OPERATION CLAMBAKE: SCIENTOLOGY COURT FILES

Part of a public library containing court papers related to lawsuits involving Scientology in some way. Collected to help lawyers and critics of Scientology in future lawsuits from or against this cult. Please report back if this has been of help, or send new contributions to the collection. Thanks. Andreas Heldal-Lund (heldal@online.no)




   The FOUNDING CHURCH OF SCIENTOLOGY OF WASHINGTON, D.C., et al., Appellants,
                                       v.
                       UNITED STATES of America, Appellee.
                                   No. 21483.
          United States, court of Appeals District of Columbia Circuit.
                              Argued Nov. 5, 1968.
       Decided Feb. 5, 1969, Petition for Rehearing Denied April 18, 1969.
  Proceeding on libel of information filed by United States, attorney for
 condemnation of device and accompanying false or misleading labeling. The
 United States District Court for the District of Columbia, John J. Sirica, J.,
 entered a judgment in favor of the government and the claimant appealed. The
 Court of Appeals, J. Skelly Wright, Circuit Judge, held that where incorporated
 church, whose ministers were qualified to perform marriages and burials, made
 out an unrebutted prima facie case that it was a bona fide religion, its
 literature setting forth religious doctrines and referring to instrument used
 in auditing procedures which played a central part in religious doctrine did
 not constitute 'labeling' within Federal Food, Drug, and Cosmetic Act rendering
 device with accompanying false and misleading labeling subject to condemnation.
  Reversed.
  McGowan, Circuit Judge, dissented.

 [1] SEARCHES AND SEIZURES
 Purpose of warrant clause of Fourth Amendment is to interpose relatively
 detached and independent decision maker between privacy of individual and the
 otherwise unchecked zeal of enforcement officials.  U.S.C.A.Const. Amend. 4.

 [2] ADMIRALTY
 In case of ordinary civil attachments, details of such proceedings are, even in
 federal courts, left to state law, and in cases in admiralty the process is
 governed by Admiralty Rules.  Fed.Rules Civ.Proc. rule 64, 28 U.S.C.A.;
 Supplemental Rules for Certain Admiralty and Maritime Claims, rules B, C, 28
 U.S.C.A.

 [2] FEDERAL CIVIL PROCEDURE
 In case of ordinary civil attachments, details of such proceedings are, even in
 federal courts, left to state law, and in cases in admiralty the process is
 governed by Admiralty Rules.  Fed.Rules Civ.Proc. rule 64, 28 U.S.C.A.;
 Supplemental Rules for Certain Admiralty and Maritime Claims, rules B, C, 28
 U.S.C.A.

 [3] SEARCHES AND SEIZURES
 Where libel of information filed by United States Attorney particularly
 described items to be seized and gave a reasonably particular account of
 respects in which items were thought to contravene Food, Drug, and Cosmetic
 Act, libel was subject to scrutiny by federal district judge and it was only
 after his review and by court order that warrant was issued for seizure, all
 requirements interposed by Fourth Amendment had been complied with and the
 seizure was reasonable.  Federal Food, Drug, and Cosmetic Act, s 304(a, b),
 21 U.S.C.A. s 334(a, b);  U.S.C.A.Const. Amend. 4.

 [4] SEARCHES AND SEIZURES
 Inspections of premises open to general public are not illegal searches.
 U.S.C.A.Const. Amend. 4.

 [5] CONSTITUTIONAL LAW
 First Amendment does not protect from regulation or prohibition all bona fide
 religious practices, but rather embraces two concepts:  freedom to believe and
 freedom to act;  and while the first is absolute, in the nature of things the
 second cannot be and conduct remains subject to regulation for protection of
 society.  U.S.C.A.Const. Amend. 1.

 [6] CONSTITUTIONAL LAW
 Legal restrictions cannot be applied to religious practices merely on showing
 of rational relationship between regulation imposed and legitimate end
 sought.  U.S.C.A.Const. Amend. 1.

 [7] CONSTITUTIONAL LAW
 Freedoms of speech and of press, of assembly and of worship are susceptible of
 restriction only to prevent grave and immediate danger to interests which state
 may lawfully protect.  U.S.C.A.Const. Amend. 1.

 [7] CONSTITUTIONAL LAW
 Freedoms of speech and of press, of assembly and of worship are susceptible of
 restriction only to prevent grave and immediate danger to interests which state
 may lawfully protect.  U.S.C.A.Const. Amend. 1.

 [7] CONSTITUTIONAL LAW
 Freedoms of speech and of press, of assembly and of worship are susceptible of
 restriction only to prevent grave and immediate danger to interests which state
 may lawfully protect.  U.S.C.A.Const. Amend. 1.

 [8] DRUGS AND NARCOTICS
 In determining whether literature "accompanies" a device within meaning of
 Federal Food, Drug, and Cosmetic Act authorizing seizure of misbranded device,
 literature need not be shipped together with device but must be designed for
 use in distribution and sale of device, and the two must be parts of an
 integrated distribution system.  Federal Food, Drug, and Cosmetic Act, ss 1
 et seq., 201(b, m), 304(a), 502, 21 U.S.C.A. ss 301 et seq.,
 321(b, m), 334(a), 352;  U.S.C.A.Const. Amends. 1, 4.
 See publication Words and Phrases for other judicial constructions and
 definitions.

 [9] DRUGS AND NARCOTICS
 Where incorporated church, whose ministers were qualified to perform marriages
 and burials, had made out an unrebutted prima facie case that it was a bona
 fide religion, its literature setting forth religious doctrines and referring
 to instrument used in auditing procedures which played a central part in
 religious doctrine did not constitute "labeling" within Federal Food, Drug,
 and Cosmetic Act rendering device with accompanying false and misleading
 labeling subject to condemnation.  Federal Food, Drug, and Cosmetic Act,
 ss 1 et seq., 201(b, m), 304(a), 502, 21 U.S.C.A. ss 301 et
 seq., 321(b, m), 334(a), 352;  U.S.C.A.Const. Amends. 1, 4.
 See publication Words and Phrases for other judicial constructions and
 definitions.

 [10] CONSTITUTIONAL LAW
 Failure of incorporated church, whose ministers were licensed as such with
 legal authority to marry and to bury and which had fundamental writings
 containing general account of man and his nature comparable in scope, if not in
 content, to those of some recognized religions, to postulate a deity in
 conventional sense did not preclude its status as a religion within protection
 of First Amendment.  U.S.C.A.Const. Amend. 1.

 [11] CONSTITUTIONAL LAW
 Theories of church, which had made a prima facie showing of being a bona fide
 religion, as expounded in its literature were protected by First Amendment from
 court room evaluation as to truth or falsity in suit by government to condemn
 instrument under Federal Food, Drug, and Cosmetic Act on theory that literature
 expounding the theories constituted false and misleading labeling of the
 devices.  Federal Food, Drug, and Cosmetic Act, ss 1 et seq., 201(b, m),
 304(a), 502, 21 U.S.C.A. ss 301 et seq., 321(b, m), 334(a),
 352;  U.S.C.A.Const. Amends. 1, 4.

 [12] DRUGS AND NARCOTICS
 A showing that auditing services had been peddled by incorporated church to
 general public on basis of wholly non-religious pseudo-scientific
 representations would support a verdict of false and misleading labeling of
 instruments seized by Food and Drug Administration as devices with accompanying
 false and misleading labeling.  Federal Food, Drug, and Cosmetic Act, ss 1
 et seq., 201(b, m), 304(a), 502, 21 U.S.C.A. ss 301 et seq.,
 321(b, m), 334(a), 352;  U.S.C.A.Const. Amends. 1, 4.

 [13] DRUGS AND NARCOTICS
 In order to raise a religious defense to charge of misbranding of device,
 person charged with alleged misrepresentation must have explicitly held himself
 out as making religious, as opposed to medical, scientific or otherwise
 secular, claims.  Federal Food, Drug, and Cosmetic Act, ss 1 et seq.,
 201(b, m), 304(a), 502, 21 U.S.C.A. ss 301 et seq., 321(b, m),
 334(a), 352;  U.S.C.A.Const. Amends. 1, 4.

 [14] FEDERAL COURTS
 Where jury's general verdict may have rested upon grounds improper for First
 Amendment reasons, a reviewing court will not pause to speculate whether jury's
 verdict was actually reached on other, and permissible grounds.
 U.S.C.A.Const. Amend. 1.

 [15] FEDERAL COURTS
 Denial of First Amendment rights is one of those exceptional instances where
 appellate court will notice error in charge even when no objection is made at
 trial.  U.S.C.A.Const. Amend. 1.

 [16] DRUGS AND NARCOTICS
 If on new trial relating to condemnation of device and accompanying false or
 misleading labeling defense of religious claim is made with regard to labeling,
 it is incumbent on trial judge to rule in first instance as to whether each
 item of alleged false and misleading labeling makes religious claims and hence
 cannot be submitted to jury for factual determinations of whether it is a label
 for device in question and whether it is false.  Federal Food, Drug, and
 Cosmetic Act, ss 1 et seq., 201(b, m), 304(a), 502, 21
 U.S.C.A. ss 301 et seq., 321(b, m), 334(a), 352;  U.S.C.A.Const.
 Amends. 1, 4.

