People v. Grossman, 85 N.Y.2d 144 (1995)
The determination of whether state action unconstitutionally infringes upon religious freedom is a question of law to be decided by the court, not a question of fact for the jury.
Summary
Grossman was convicted in Town Court for violating a zoning ordinance. He argued his religion required him to violate the ordinance and requested the court include the Free Exercise of Religion Clause from the New York Constitution in its jury charge. The Town Court refused. The County Court reversed, finding Grossman presented enough evidence to warrant the instruction. The Court of Appeals reversed the County Court’s decision, holding that determining whether state action unconstitutionally abridged religious freedom is a question of law for the court, not a question of fact for the jury. The case was remitted to County Court for factual determinations.
Facts
Grossman claimed his religious beliefs required him to violate a town zoning ordinance. During his trial in Town Court, Grossman requested the court include the language of the Free Exercise of Religion Clause from the New York Constitution in the jury charge. The Town Court refused to give the requested instruction.
Procedural History
The Town Court convicted Grossman of the zoning violation. Grossman appealed to the County Court. The County Court reversed and ordered a new trial, concluding that Grossman had presented a sufficient evidentiary basis for the jury instruction. The People appealed to the New York Court of Appeals.
Issue(s)
Whether a jury should determine if state action unconstitutionally abridges a defendant’s religious freedom.
Holding
No, because determining whether state action unconstitutionally abridges religious freedom is a question of law for the court to resolve, not a question of fact for the jury.
Court’s Reasoning
The Court of Appeals emphasized that the jury’s role is to resolve factual disputes by assessing evidence and witness credibility, citing Dominguez v Manhattan & Bronx Surface Tr. Operating Auth., 46 NY2d 528, 534, and Wragge v Lizza Asphalt Constr. Co., 17 NY2d 313, 319. The court reasoned that Grossman’s proposed instruction would require the jury to determine the constitutionality of state action regarding religious freedom, a question of law reserved for the court.
The court affirmed the Town Court’s role in balancing “the interest of the individual right of religious worship against the interest of the State which is sought to be enforced” (People v Woodruff, 26 AD2d 236, 238, affd no opn 21 NY2d 848). Therefore, the Town Court acted appropriately in refusing the requested jury instruction. The court did not elaborate further on the specific facts of the case or the zoning ordinance in question, focusing instead on the fundamental principle of separation of powers between judge and jury.