Trinity Lutheran Church of Columbia, Inc. v. Comer

Many states have laws against publicly funding religious organizations in accordance with the Establishment Clause of the 1st Amendment.

The Missouri Department of Natural Resources (MoDNR) reimburses organization that re-surface their playgrounds with recycled tires.

Carol Comer ("Comer") was the Director of MoDNR.

In 2012, Trinity Lutheran Church of Columbia ("Church") applied for a grant from Comer under the tire recycling program. Church's application is denied.

Comer denied funding to resurface Church's playground because it was a religious organization.

The district court dismissed Church's funding claim because the court ruled that the Free Exercise Clause doesn't require funding Church.

8th Circuit affirms the court and reiterates that Comer was also following the state Constitution of Missouri to not fund religious organizations.

Does excluding Church from a state grant violating the Free Exercise Clause under the 1st Amendment?

Excluding "Church" from a generally-available grant violates Church's Free Exercise Clause rights.

SCOTUS holds that Comer discriminated against Church on the basis of religion.