 [17] CONSTITUTIONAL LAW
 If government in event of a new trial in proceeding relating to condemnation of
 device and accompanying false labeling successfully challenges bona fides of
 church's claim of religion with respect to literature describing device and
 asserted to be false and misleading labeling, First Amendment question as a
 defense would disappear from case.  Federal Food, Drug, and Cosmetic Act,
 ss 1 et seq., 201(b, m), 304(a), 502, 21 U.S.C.A. ss 301 et
 seq., 321(b, m), 334(a), 352;  U.S.C.A.Const. Amends. 1, 4.
  On Appellee's Petition for Rehearing
  *1148 **231 Mr. Oscar H. Brinkman, Washington, D.C., for appellants.
  Mr. Nathan Dodell, Asst. U.S. Atty., with whom Messrs. David G. Bress, U.S.
 Atty., Frank Q. Nebeker, Asst. U.S. Atty., William W. Goodrich, Assistant
 General Counsel, Department of Health, Education and Welfare, and Joanne S.
 Sisk, Attorney, Department of Health, Education and Welfare, were on the brief,
 for appellee.

  Before WRIGHT, MCGOWAN and ROBINSON, Circuit Judges.

  J. SKELLY WRIGHT, Circuit Judge:
  This is an appeal from a judgment and decree of condemnation and destruction
 against several electrical instruments and a large quantity of literature owned
 by claimants-appellants, The Founding Church of Scientology of Washington,
 D.C. and various individual adherents of that organization. The instruments and
 literature were seized by the Food and Drug Administration as 'devices' with
 accompanying 'false and misleading labeling' subject to condemnation under the
 Food, Drug and Cosmetic Act, 21 U.S.C. s 301 et seq. (1964).  The Government
 further charged that the instruments were 'devices' lacking 'adequate
 directions for use,' in further violation of the Act. [FN1]  After a jury
 trial, a general verdict 'for the Government' was returned, and a judgment and
 decree of condemnation was entered.

      FN1. 'Any * * * device * * * that is * * * misbranded * * * while in
     interstate commerce * * * shall be liable to be proceeded against * * * and
     condemned in any district court of the United States within the
     jurisdiction of which the article is found * * *.'
     21 U.S.C. s 334(a).
     'A drug or device shall be deemed to be misbranded--
     '(a) False or misleading label.
     'If its labeling is false or misleading in any particular.
     '(f) Directions for use and warnings on label.
     'Unless its labeling bears (1) adequate directions for use * * *.'
     21 U.S.C. s 352.
     'The term 'interstate commerce' means * * * (2) commerce within the
     District of Columbia * * *.'
     21 U.S.C. s 321(b).

  Appellants contend that the seizure of the articles violated their Fourth
 Amendments rights, that the proceedings interfered with the free exercise of
 their religion, and that the evidence was insufficient to sustain the verdict.
 Because we find that much of the literature relied *1149 **232 on by the
 Government to establish misbranding was not 'labeling' [FN2] within the meaning
 of the statute as interpreted in the light of the First Amendment, we reverse.

      FN2. As defined in 21 U.S.C. s 321(m), the text of which is set out in
     Note 15, infra.

  I
  At the outset, we confront appellants' claim that the disputed instruments and
 literature, the res of this lawsuit, were seized in violation of the Fourth
 Amendment.  The Act provides that misbranded devices 'shall be liable to be
 proceeded against * * * on libel of information,' [FN3] and that such devices
 'shall be liable to seizure by process pursuant to the libel, and the procedure
 in cases under this section shall conform, as nearly as may be, to the
 procedure in admiralty * * *.' [FN4] The applicable procedure in admiralty at
 the time of the seizure was provided in former Admiralty Rule 21, the text of
 which is set out in the margin. [FN5]

      FN3. 21 U.S.C. s 334(a).

      FN4. 21 U.S.C. s 334(b).

      FN5. 'All informations and libels of information upon seizures for any
     breach of the revenue, or navigation or other laws of the United States,
     shall state the place of seizure, whether it be on land or on the high
     seas, or on navigable waters within the admiralty and maritime jurisdiction
     of the United States, and the district within which the property is brought
     and where it then is.  The information or libel of information shall
     propound in distinct articles the matters relied on as grounds or causes of
     forfeiture, and aver the same to be contrary to the form of the statute or
     statutes of the United States in such case provided, as the case may
     require, and shall conclude with a prayer of due process to enforce the
     forfeiture, and to give notice to all persons concerned in interest to
     appear and show cause at the return day of the process why the forfeiture
     should not be decreed.'
     7A J. MOORE, FEDERAL PRACTICE P.30, p. 236 (2d ed.1968).

  The Government complied with the procedures required by statute and rule in
 this case.  Pursuant to the inspection provisions of the Act, FDA agents
 visited the Founding Church of Scientology, obtained a demonstration of the
 instrument later seized, and bought copies of the literature later alleged to
 be 'labeling' of the instrument. The United States Attorney then filed a libel
 of information with the District Court, describing the instrument and
 literature and averring that together they constituted a 'device' and
 accompanying 'false or misleading labeling' subject to condemnation under the
 Act.  The court ordered issuance of a warrant authorizing seizure of the
 instruments and literature, and public advertisement of the seizure.  FDA
 agents and United States Marshals carried out the seizure on January 4, 1963,
 at various premises owned by appellant Founding Church and its affiliates,
 after service of the warrant of attachment.
  Appellants [FN6] contend that seizures such as this are governed by the
 warrant clause of the Fourth Amendment, which provides that 'no Warrants shall
 issue, but upon probable cause, supported by Oath or affirmation, and
 particularly describing the place to be searched, and the persons or things to
 be seized.'  Since in appellants' view the warrant of seizure was not issued
 'upon probable cause, supported by Oath or affirmation,' they contend that the
 exclusionary rule bars the use in evidence in a condemnation proceeding of the
 matter seized.

      FN6. Appellants appeared as claimants to the seized goods in the District
     Court, and demanded a jury trial, under 21 U.S.C. s 334(b).

  In arguing the Fourth Amendment issue, the parties have concentrated chiefly
 upon the question whether the exclusionary rule applies to condemnation
 proceedings under the Act. [FN7] Because we find *1150 **233 that the
 seizure in this case was 'reasonable' under the applicable Fourth Amendment
 standards, we do not reach that question.

      FN7. See One 1958 Plymouth Sedan v. Com. of Pennsylvania, 380 U.S. 693,
     85 S.Ct. 1246, 14 L.Ed.2d 170 (1965); Boyd v. United States, 116 U.S.
     616, 6 S.Ct. 524, 29 L.Ed. 746 (1886); but see United States v. 2000
     Plastic Tubular Cases, etc., 3 Cir., 352 F.2d 344 (1965), cert. denied,
     383 U.S. 913, 86 S.Ct. 891, 15 L.Ed.2d 667 (1966).

  [1] The Fourth Amendment protects 'the right of the people to be secure in
 their persons, houses, papers, and effects, against unreasonable searches and
 seizures.'  It gives procedural form to this sweeping protection through the
 warrant clause, which requires that a magistrate review the decision to arrest
 or search except in exigent cases.  The often stated purpose of this
 requirement is to interpose a relatively detached and independent decision
 maker between the privacy of the individual and the otherwise unchecked zeal of
 enforcement officials. [FN8]

      FN8. Camara v. Municipal Court of City and County of San Francisco, 387
     U.S. 523, 532-533, 87 S.Ct. 1727, 18 L.Ed.2d 930 (1967); Johnson v.
     United States, 333 U.S. 10, 14, 68 S.Ct. 367, 92 L.Ed. 436 (1948).

  [2] Though warrants are generally necessary for arrests of persons and for
 searches, the warrant requirement has not traditionally been imposed upon
 seizures of the type involved in this case-- attachment of property in the
 course of civil proceedings.  This does not mean that the Fourth Amendment does
 not apply to such seizures, in both its substantive prohibition against
 unreasonable seizures and its procedural requirement of judicial or quasi-
 judicial review of the decision to seize.  It means merely that judicial
 restraint is imposed through a different form of proceeding than the showing of
 probable cause before a magistrate.  In the case of ordinary civil attachments,
 the details of such proceedings are, even in the federal courts, left to state
 law. [FN9]  In cases in admiralty, the process is governed by the Admiralty
 Rules, lately recodified as a supplement to the Civil Rules. [FN10]

      FN9. Rule 64, FED.R.CIV.P.

      FN10. Supplemental Rules B and C, FED.R.CIV.P.

