George Reynolds, a member of the Church of Jesus Christ of Latter Day Saints, was following religious practice when he married his second wife while still married to his first. But he was arrested and convicted of breaking the law. He took his case to the Supreme Court in 1879, arguing that the laws against polygamy (marriage to multiple partners) violated his First Amendment right to the free exercise of religion. He lost.

The Court reasoned that Mr. Reynolds’s beliefs were protected, but his actions were not. The Court’s unanimous decision stated that religious practice could not excuse illegal actions, for religion would then become “superior to the law of the land” and “permit every citizen to become a law unto himself.”