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