  Tradition has sanctified these forms and processes of civil attachments, and
 they have not been subjected to much Fourth Amendment scrutiny in either
 litigation or scholarly literature. We need not review them generally now,
 however, for we find that this particular seizure was reasonable in both the
 grounds supporting it and the judicial supervision over the decision to make
 it.
  [3][4] The libel of information filed by the United States Attorney
 particularly described the items to be seized, and gave a reasonably particular
 account of the respects in which they were thought to contravene the Act.
 [FN11]  Though the libel was not a verified complaint, it has been been held
 that in admiralty complaints signed by Government officers are attested to by
 the officer's oath of office. [FN12]  The libel was subject to scrutiny by a
 United States District Judge, and it was only after his review and by court
 order that the warrant issued.  In these circumstances, all requirements
 imposed by the Fourth Amendment were complied with. [FN13]

      FN11. The libel alleged that the 'Hubbard Electrometers' were accompanied
     as labeling by a list of named books and pamphlets, which were alleged to
     claim that the E-meter could be used in the cure or treatment of a list of
     named diseases, claims alleged to be false and misleading.

      FN12. United States v. 935 Cases, etc., of Tomato Puree, 6 Cir., 136
     F.2d 523, 525, cert. denied, 320 U.S. 778, 64 S.Ct. 92, 88 L.Ed. 467
     (1943).

      FN13. Appellants also contend that the seizure was the fruit of an illegal
     search in the form of a visit to the Scientology headquarters four years
     previously by an FDA agent passing as a member of the general public. There
     was no showing that the previous visit bore any relationship to the seizure
     in this case, and in any event inspections of premises open to the general
     public are not illegal searches.  Lewis v. United States, 385 U.S. 206,
     87 S.Ct. 424, 17 L.Ed.2d 312 (1966). Appellants also contend that the
     seizure was carried out in an unreasonable manner, but on examination of
     the record we find this contention to be without merit.

  *1151 **234 II
  We turn then to the merits of the Government's case against the instruments
 and literature subject to the decree of condemnation. The Government has
 charged that the instruments seized, Hubbard Electrometers or 'E-meters,' are
 'devices' as defined in the Act; [FN14] that the literature seized constitutes
 'labeling' of the device, in that it is 'written, printed, or graphic
 matter * * * accompanying' the device; [FN15] and that this 'labeling' is false
 or misleading.  Because our reading of the Act in its application to this case
 is influenced by appellants' claims to the free exercise of their religion,
 some background concerning their movement becomes necessary.

      FN14. 'The term 'device' * * * means instruments, apparatus, and
     contrivances, including their components, parts, and accessories, intended
     (1) for use in the diagnosis, cure, mitigation, treatment, or prevention of
     disease in man or other animals; or (2) to affect the structure or any
     function of the body of man or other animals.'
     21 U.S.C. s 321(h).

      FN15. 'The term 'labeling' means all labels and other written, printed, or
     graphic matter (1) upon any article or any of its containers or wrappers,
     or (2) accompanying such article.'
     21 U.S.C. s 321(m).

  A.  Appellants in this case, claimants to the seized materials, are individual
 and corporate adherents to the movement known as Scientology. The movement
 apparently rests almost entirely upon the writings of one man, L. Ron Hubbard,
 an American who maintained the headquarters of the movement in England at the
 time this action was brought.  In the early 1950's, Hubbard wrote tracts
 elucidating what he called 'Dianetics.' [FN16] Dianetics is a theory of the
 mind which sets out many of the therapeutic techniques now used by
 Scientologists, including techniques attacked by the Government in this case as
 false healing.

      FN16. DIANETICS: THE EVOLUTION OF A SCIENCE (1958) (a work which
     apparently appeared in ASTOUNDING SCIENCE FICTION magazine in 1950-- see A
     BRIEF BIOGRAPHY OF L. RON HUBBARD 8 (author not given, 1959); DIANETICS:
     THE MODERN SCIENCE OF MENTAL HEALTH (1950); SCIENCE OF SURVIVAL: PREDICTION
     OF HUMAN BEHAVIOUR (1951).  In this and succeeding footnotes, where author
     is not given, the author is L. Ron Hubbard.

  The basic theory of Dianetics is that man possesses both a reactive mind and
 an analytic mind.  The analytic mind is a superior computer, incapable of
 error, to which can be attributed none of the human misjudgments which create
 social problems and much individual suffering.  These are traceable rather to
 the reactive mind, which is made up of 'engrams,' or patterns imprinted on the
 nervous system in moments of pain, stress or unconsciousness.  These imprinted
 patterns may be triggered by stimuli associated with the original imprinting,
 and may then produce unconscious or conditioned behavior which is harmful or
 irrational. [FN17]

      FN17. An exposition of the 'fundamentals of Dianetics' of relative clarity
     and brevity is to be found in the publisher's introduction to SCIENCE OF
     SURVIVAL, supra Note 16, at i-viii.

  Dianetics is not presented as a simple description of the mind, but as a
 practical science which can cure many of the ills of man. It terms the ordinary
 person, encumbered by the 'engrams' of his reactive mind, as a 'preclear,' by
 analogy to a computer from which previously programmed instructions have not
 been erased. The goal of Dianetics is to make persons 'clear,' thus freeing the
 rational and infallible analytical mind.  The benefits this will bring are set
 out in considerable and alluring detail. All mental disorders are said to be
 caused by 'engrams,' as are all psychosomatic disorders, and that concept is
 broadly defined. [FN18]

      FN18. DIANETICS: THE MODERN SCIENCE OF MENTAL HEALTH, supra Note 16, at
     91-108.

  A process of working toward 'clear' is described as 'auditing.' This process
 was explicitly characterized as 'therapy' in Hubbard's best-selling book
 DIANETICS: *1152 **235 THE MODERN SCIENCE OF MENTAL HEALTH (1950).  The
 process involves conversation with an 'auditor' who would lead the subject or
 'preclear' along his 'time track,' discovering and exposing 'engrams' along the
 way. Though auditing is represented primarily as a method of improving the
 spiritual condition of man, rather explicit benefits to bodily health are
 promised as well. Hubbard has asserted that arthritis, dermatitis, asthma, some
 coronary difficulties, eye trouble, bursitis, ulcers and sinusitis are
 psychosomatic and can be cured, and further that tuberculosis is 'perpetuated
 by engrams.' [FN19]

      FN19. Id. at 92-93.  In a later work, Hubbard brought cancer within the
     scope of treatment by 'auditing.'  See SCIENTOLOGY: A HISTORY OF MAN 21
     (4th ed. 1961).

  A few years after the appearance of Dianetics, Hubbard began to set forth the
 broader theories of Scientology.  Dianetics was explicitly endorsed as part of
 Scientology, 'that branch * * * that covers Mental Anatomy.' [FN20] Testimony
 by Scientology adherents at the trial made clear that they continue to uphold
 the theories of Dianetics, though they feel that there may have been some
 errors in early formulations.

      FN20. See SCIENCE OF SURVIVAL, supra Note 16, at 1 n. 1 (apparently a
     footnote inserted into a later printing of this pre-Scientology book).

  With Scientology came much of the overlay which lends color to the
 characterization of the movement as a religious one.  Hubbard has claimed
 kinship between his theories and those espoused by Eastern religions,
 especially Hinduism and Buddhism. [FN21]  He argues that man is essentially a
 free and immortal spirit (a 'thetan' in Scientological terminology) [FN22]
 which merely inhabits the 'mest body' ('mest' is an acronym of the words
 matter, energy, space, time). [FN23]  Man is said to be characterized by the
 qualities of 'beingness,' 'havingness,' and 'doingness.' [FN24] The
 philosophical theory was developed that the world is constructed on the
 relationships of 'Affinity,' 'Reality' and 'Communication,' which taken
 together are denominated 'the ARC Triangle.' [FN25]

      FN21. See, e.g., L. RON HUBBARD'S PAB's, BOOK III 14-20 (1956).

      FN22. See SCIENTOLOGY: THE FUNDAMENTALS OF THOUGHT 32 (1956).

      FN23. See SCIENTOLOGY 8-8008 at 13-19 (3d ed.1956).

      FN24. See SCIENTOLOGY: THE FUNDAMENTALS of THOUGHT, supra Note 22, at 16.

      FN25. See SCIENTOLOGY 8-8008, supra Note 23, at 20-44.

  On the more mundane level, early in the career of Scientology Hubbard's
 followers-- at least those in the United States-- began to constitute
 themselves into formal religious bodies.  The Founding Church of Scientology of
 Washington, D.C., one of the appellants, was incorporated in the District of
 Columbia in 1955.  A formal creed was promulgated and was made part of the
 Articles of Incorporation.  From the literature of the movement in evidence at
 trial, it appears that the move toward formal religious organization disturbed
 some adherents of Scientology, who seem to have regarded it as an attempt to
 provide a legal cloak for the movement's activities.  But Hubbard defended the
 church movement, disavowing mysticism or supernaturalism, but pointing out the
 kinship of his ideas with those of the Vedas and other Eastern religious
 doctrines. [FN26]

      FN26. For Hubbard's account of this dispute, see L. RON HUBBARD'S PAB'S,
     BOOK III, supra Note 21, at 14-20.

