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Church of the Lukumi Babalu Aye v. City of Hialeah

508 U.S. 520 (1993)


Facts of the Case:

The Church of the Lukumi Babalu Aye leased land in Hialeah, Florida and planned to establish a church, school, and cultural center there. They would bring their practice of Santeria, which included the ritual sacrifice of animals, into the area. Animal sacrifice is practiced at birth, marriage, and death rites. It is also used for curing the sick and other annual ceremonies. As a response to this, the city of Hialeah passed several ordinances prohibiting animal sacrifice. The Church claimed that this violated their First Amendment rights to freely exercise their religion.



Decision:

The Court unanimously invalidated the city ordinances that outlawed animal sacrifices.


Majority Opinion: (Justice Kennedy)

In order to avoid having to meet the compelling interest requirement, a law must be both neutral and generally applicable. "Official action that targets religious conduct for distinctive treatment cannot be shielded by mere compliance with the requirement of facial neutrality." The suppression of Santeria was the central purpose of the law as noted by the use of terms such as 'ritual' and sacrifice' in the statute. Also, a resolution was passed that spoke harshly against "practices which are inconsistent with public morals, peace of safety," and "reiterated" the city's commitment to prohibit "any and all [such] acts of any and all religious groups." If the city's primary purpose was to protect against cruelty to animals, a less restrictive ordinance could have been passed. The city claimed to have two interests in passing the legislation: protecting the public health and preventing cruelty to animals. However, the laws that were passed did not go far enough to meet these interests. They limited the laws to cover only the types of practices that would occur during Santeria.



Significance:

This decision reaffirmed the standard set forth in Smith to determine whether a law violates the freedom of individuals' to exercise their religions. In order to not have to meet the compelling interest standard a law must be generally applicable and neutral.



  

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