concurring.
As the Court points out, ante, at 243, invalidation of the 50-percent rule would require the State to shoulder the considerable burden of demonstrating that the Unification Church is not a religious organization if the State persists in its attempt to require the Church to register and file financial statements. The burden is considerable because the record already establishes a prima facie case that the Church is a religious organization,1 and because a strict construction of a statutory exemption for religious organizations is disfavored and may give rise to constitutional questions.2 Justice Rehnquist therefore is plainly wrong when he asserts in dissent that “invalidation of the fifty percent rule will have absolutely no effect on the Association’s obligation to register and report as a charitable organization under the Act.” Post, at 267, n. 3 (emphasis in original). The 50-percent rule has caused appellees a significant injury in fact because it has *257substituted a simple method of imposing registration and reporting requirements for a more burdensome and less certain method of accomplishing that result. I therefore agree with the Court’s conclusion that the appellees have standing to challenge the 50-percent rule in this case.
The more difficult question for me is whether the Court’s policy of avoiding the premature adjudication of constitutional issues3 counsels postponement of any decision on the validity of the 50-percent rule until after the Unification Church’s status as a religious organization within the meaning of the Minnesota statute is finally resolved. My difficulty stems from the fact that the trial and resolution of the statutory issue will certainly generate additional constitutional questions.4 Therefore, it is clear that at least one decision of constitutional moment is inevitable.5 Under these circumstances, it seems to me that reaching the merits is consistent with our “policy of strict necessity in disposing of constitutional issues,” Rescue Army v. Municipal Court, 331 *258U. S. 549, 568. Moreover, a resolution of the question that has been fully considered by the District Court and by the Court of Appeals and that has been fully briefed and argued in this Court is surely consistent with the orderly administration of justice.
I agree with the Court’s resolution of the Establishment Clause issue. Accordingly, I join the Court’s opinion.
The Church has been incorporated in California as a religious corporation and has been treated as a religious organization for tax purposes by the Federal Government and by the State of Minnesota. App. to Juris. Statement A-37. The Church was treated as a religious organization by the State prior to the enactment of the 50-percent rule in 1978. According to the Magistrate, the appellees “have submitted substantial, although not uncontroverted, evidence of the religious nature of the Unification Church and of their solicitations.” Id., at A-23; see id., at A-47.
See Washington Ethical Society v. District of Columbia, 101 U. S. App. D.C. 371, 373, 249 F. 2d 127, 129 (1957) (Burger, J.) (“To construe exemptions so strictly that unorthodox or minority forms of worship would be denied the exemption benefits granted to those conforming to the majority beliefs might well raise constitutional issues”).
See generally Rescue Army v. Municipal Court, 331 U. S. 549, 568-574; Ashwander v. TVA, 297 U. S. 288, 346-348 (Brandeis, J., concurring). I have no reservations about the wisdom or importance of this policy. See, e. g., California ex rel. Cooper v. Mitchell Brothers’ Santa Ana Theater, 454 U. S. 90, 94 (Stevens, J., dissenting); Minnick v. California Dept. of Corrections, 452 U. S. 105; University of California Regents v. Bakke, 438 U. S. 265, 411-412 (opinion of Stevens, J.).
Even if we were to conclude that the constitutional standards for resolving the statutory issue were perfectly clear, there is nevertheless an important interest in avoiding litigation of issues relating to church doctrine. See United States v. Lee, 455 U. S. 252, 263, n. 2 (Stevens, J., concurring in judgment). Cf. NLRB v. Catholic Bishop of Chicago, 440 U. S. 490.
Even if the District Court should find that the Church is not a religious organization, I believe that it is fair to assume that the Church would challenge that conclusion in this Court. I recognize that it is also possible that ultimately we may be required to confront both constitutional problems, but that possibility is present whether we dismiss the appeal pending resolution of the Church’s status or we decide now the validity of the 50-percent rule.