  From the evidence developed at trial, it appears that a major activity of the
 Founding Church and its affiliated organizations in the District of Columbia is
 providing 'auditing,' at substantial fees (at the time of trial $500 for a 25-
 hour course), to persons interested in Scientology.  The affiliated Academy of
 Scientology is engaged in training auditors.  Auditors are paid directly by the
 Church.  There is no membership in the Church as such; persons are accepted for
 auditing on the basis of their interest in Scientology *1153 **236 (and
 presumably their ability to pay for its benefits).
  The Hubbard Electrometer, or E-meter, plays an essential, or at least
 important, part in the process of auditing.  The E-meter is a skin
 galvanometer, similar to those used in giving lie detector tests.  The subject
 or 'preclear' holds in his hands two tin soup cans, which are linked to the
 electrical apparatus.  A needle on the apparatus registers changes in the
 electrical resistance of the subject's skin.  The auditor asks questions of the
 subject, and the movement of the needle is apparently used as a check of the
 emotional reaction to the questions.  According to complex rules and procedures
 set out in Scientology publications, the auditor can interpret the movements of
 the needle after certain prescribed questions are asked, and use them in
 diagnosing the mental and spiritual condition of the subject.  The E-meters are
 sold for about $125, and are advertised in Scientology publications available
 at the Distribution Center adjoining the Church.
  The Scientology movement in the District of Columbia also offers the entire
 range of Scientology publications for sale.  Over the years this literature has
 grown into a formidable corpus. Hubbard's two early books on Dianetics are
 sold, along with later treatises developing Scientology.  A large number of
 pamphlets and tracts supplements the hardcover books.  The movement has a
 monthly magazine, ABILITY, which at the time of trial had published over 100
 numbers.  In addition, 'L. Ron Hubbard's Professional Auditors' Bulletins,'
 numbering at least 80 at the time of trial, are collected and published in
 pamphlets.  Much of this literature is before the court as exhibits in
 evidence, and a large proportion of it stands condemned by the District Court's
 decree as 'false or misleading labeling' of the E-meter. [FN27]

      FN27. In an appendix to its decree the District Court listed the works
     found to make false claims respecting the curative powers of auditing and
     ordered them condemned along with the E-meter.  Since we conclude that the
     judgment of the court must be reversed in toto, we do not reach appellants'
     claim that the Act does not authorize condemnation of labeling, especially
     'labeling' which takes the form of general literature.

  B.  With this factual background in mind, we turn to the litigation of this
 case in the District Court.  The Government has framed this as a typical Food,
 Drug and Cosmetic Act case, involving a device whose accompanying promotional
 literature makes claims to curative powers unsupported in fact.  The Government
 has culled from the vast literature of Scientology a large number of statements
 which assert or imply that 'engrams' or the 'reactive mind' cause various
 conditions, mostly those normally considered mental or psychosomatic disorders,
 but also including diseases or conditions which standard medical opinion would
 regard as organic.  Further statements have been found asserting that auditing
 or processing, in clearing away the 'engrams,' can cure or alleviate these
 conditions.  And finally statements have been introduced indicating that the E-
 meter is essential to, or at least useful in, auditing or processing.  On this
 basis, the Government claims to have shown that the E-meter is a 'device'
 within the meaning of the Act, in that it is 'intended * * * for use in the
 diagnosis, cure, mitigation, treatment, or prevention of disease * * *.' 21
 U.S.C. s 321(h).
  The Government put on a series of expert witnesses.  First, physicists and
 engineers testified concerning the E-meter itself. They found it to be a crude
 skin galvanometer, of reasonably craftsmanlike design and construction, though
 with certain serious defects if meant to be used as a research tool for
 meaningfully measuring electrical skin resistance.
  Next, a series of doctors and medical researchers and a psychiatrist testified
 that, within their expert knowledge, there was no use for such an instrument in
 the diagnosis or treatment of any disease or mental disorder. They were asked
 about the specific diseases or conditions claimed in the Scientology
 literature *1154 **237 to be susceptible of alleviation through auditing,
 and unanimously agreed that none of these could be treated or helped in any way
 through any known use of the E-meter. [FN28]

      FN28. One Government witness, a psychophysiologist and neurophysiologist,
     did testify that there is a connection between stimuli, including mental or
     emotional stimuli, and skin resistance.  He stated: 'The good skin
     resistance devices have been used as a research tool and only very
     occasionally as a clinical tool to try to discover areas of emotional
     conflict within an individual who is characterized by a neurotic ailment,
     if that is the correct word to use here.'  However, the witness did not
     consider the E-meter a 'good skin resistance device' because its needle
     reacted to such irrelevant factors as the tightness with which the subject
     held the soup cans.

  In its legal arguments the Government has contended from the outset that
 whether or not Scientology is a religion, and whether or not auditing or
 processing is a practice of that religion, are entirely irrelevant to the
 case.  Religious beliefs, it is argued, are entirely protected by the First
 Amendment, but action in the name of religion is susceptible to legal
 regulation under the same standards and to the same degree as it would be if
 entirely secular in purpose.
  Appellants have argued from the first that the entire case must fall as an
 unconstitutional religious persecution.  In their view, auditing or processing
 is a central practice of their religion, akin to confession in the Catholic
 Church, and hence entirely exempt from regulation or prohibition.  They have
 made no attempt to contradict the expert testimony introduced by the
 Government. They have conceded that the E-meter is of no use in the diagnosis
 or treatment of disease as such, and have argued that it was never put forward
 as having such use.  Auditing or processing, in their view, treats the spirit
 of man, not his body, though through the healing of the spirit the body can be
 affected.  They have culled from their literature numerous statements
 disclaiming any intent to treat disease and recommending that Scientology
 practitioners send those under their care to doctors when organic defects may
 be found.  They have introduced through testimony a document which they assert
 all those who undergo auditing or processing must sign which states that
 Scientology is 'a spiritual and religious guide intended to make persons more
 aware of themselves as spiritual beings, and not treating or diagnosing human
 ailments of body or mind, and not engaged in the teaching of medical arts or
 sciences * * *.'
  Finally, with respect to their claim to be a religion and hence within the
 protection of the First Amendment, they have shown that the Founding Church of
 Scientology is incorporated as a church in the District of Columbia, and
 that its ministers are qualified to perform marriages and burials.  They have
 introduced their Creed into evidence.  The Government has made no claim that
 the Founding Church is not a bona fide religion, that auditing is not part of
 the exercise of that religion, or that the theory of auditing is not a doctrine
 of that religion.
  C.  Thus both parties have viewed the religious issue as a simple one.  In the
 Government's view, religion is simply irrelevant-- appellants have engaged in
 'action' and hence stripped themselves of any First Amendment protection.  In
 appellants' view, religion is dispositive-- auditing is part of the practice of
 their faith and hence the free exercise clause protects it from all secular
 regulation.  In our view, the religious issue is more complex than either of
 the parties has maintained.
  [5] First, it is clear that the First Amendment does not protect from
 regulation or prohibition all bona fide religious practices. As the Supreme
 Court has stated:
  '* * * (The First Amendment) embraces two concepts,-- freedom to believe and
 freedom to act.  The first is absolute but, in the nature of things, the second
 cannot be.  Conduct remains *1155 **238 subject to regulation for the
 protection of society. * * *'
  Cantwell v. Connecticut, 310 U.S. 296, 303-304, 60 S.Ct. 900, 903, 84 L.Ed.
 1213 (1940). Thus the prohibition of plural marriage has been upheld, even
 though the practice is a religious duty to some. [FN29]  Similarly, parading
 without a license [FN30] and the sale by children of religious literature
 [FN31] have been prohibited, even though practiced as tenets of religious
 faith.

      FN29. Davis v. Beason, 133 U.S. 333, 10 S.Ct. 299, 33 L.Ed. 637
     (1890); Reynolds v. United States, 98 U.S. (8 Otto) 145, 25 L.Ed. 244
     (1878).

      FN30. Cox v. New Hampshire, 312 U.S. 569, 61 S.Ct. 762, 85 L.Ed. 1049
     (1941).

      FN31. Prince v. Commonwealth of Massachusetts, 321 U.S. 158, 64 S.Ct.
     438, 88 L.Ed. 645 (1944).

