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Case Summary for Church of the Lukumi Babalu Aye, Inc. v. Hialeah
Date Decided: June 11, 1993
Issue: Freedom of Religion -- Whether a city may constitutionally enact ordinances that are designed to prohibit certain religious practices.
Vote: No, 9-0
Facts: Many Cuban refugees in South Florida practice the Santeria religion, which combines a traditional African religion with elements of Roman Catholicism. An important ritual in Santeria is animal sacrifice. When a Santeria church announced plans to open in Hialeah, Florida, the city council enacted three ordinances designed to prohibit any animal sacrifices by the church. The church sued the city and city officials, claiming that the ordinances violated its rights under the Free Exercise Clause of the First Amendment. The district court found that the ordinances were not directed solely at the church and that the prohibition of ritual sacrifice was constitutional. The Court of Appeals for the Eleventh Circuit affirmed in a one-paragraph opinion.
Legal Principles at Issue: The Free Exercise Clause of the First Amendment provides that the government may not enact laws that suppress religious beliefs. McDaniel v. Paty, 435 U.S. 618 (1978). Moreover, a law that is designed to restrict religious practices will be upheld only if it is justified by a compelling interest and is narrowly tailored to advance that interest. A law that is neutral towards religion and of general applicability, however, need not be justified by a compelling governmental interest, even if the law incidentally burdens a particular religious practice. Employment Div., Dept. of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990).
Legal Basis for Decision: The Court found that the ordinances were not neutral and that they were directed solely at the Santeria church. The Court then held that the ordinances were not narrowly tailored because they advanced the proferred governmental interests -- the health risk of animal sacrifices to participants, the emotional injury to children who witnessed the sacrifices, the need to protect animals from unnecessary killings, and the need to restrict the slaughter of animals to areas zoned for slaughterhouse use -- only when the conduct was motivated by religious beliefs.
This Case is Important Because: The Court demonstrated its willingness to look critically at purportedly neutral restrictions to determine their effect on controversial religious practices. The number of concurring opinions, however, indicates that the Court still has not reached a consensus as to how Free Exercise cases should be evaluated.
Quotable: "The Free Exercise Clause commits government itself to religious tolerance, and upon even slight suspicion that proposals for state intervention stem from animosity to religion or distrust of its practices, all officials must pause to remember their own high duty to the Constitution and to the rights it secures."
Writing for the Majority: Justice Kennedy
Voting with the Majority: Chief Justice Rehnquist, Justices White, Stevens, Scalia, Thomas, Souter, Blackmun, and O'Connor (Chief Justice Rehnquist and Justice Scalia, concurring in part and concurring in the judgment) (Justice Souter concurring in part and concurring in the judgment) (Justices Blackmun and O'Connor, concurring in the judgment)
Writing for the Dissent: N/A
Voting with the Dissent: N/A
Not Voting: N/A
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