or encouraged them. It also required prospective voters to swear that they did not fall within those disqualified categories. Davis sought habeas corpus relief, arguing that the territorial court lacked jurisdiction and that the Idaho provisions conflicted with federal law and the constitutional protection for religious exercise. The lower court refused relief, and the Supreme Court affirmed.
Issue #1
Whether habeas corpus permitted the Supreme Court to review alleged trial errors or the sufficiency of the evidence supporting Davis's conviction.
Holding
No. On habeas review, the Court could determine only whether the territorial district court had jurisdiction over an offense charged in the indictment.
Reasoning
The Court emphasized that habeas corpus is not a substitute for a writ of error or an ordinary appeal. Once a court of competent jurisdiction has tried a defendant, habeas review does not allow a higher court to revisit evidentiary disputes, factual findings, or claimed mistakes in the conduct of the trial.
Accordingly, the Court assumed the indictment's allegations were true: Davis belonged to an organization that taught and counseled bigamy and polygamy, and he falsely denied that membership in taking the registration oath. The only question was whether those alleged facts described an offense that the territorial court had power to try.
Issue #2
Whether the Free Exercise Clause protected religious advocacy of, or participation in an organization encouraging, bigamy and polygamy from Idaho's voter-disqualification and oath requirements.
Holding
No. The Constitution protects religious beliefs and forms of worship, but it does not immunize conduct or advocacy that aids crimes prohibited by valid criminal laws.
Reasoning
Justice Field described religion as involving a person's relation to the Creator and the obligations that relation imposes. In the Court's view, the First Amendment protects beliefs, religious opinions, and modes of worship, so long as their exercise does not injure others' equal rights or interfere with laws enacted to preserve peace, order, and public morals.
The Court regarded bigamy and polygamy as crimes universally condemned in the civilized and Christian world, as well as under federal and Idaho law. It reasoned that teaching, advising, or counseling the commission of a crime aids its commission and may itself be punished, just as other forms of aiding and abetting may be punished.
Relying on Reynolds v. United States, the Court repeated the distinction between protected belief and regulable practice. Permitting a religious belief to excuse prohibited conduct, it said, would make each person's professed religious doctrine superior to law and allow each citizen to become a law unto himself. The Court illustrated that conclusion with religious claims involving human sacrifice or other conduct viewed as destructive of public order.
Issue #3
Whether Congress authorized the Idaho territorial legislature to deny voting and officeholding to persons who advocated criminal violations and to require a registration oath addressing membership in organizations that encouraged bigamy or polygamy.
Holding
Yes. The territorial legislature possessed authority to set reasonable voter and officeholding qualifications not inconsistent with the restrictions imposed by Congress.
Reasoning
Congress gave territorial legislatures authority over rightful subjects of legislation and specifically allowed them to prescribe qualifications for voters and officeholders, subject to enumerated federal limits. Those limits chiefly protected voting rights against discrimination based on race, color, or previous condition of servitude and imposed certain citizenship, age, residency, and military-status rules.
The Idaho statute did not violate those federal restrictions. Apart from excluding persons under guardianship or of unsound mind, it disqualified persons convicted of specified offenses and persons who advocated practical resistance to territorial criminal laws by teaching, counseling, encouraging, or approving prohibited crimes.
The Court also upheld the oath required for voter registration. It characterized the oath as a means of preventing persons who supported disregard of Idaho's criminal law from using political power to defeat or undermine those laws.
Issue #4
Whether Congress's federal legislation disqualifying polygamists and bigamists from voting or holding office preempted Idaho from imposing related disqualifications and registration requirements.
Holding
No. Congress had not occupied the field in a way that barred Idaho's additional provisions.
Reasoning
The federal statute applied generally in the Territories and disqualified polygamists, bigamists, and certain persons cohabiting with more than one woman from voting and officeholding. But it did not address persons who taught, advised, or counseled bigamy or polygamy, nor did it prescribe Idaho's registration-oath mechanism.
Congressional legislation displaces territorial or state legislation when both enactments regulate the same matter in a manner showing that Congress has covered the entire field. Here, the Court found no such overlap: Idaho addressed advocacy, assistance, and means of detecting disqualified voters—subjects the federal statute did not regulate.