  [6][7] On the other hand, legal restrictions cannot be applied to religious
 practices, as they can in much of the secular realm, merely on a showing of a
 rational relationship between the regulation imposed and the legitimate end
 sought.  In Cantwell, supra, 310 U.S. at 304, 60 S.Ct. at 903, the Court
 stated that 'the power to regulate must be so exercised as not, in attaining a
 permissible end, unduly to infringe the protected freedom.'  And in West
 Virginia State Board of Education v. Barnette, 319 U.S. 624, 639, 63 S.Ct.
 1178, 1186, 87 L.Ed. 1628 (1943), the Court spoke more elaborately and more
 forcefully to the same issue:
  '* * * The right of a State to regulate, for example, a public utility may
 well include, so far as the due process test is concerned, power to impose all
 of the restrictions which a legislature may have a 'rational basis' for
 adopting.  But freedoms of speech and of press, of assembly, and of worship may
 not be infringed on such slender grounds.  They are susceptible of restriction
 only to prevent grave and immediate danger to interests which the State may
 lawfully protect. * * *'
  Similarly in Sherbert v. Verner, 374 U.S. 398, 406, 83 S.Ct. 1790, 1795, 10
 L.Ed.2d 965 (1963), the Court held that "only the gravest abuses, endangering
 paramount interests, give occasion for permissible limitation" of religious
 practices.  In that case, the Court held that denial of unemployment benefits
 to those who would not work on Saturday, though permissible as a general rule,
 could not be applied to one whose refusal to work was based on religious
 objections.
  The principles enunciated in Cantwell, Barnette and Sherbert at least raise
 a constitutional doubt concerning the condemnation of instruments and
 literature apparently central to the practice of religion.  That doubt becomes
 more serious when we turn to the decision of the Supreme Court in United
 States v. Ballard, 322 U.S. 78, 64 S.Ct. 882, 88 L.Ed. 1148 (1944).
  Ballard involved an eccentric religion known as the 'I Am' movement.  The
 promoters of this religion, members of the Ballard family, claimed to have been
 appointed by one 'Saint Germain' as 'divine messengers,' and to have been given
 the power to cure all diseases.  By virtue of these claims, they obtained money
 from members of the public.  They were tried for mail fraud. The trial judge
 excluded from consideration by the jury the issue of the truth or falsity of
 their claims to divine designation and miraculous powers, and the case was
 submitted on the sole issue of whether they made those claims in good faith.
 They were convicted, and on review the Court of Appeals ruled that exclusion of
 the issue of truth or falsity was improper. Ballard v. United States, 9
 Cir., 138 F.2d 540 (1943).
  The Supreme Court reversed the Court of Appeals, holding that the First
 Amendment prohibited trial of the truth or falsity of religious beliefs:
  '* * * Freedom of thought, which includes freedom of religious
 belief, *1156 **239 is basic in a society of free men. * * * It embraces
 the right to maintain theories of life and of death and of the hereafter which
 are rank heresy to followers of the orthodox faiths.  Heresy trials are foreign
 to our Constitution. Men may believe what they cannot prove.  They may not be
 put to the proof of their religious doctrines or beliefs. * * * Many take their
 gospel from the New Testament.  But it would hardly be supposed that they could
 be tried before a jury charged with the duty of determining whether those
 teachings contained false representations. * * * The religious views espoused
 by respondents might seem incredible, if not preposterous, to most people.  But
 if those doctrines are subject to trial before a jury charged with finding
 their truth or falsity, then the same can be done with the religious beliefs of
 any sect.  When the triers of fact undertake that task, they enter a forbidden
 domain. * * *'
  322 U.S. at 86-87, 64 S.Ct. at 886.
  The Ballard case does not hold merely that religious belief is protected.
 The Ballards engaged in action; they solicited money from their faithful.
 Rather the holding of the case seems to be that regulation of religious action
 which involves testing in court the truth or falsity of religious belief is
 barred by the First Amendment.
  The relevance of Ballard to the case before us is obvious. [FN32] Here the E-
 meter has been condemned, not because it is itself harmful, but because the
 representations made concerning it are 'false or misleading.'  And the largest
 part of those representations is contained in the literature of Scientology
 describing the process of auditing which appellants have claimed, without
 contest from the Government, is part of the doctrine of their religion and
 central to its exercise.  Thus if their claims to religious status are
 accepted, a finding that the seized literature misrepresents the benefits from
 auditing is a finding that their religious doctrines are false.  To construe
 the Food, Drug and Cosmetic Act to permit *1157 **240 such a finding
 would, in the light of Ballard, present the gravest constitutional
 difficulties.

      FN32. We do not perceive any meaningful distinction in the fact that this
     is a civil in rem action whereas Ballard was a criminal prosecution.  In
     the first place the Supreme Court has long recognized that in rem
     forfeiture actions are penal in nature and subject to many of the same
     restrictions placed upon prosecutions. One 1958 Plymouth Sedan v.
     Pennsylvania, supra Note 7; Boyd v. United States, supra Note 7. The
     action taken against appellants here is more than merely remedial; it is
     punitive.  The devices condemned here cannot properly be considered
     contraband per se.  See One 1958 Plymouth Sedan, supra, 380 U.S. at 699,
     85 S.Ct. 1246, 14 L.Ed.2d 170. They are not in themselves harmful, as are
     adulterated foods and drugs or miswired electrical devices.  Their only
     alleged illegal attribute is the supposedly false claims made concerning
     their powers.
     Second, we do not perceive the constitutional defect found in Ballard to
     have been the prosecution of individuals for promulgating false religion.
     That defect was rather the litigation of the truth or falsity of religious
     doctrines.  See 322 U.S. at 87, 64 S.Ct. at 887:
     '* * * But if those doctrines are subject to trial before a jury charged
     with finding their truth or falsity, then the same can be done with the
     religious beliefs of any sect.  When the triers of fact undertake that
     task, they enter a forbidden domain. * * *'
     Thus under Ballard it seems unlikely that a disgruntled former adherent
     could sue a church for fraud and deceit because it had collected money from
     him on the basis of allegedly 'false' doctrines concerning salvation,
     heaven and hell-- or for that matter on the basis of doctrines, such as
     those of the Christian Scientists, concerning the cause and cure of
     disease.
     Indeed, the Supreme Court has recently unanimously held that courts cannot
     settle a civil property dispute between church bodies where the dispute
     turns on the orthodoxy of the religious doctrines espoused by the parties.
     Presbyterian Church in the United States v. Mary Elizabeth Blue Hull
     Memorial Presbyterian Church, 393 U.S. 440, 89 S.Ct. 601, 21 L.Ed.2d 658
     (1969).

  D.  It is with these constitutional considerations in mind that we turn to our
 examination of the application of the statute to the facts of this case.
 Appellants have argued that much of the Scientology literature from which
 claims concerning the curative powers of auditing was culled by a Government
 witness is not 'labeling' of the E-meter within the meaning of the Act, since
 it is part of the religious doctrine of their church.
  For purposes of the Act, 'the term 'labeling' means all labels and other
 written, printed, or graphic matter (1) upon any article or any of its
 containers or wrappers, or (2) accompanying such article.' [FN33] Most of the
 litigation over this definition has turned upon the question of when written
 matter may be said to 'accompany' an article.  In this case the Government has
 contended that Scientology literature on sale in the Distribution Center, which
 adjoins the Hubbard Guidance Center where E-meters were used in auditing,'
 accompanied' the E-meters.

      FN33. 21 U.S.C. s 321(m).

  The courts have construed the word 'accompanying' to give broad remedial
 effect to the purposes of the Act.  In Kordel v. United States, 335 U.S.
 345, 69 S.Ct. 106, 93 L.Ed. 52 (1948), the Supreme Court ruled that, in order
 to be considered 'labeling' of a drug, promotional pamphlets need not be
 shipped together with the drug. It held that:
  'One article or thing is accompanied by another when it supplements or
 explains it, in the manner that a committee report of the Congress accompanies
 a bill.  No physical attachment one to the other is necessary. * * *
  'The false and misleading literature in the present case was designed for use
 in the distribution and sale of the drug, and it was so used. * * *'
  335 U.S. at 350, 69 S.Ct. at 109.  Nor did the fact that the pamphlets were
 sold save them from being 'labeling' in the context of that case:
  '* * * The booklets and drugs were nonetheless interdependent; they were parts
 of an integrated distribution program.  The Act cannot be circumvented by the
 easy device of a 'sale' of the advertising matter where the advertising
 performs the function of labeling.'
  Ibid.
  [8] Kordel thus laid down the broad lines for determining whether
 literature 'accompanies' a drug or device; to do so it need not be shipped
 together with the device, but it must be 'designed for use in the distribution
 and sale of' the device, and the two must be 'parts of an integrated
 distribution program.'
  Subsequent cases in the lower courts have helped sketch in the rough outlines
 drawn by Kordel.  In the Molasses [FN34] case, a best-selling book extolling
 the curative powers of blackstrap molasses, though mentioning no brand names,
 was used by health food retailers in a promotional scheme.  A copy of the book
 was placed in the window of the store next to a display of their brand of
 molasses.  Prospective purchasers of molasses inside the store were handed
 copies of the book and referred to passages in it which made the misleading
 claims about the product.  The particular copies of the book used in this
 scheme were found by the District Court to 'accompany' the molasses. [FN35]

      FN34. United States v. 8 Cartons, etc., Molasses, W.D.N.Y., 103 F.Supp.
     626 (1951).

      FN35. For a similar case, involving the book ABOUT HONEY, see United
     States v. 250 Jars, etc., of U.S. Fancy Pure Honey, E.D.Mich., 218 F.Supp.
     208 (1963), affirmed, 6 Cir., 344 F.2d 288 (1965).

  On the other hand, in the Balanced Foods [FN36] case, general literature which
 falsely claimed healthful properties for a food was found by the Second Circuit
 not *1158 **241 to 'accompany' it.  The facts of that case are
 interesting.  The best- sellers FOLD MEDICINE and ARTHRITIS AND FOLK MEDICINE
 prescribed a mixture of vinegar and honey for a wide variety of maladies.
 After FOLK MEDICINE achieved success, a health food manufacturer bottled a
 preparation of this mixture for sale. The manufacturer also purchased copies of
 the book and distributed them after special promotional efforts to the same
 health food outlets which sold the mixture.  There was evidence that the retail
 stores displayed the mixture and copies of the book a few feet apart.  On these
 facts, the court reversed a judgment that the book constituted 'false labeling'
 of the food.  The court distinguished Kordel on the ground that the drug and
 pamphlet in that case had been mailed in 'integrated transactions,' and that
 the vendors had given away copies of the pamphlets with sales of the drugs in
 some instances. [FN37]

      FN36. United States v. 24 Bottles 'Sterling Vinegar & Honey, etc.', 2
     Cir., 338 F.2d 157 (1964).

      FN37. In another case the Second Circuit has found general literature (in
     this case articles in medical journals) to be 'labeling' because it was
     used in a promotional scheme with a device.  United States v. Diapulse
     Manufacturing Corp. of America, 2 Cir., 389 F.2d 612, cert. denied, 392
     U.S. 907, 88 S.Ct. 2059, 20 L.Ed.2d 1365 (1968).

  [9] The facts of the case before us differ materially from those in the
 cases just reviewed.  The alleged 'labeling' here is not a single readily
 digestible book, or a collection of pamphlets obviously promotional in nature,
 but rather a vast array of the often obscure literature of Scientology.  This
 literature was, according to the evidence at trial, all offered for sale at the
 Distribution Center, Inc., a corporation affiliated with the Founding Church,
 which had its book store next to the Guidance Center at which Scientology
 auditing services were provided.
  A small proportion of this literature deals directly with the E-meter itself.
 Two books, apparently intended for Scientology auditors rather than the general
 public, describe the nature and workings of the E-meter, and at the same time
 give some guidance as to its use in the auditing process. [FN38]  Within these
 books can be found statements to the effect that the E-meter is an essential
 aid to proper auditing.  However, these works contain very little of what the
 Government contends is false and misleading in the labeling of the E-meter.
 Though there are claims concerning the scientific properties of the E-meter
 which are open to question, [FN39] the Government placed little reliance upon
 the these in presenting its case to the jury.

      FN38. J. SANBORN, THE HUBBARD ELECTROMETER (1959); L. R. HUBBARD, E METER
     ESSENTIALS 1961.

      FN39. For instance, in E METER ESSENTIALS 1961, supra Note 38, at 18,
     Hubbard claims that 'the meter will also read Basal Metabolism.'  The
     Government included this claim among its allegations of false labeling in
     the libel.  However, the great bulk of the allegations charges that false
     or misleading statement were made, not about the E-meter itself, but about
     the process of auditing in which it is used.

  Among the literature of Scientology before the court there are found a few
 advertisements, apparently directed at the general public, which make direct
 appeals for customers (or converts, if the appellants' version is to be
 accepted).  These advertisements are found in copies of the monthly Scientology
 magazine ABILITY. Their representations concerning the auditing process appear
 to be general come-ons, designed to bring in the curious or the gullible.
 [FN40]

      FN40. See, e.g., ABILITY, No. 58, at 5:
     'Plagued by illness? We'll make you able to have good health. Get processed
     by the finest capable auditors in the world today. Every auditor a D.D.
     One-week intensive.  Three-week intensive. Weekend group intensives.
     Personally coached and monitored by L. Ron Hubbard, Founder.  Come to
     Registrar, 1812-19th Street, N.W., Washington 9, D.C.'

  By far the greatest bulk of the material alleged to be 'false labeling' of the
 E-meter consists of the general literature of Scientology, which presents in an
 integrated *1159 **242 manner the theory sketched earlier concerning the
 human mind, the sources of various sorts of unhappiness, personality disorder
 and psychosomatic complaints, and the way in which the process of auditing can
 alleviate these ills.  Within this literature is to be found only the most
 occasional passing reference to the E-meter; more often than not, the meter is
 not even mentioned in these general works. Among these are the introductory
 works describing Scientology, and it is presumably these works, if any, which
 are pressed upon curious members of the public in any effort which might be
 made to promote the sale of Scientology services.
  It is within this general literature that the Government has found the
 passages which, in isolation, stand out most dramatically as fraudulent healing
 claims.  For instance, in perhaps the most obscure and impenetrable of the
 books, Hubbard's SCIENTOLOGY: A HISTORY OF MAN (4th ed. 1961), occurs the
 damaging sentence: 'Cancer has been eradicated by auditing out conception and
 mitosis.' [FN41] In short, it is upon this mass of literature that the
 Government largely depended in showing, to the satisfaction of the jury, that
 the Scientology movement had made false claims concerning the curative powers
 of its auditing techniques.

      FN41. At page 21.

  These, however, are the books which set forth the doctrines of Scientology.
 If that movement is a religion, as appellants here have claimed, and as the
 Government has not denied, these books are its scriptures.  The statements
 concerning the powers of auditing over the ills of mind and body are not
 readily separable from general statements of Scientological doctrines
 concerning the nature of man and the relationship of his mind to his body.
 Many will find these doctrines, those which relate to health as well as those
 which do not, absurd or incoherent.  But the Ballard case makes suspect the
 legal inquisition of such doctrines where they are held as religious tenets.
  Were the literature here introduced clearly secular, we might well conclude
 that under existing law it constituted 'labeling' for purposes of the Act.
 Such a conclusion might be justified by a broad reading of the statute,
 consistent with its high purpose of protecting the public health and Pocketbook
 against health frauds. However, such broad readings are not favored when they
 impinge upon constitutionally sensitive areas, especially in the absence of a
 showing of legislative intent to regulate these areas. Nothing in the history
 or interpretation of the Act indicates that it was meant to deal with the
 special problem of religious healing, a problem often given legislative
 treatment separate from that imposed upon the general area of public health and
 medical practice. [FN42]  In light of these considerations, highlighted by the
 explicit holding of Ballard, [FN43] we *1160 **243 interpret the Act as
 not including within its concept of 'labeling' the literature developing the
 doctrines of a religion.

      FN42. 2 D.C.CODE s 134(d) (1967) exempts from the operation of the
     medical licensing laws 'persons treating human ailments by prayer or
     spiritual means, as an exercise of enjoyment of religious freedom * * *.'
     According to Cawley, Criminal Liability in Faith Healing, 39 MINN.L.REV.
     48, 64 (1954), 'Most, if not all, * * * states * * * except from the
     licensing requirements those persons who endeavor to treat human ailments
     by prayer or spiritual means exclusively.'  It has been argued that the
     Constitution requires such exceptions to medical licensing laws. People
     v. Cole, 219 N.Y. 98, 111, 113 N.E. 790, 795, L.R.A.1917C, 816
     (1916) (concurring opinion of Chief Judge Bartlett).  Official and
     unofficial exemptions from various health regulations have protected
     Christian Scientists in the exercise of their religion.  See Schneider,
     Christian Science and the Law: Room for Compromise?, 1 COLUM.J.LAW & SOC.
     PROB. 81 (1965).

      FN43. The Ballards made claims to miraculous healing powers and collected
     money on the basis of these claims.  The truth or falsity of their claims
     was held not subject to evaluation in a prosecution for mail fraud.  They
     marketed no 'device' in connection with their claims, but it is difficult
     confidently to conclude that had they, and had their practices been
     attacked under food and drug laws rather than the mail fraud statute, the
     truth of their claims would have been any more a fit subject for
     litigation.

  [10] E. Finally, we come to the vexing question: is Scientology a religion?
 On the record as a whole, we find that appellants have made out a prima facie
 case that the Founding Church of Scientology is a religion.  It is incorporated
 as such in the District of Columbia.  It has ministers, who are licensed as
 such, with legal authority to marry and to bury.  Its fundamental writings
 contain a general account of man and his nature comparable in scope, if not in
 content, to those of some recognized religions. [FN44]  The fact that it
 postulates no deity in the conventional sense does not preclude its status as a
 religion. [FN45]

      FN44. See text accompanying Notes 21-26, supra.

      FN45. See United States v. Seeger, 380 U.S. 163, 85 S.Ct. 850, 13
     L.Ed.2d 733 (1965); Washington Ethical Society v. District of Columbia,
     101 U.S.App.D.C. 371, 249 F.2d 127 (1957).

  The Government might have chosen to contest the claim that the Founding Church
 was in fact a religion.  Not every enterprise cloaking itself in the name of
 religion can claim the constitutional protection conferred by that status.  It
 might be possible to show that a selfproclaimed religion was merely a
 commercial enterprise, without the underlying theories of man's nature or his
 place in the Universe which characterize recognized religions.  Though
 litigation of the question whether a given group or set of beliefs is or is not
 religious is a delicate business, [FN46] our legal system sometimes requires it
 so that secular enterprises may not unjustly enjoy the immunities granted to
 the sacred.  When tax exemptions are granted to churches, litigation concerning
 what is or is not a church will follow. [FN47]  When exemption from military
 service is granted to those who object on religious grounds, there is similar
 litigation. [FN48]  When otherwise proscribed substances are permitted to be
 used for purposes of worship, worship must be defined. [FN49]  The law has
 provided doctrines and definitions, unsatisfactory as they may be, to deal with
 such disputes. [FN50] Since the Government chose not to contest appellants'
 claim to religious status, and since in our view appellants have made a prima
 facie case for such status, we conclude that for purposes of review of the
 judgment before us they are entitled to the protection of the free exercise
 clause. [FN51]

      FN46. Cf. United States v. Ballard, 322 U.S. 78, 92, 64 S.Ct. 882, 88
     L.Ed. 1148 (1944) (dissenting opinion of Mr. Justice Jackson).

      FN47. Washington Ethical Society v. District of Columbia, supra Note
     45; and see particularly, for perhaps the fullest discussion of the meaning
     of religion for tax exemption purposes, Fellowship of Humanity v. County
     of Alameda, 153 Cal.App.2d 673, 315 P.2d 394 (1957).

      FN48. United States v. Seeger, supra Note 45; United States v.
     Kauten, 2 Cir., 133 F.2d 703 (1943).

      FN49. People v. Woody, 61 Cal.2d 716, 40 Cal.Rptr. 69, 394 P.2d 813
     (1964); In re Grady, 61 Cal.2d 887, 39 Cal.Rptr. 912, 394 P.2d 728
     (1964).

      FN50. For thoughtful efforts at 'defining' religion in the context of
     litigation, see United States v. Seeger, supra Note 45 (with concurring
     opinion of Mr. Justice Douglas, 380 U.S. at 188, 85 S.Ct. 850), and
     Fellowship of Humanity v. County of Alameda, supra Note 47.  Further on
     the question see Comment, Defining Religion: Of God, the Constitution
     and the D.A.R., 32 U.CHI.L.REV. 533 (1965); Boyan, Defining Religion in
     Operational and Institutional Terms, 116 U.PA.L.REV. 479 (1968).  For
     recognition that the bona fides of religious professions may properly be
     litigated, see United States v. Seeger, supra Note 45, 380 U.S. at
     185, 85 S.Ct. 850; In re Grady, supra Note 49; People v. Cole, supra
     Note 42, 113 N.E. at 794.

      FN51. The Founding Church of Scientology has sued the United States in the
     Court of Claims for recovery of income taxes paid upon denial of an
     exemption to the Church under 26 U.S.C. s 501(c), Internal Revenue Code
     of 1954, which exempts a corporation 'organized and operated exclusively
     for religious * * * or educational purposes, * * * no part of the net
     earnings of which inures to the benefit of any private shareholder or
     individual * * *.'  A Commissioner of the Court of Claims has filed an
     opinion, including findings of fact and recommended conclusion of law,
     recommending that the court uphold the denial of the exemption (No. 226-61,
     filed August 7, 1968).  The Commissioner found that a large part of the
     activities of the Founding Church was profit making in nature, and that
     some of its net earnings inured to the benefit of L. Ron Hubbard.

  *1161 **244 Appellants have contended that their theories concerning
 auditing are part of their religious doctrine. We have delineated in detail the
 evidence on which this claim is based.  Again the Government has not contested
 this claim; it has not tried to argue or prove, for instance, that even if
 Scientology as practiced here is a religion, auditing services have been
 peddled to the general public on the basis of wholly non-religious pseudo-
 scientific representations. [FN52]  We cannot assume as a matter of law that
 all theories describing curative techniques or powers are medical and therefore
 not religious.  Established religions claim for their practices the power to
 treat or prevent disease, or include within their hagiologies accounts of
 miraculous cures. [FN53]  In the circumstances of this case we must conclude
 that the literature setting forth the theory of auditing, including the claims
 for curative efficacy contained therein, is religious doctrine of Scientology
 and hence as a matter of law is not 'labeling' for the purposes of the Act.

      FN52. As one thoughtful commentator has noted: 'We can only know that a
     claim is based on religion when we are told that it is. The legal basis for
     stating that a claim is in the religious domain can be that it is held out
     as being religious in nature.'
     And further:
     '* * * If a man simply sells bad drugs and defends on religious grounds, we
     can find his defense insufficient.  For we say: first, you failed to define
     your claims as religious and they were claims of a nature that would not
     ordinarily be understood as religious; second, holding yourself out as a
     drug salesman implied that you spoke with medical authority. * * *'
     Weiss, Privilege, Posture and Protection: 'Religion' in the Law, 73 YALE
     L.J. 593, 604, 605 (1964).
     The distinction between a healer who represents his cure from the first as
     religious, and one who represents it as medical or scientific but then
     defends on the basis of religion, is well marked by two New York cases,
     People v. Cole, supra Note 42 (Christian Science practitioner who cured
     only by prayer exempt from medical licensing statute), and People v.
     Vogelgesang, 221 N.Y. 290, 116 N.E. 997 (1917) (Cardozo, J.) ('faith
     healer' who advertised self as 'specialist in all forms of chronic
     diseases' and who prescribed drugs not exempt).
     In this opinion, of course, we imply no view as to whether the District of
     Columbia medical licensing statute, 2 D.C.CODE ss 120, 134 (1967), is
     applicable to appellants' activities.

      FN53. See, e.g., Schneider, op. cit. supra Note 42.

  [11] This case was tried before a jury on two charges: that the E-meter was
 misbranded in that its 'labeling' made false or misleading claims concerning
 the process of auditing in which it was used, and that the E-meter was not
 accompanied by adequate instructions for its use.  The jury returned a general
 verdict for the Government. During the course of the trial, in an effort to
 prove the first of these two charges, the Government put into evidence some
 thousands of pages of Scientology literature, all of which the jury was invited
 to consider on the issue of misbranding. Through a Government witness, the
 jury's attention was directed to passages in this literature describing the
 theories of Scientology as they relate to auditing and claiming curative powers
 for that process. We have found that, under Ballard, these theories are not
 properly subject to courtroom evaluation as to truth or falsity. Since the
 jury's general verdict may have rested in whole or in part on a finding that
 this literature was false *1162 **245 or misleading labeling of the E-
 meter, that verdict must be set aside.
  III
  Since our road to this conclusion has been long and complex, we think it
 appropriate to summarize what we have and what we have not held.  We have held
 the following:
  (1) On the basis of the record before us, the Founding Church of Scientology
 has made out a prima facie case that it is a bona fide religion and, since no
 rebuttal has been offered, it must be regarded as a religion for purposes of
 this case.
  (2) On the record before us, a prima facie case exists that auditing is a
 practice of Scientology, and that accounts of auditing integrated into the
 general theory of Scientology are religious doctrines.  Since no rebuttal has
 been offered, we must take the point as proven.
  (3) In view of the constitutional doctrine of United States v. Ballard,
 supra, literature setting forth religious doctrines, and related to an
 instrument in the manner in which the 'auditing' literature here is related to
 the E-meter, cannot be subjected to courtroom evaluation and therefore cannot
 be considered 'labeling' of such an instrument for purposes of the 'false or
 misleading labeling' provisions of the Act.
  On the other hand, the following should be noted:
  (1) We do not hold that the Founding Church is for all legal purposes a
 religion.  Any prima facie case made out for religious status is subject to
 contradiction by a showing that the beliefs asserted to be religious are not
 held in good faith by those asserting them, and that forms of religious
 organization were erected for the sole purpose of cloaking a secular enterprise
 with the legal protections of religion.
  (2) We do not hold that, even if Scientology is a religion, all literature
 published by it is religious doctrine immune from the Act.
  (3) We do not hold that public health laws in general, or the Food, Drug and
 Cosmetic Act in particular, have no application to the activities of religion.
 For instance, it may well be that adulterated foods, drugs or devices used in
 religious practices can be condemned under the Act. [FN54] It may be that a
 drug or device used in religion is subject to condemnation as 'misbranded' if
 its labeling is found to lack, for instance, adequate directions for use, as
 was charged in this case. [FN55]  Our holding prevents only a finding of false
 labeling on the basis of doctrinal religious literature.

      FN54. See 21 U.S.C. ss 331(a), 334(a), 341, 351.

      FN55. See 21 U.S.C. s 352(f)(1).

  Finally, we make no holding concerning the power of Congress to deal generally
 with the making of false claims by religions deemed injurious to the public
 health or welfare.  The Ballard case of course casts doubt on some aspects
 of such a power; but this opinion makes only a narrowing construction, in a
 constitutionally sensitive area, of a statute which has otherwise quite
 properly been construed broadly by the courts.
  Reversed.

  McGOWAN, Circuit Judge (dissenting):
  At the trial in the District Court, the Government put in evidence from which,
 in my view, a jury would be warranted in finding that (1) the practice of the
 asserted religion of Scientology involved the use of mechanical device in
 association with certain publications which represented the device to have
 utility in the prevention, relief, or cure of physical illnesses such as
 cancer, and (2) the device in fact had no such capacity. The majority, as I
 understand it, holds that, because the Government did not go further and prove
 that Scientology was not a bona fide religion, the First Amendments, as
 interpreted in United States v. Ballard, 322 U.S. 78, 64 S.Ct. 882, 88 L.Ed.
 1148 (1944), bars any judicial inquiry whatsoever into whether the device had
 the healing powers claimed for it. Absent such a determination, the
 **246 *1163 majority logically concludes that a judgment that the device
 is misbranded can not be upheld.
  This proceeding did not involve an inquisition into the validity of any
 personal religious beliefs, or the infliction of a punishment upon any person
 for holding or disseminating such beliefs. It was a proceeding against property
 under a Congressional statute aimed at protecting the unsophisticated against
 not only wasting their money, but, more importantly, endangering their lives by
 relying upon misbranded machines. There is, as the majority points out, a well-
 recognized distinction between the good faith holding of a religious belief,
 however bizarre, and unlimited freedom to implement that belief by conduct. I
 do not believe that the Government was required, at least in a statutory in rem
 proceeding of the kind here involved, to show that, over and above the
 misbranding of the device, the religious pretensions of its sponsors were
 fraudulent.
  I respect the difficulties my colleagues have with the Ballard case, but I
 do not think it compels the result they reach. That was a criminal prosecution
 for mail fraud of an individual who proclaimed as a religion the fact that he
 was a "divine messenger" endowed by the appointment of "St. Germain" with the
 power to cure all diseases. The case, at least in its then posture, did not
 involve a practice of giving healing treatments for hire, much less the sale
 and use of devices like the meters with which we are concerned here. To the
 extent that there are expressions in Ballard that may conceivably point in
 the right direction the majority goes, I would limit them to the peculiar facts
 of that case, which, to repeat, did not involve the use of misbranded devices
 and did not result in criminal proceedings against the persons there involved.
  I am not, however, satisfied that the Government officials did not sweep too
 broadly in the seizure. The meters are vulnerable to seizure only if they are
 misbranded, and the misbranding here must be found in separate, but associated,
 pieces of literature. The record before us is such as to support a finding that
 certain items of the Scientology literature did contain healing claims (i.e,
 "Cancer has been eradicated by auditing out conception and mitosis"); and that
 the association of these claims with the meter is sufficiently close as to
 justify the latter's seizure. But this relationship in the case of one or more
 books or pamphlets would not necessarily mean that all the Scientology
 literature is subject to confiscation. Every aspect of the practice or
 preaching of a religion cannot be interfered with simply because one phase of
 it is exposed to legal action.
  The District Court was at some pains to identify those items of literature
 which effected misbranding of the meters, and those which did not. It is not
 clear to me that this separation was uniformly successful in differentiating
 affirmations of faith, on the one hand, from representations as to the curative
 capacities of the meters, on the other. Indeed, it may be that, absent a
 special showing of need beyond that for evidentiary use, the Congressional
 purposes are exhausted by a seizure and permanent retention of the devices
 alone. Certainly, as a practical matter, the objectives of the statute would
 normally be realized thereby, and difficult problems of religion and speech,
 inherent in the wholesale seizure of printed matter, avoided.
  On Appellee's Petition for Rehearing

  PER CURIAM:
  From the Government's petition for rehearing in this case, it appears that the
 following clarifying observations are in order.
                                        I
  [12][13] The Government has correctly inferred from our opinion that a
 showing that 'auditing services have been peddled to the general public on the
 basis of wholly non-religious pseudoscientific representations' would support a
 verdict of false labeling.  133 U.S.App.D.C. at , 409 F.2d at 1161.  We gave
 as further explication of this view a *1164 **247 passage from Weiss,
 Privilege, Posture and Protection: 'Religion' in the Law, 73 YALE L.J. 593,
 604, 605 (1964), and citations to two instructive New York cases, People v.
 Cole, 219 N.Y. 98, 113 N.E. 790, L.R.A.1917C, 816 (1916), and People v.
 Vogelgesang, 221 N.Y. 290, 116 N.E. 977 (1917).  Our basic point is that, in
 order to raise a religious defense to a charge of false statement (here
 misbranding), the person charged with the alleged misrepresentation must have
 explicitly held himself out as making religious, as opposed to medical,
 scientific or otherwise secular, claims.
  The Government now argues that there was sufficient evidence in the record to
 permit the jury to find false labeling on the basis of 'wholly non-religious
 pseudo-scientific representations.'  In the thousands of pages of Scientology
 literature introduced at trial, it finds passages which appear to be based on
 secular rather than religious claims, such as the claim that Scientology is 'a
 precise and exact science, designed for an age of exact sciences,' and that 'no
 other subject on earth except physics and chemistry has had such grueling
 testing (proofs, exact findings).' [FN1]

      FN1. In our main opinion, we have already noted that some claims made on
     behalf of the E-meter and the auditing process, and introduced into
     evidence at trial, had no discernible relation to whatever religious
     content Scientology might have.  See 133 U.S.App.D.C. at , 409 F.2d at
     1158, n. 39 and n. 40.

  [14][15] This argument misconceives the ground upon which we reversed.  We
 did not find insufficient competent evidence to support a verdict, nor did we
 find that all literature submitted to the jury as 'false labeling' was
 religious doctrine.  Rather we found that some of that literature was at least
 prima facie religious doctrine, and that the jury, as it was instructed, [FN2]
 could have found against the E-meter by finding false statements in 'labeling'
 which was at the same time religious doctrine.  See main opinion, 133
 U.S.App.D.C. at , 409 F.2d at 1161.  And, of course, where a jury's general
 verdict may have rested upon grounds improper for First Amendment reasons, a
 reviewing court will not pause to speculate whether the jury's verdict was
 actually reached on other, and permissible, grounds. Stromberg v.
 California, 283 U.S. 359, 367-368, 51 S.Ct. 532, 75 L.Ed. 1117 (1931);
 Gregory v. City of Chicago, 394 U.S. 111, 89 S.Ct. 946, 22 L.Ed.2d 134
 (1969).

      FN2. A tremendous volume of Scientology literature was submitted to the
     jury, and the jury was charged that if the literature 'accompanied' the E-
     meter in the sense described in the main opinion, 133 U.S.App.D.C. at ,
     409 F.2d at 1157 it was labeling. Thus there was neither a winnowing out by
     the judge of the religious material, nor an instruction to the jury that it
     could not find such material to be false labeling.
     It is true that no such sifting process and no such instruction was
     requested by appellants.  Appellants framed their First Amendment point in
     more broadside fashion as described in the main opinion, 133
     U.S.App.D.C. at , 409 F.2d at 1154.  However, even though the narrower
     Ballard point was never raised in the form of objections to evidence or
     suggested fury instructions, we regard it as subsumed in the broader free
     exercise objections actually made. In any case, a denial of First Amendment
     rights is one of those exceptional instances where an appellate court will
     notice error in the charge even where no objection in made at trial.  5 J.
     MOORE, FEDERAL PRACTICE P51.04 (2d ed. 1968); Shokuwan Shimabukuro v.
     Higeyoshi Nagayama, 78 U.S.App.D.C. 271, 273, 140 F.2d 13, 15, cert.
     denied, 322 U.S. 755, 64 S.Ct. 1270, 88 L.Ed. 1584 (1944).

                                         II
  In its petition, the Government finds unclarity in our failure to state
 whether or not a second trial may follow in this case. Of course, it is not
 within our power authoritatively to declare the res judicata effect of our own
 decision.  However, since the basis of our reversal was that the case was
 improperly framed, rather than that the Scientologists' devices and literature
 were absolutely protected, *1165 **248 or that the evidence was
 insufficient, it would appear that a new trial would be in order.
  [16] If a new trial does follow, a further observation may be helpful. We
 have held that as a matter of statutory construction compelled by the
 constitutional doctrine of United States v. Ballard, 322 U.S. 78, 64 S.Ct.
 882, 88 L.Ed. 1148 (1944), religious claims cannot be found 'false labeling'
 within the meaning of the Food, Drug and Cosmetic Act.  Thus it is incumbent on
 the trial judge to rule in the first instance whether each item of alleged
 false labeling makes religious claims and hence cannot be submitted to the jury
 for the factual determinations of whether it is a label for the device in
 question and whether it is false. [FN3]  See Jacobellis v. Ohio, 378 U.S.
 184, 187-188, 84 S.Ct. 1676, 12 L.Ed.2d 793 (1964).

      FN3. With respect to this item-by-item determination, the inquiry should
     be whether that item puts forward its allegedly false claims respecting the
     E-meter or auditing on a 'wholly non-religious' basis.  Of course, this
     does not preclude a finding that an item (book, pamphlet, advertising
     flier) makes out a self-sufficient non-religious claim for Scientology
     services, to which a religious appeal has been merely tacked on.

  [17] Finally, it should be noted that the Government up to this time,
 including its motion for rehearing, has not challenged the bona fides of
 appellants' claim of religion.  In the event of any new trial, as indicated in
 the panel opinion, it would be open to the Government to make this challenge.
 If the challenge is made successfully, the First Amendment question would, of
 course, disappear from this case.  See United States v. Kuch, D. D.C., 288
 F.Supp. 439 (1968).
  Circuit Judge McGOWAN does not join in this clarification of the majority
 opinion, and continues to adhere to his dissenting opinion.

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