Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993).
Facts
The Church of Lukumi Babalu Aye practied the religion known as Santeria, which uses animal sacrifice as a form of worship. Shortly after the Church announced its establishment in Hialeah, Florida, the city council announced several ordinances which were directed at the Church of Lukumi Babalu Aye. The ordinances included but were not limited to the prohibition of possession of animals for sacrifice or slaughter with the exception for state-licensed activities like those of butcher shops.
Issue
Did the city’s ordinance violate the First Amendment’s Free Exercise Clause?
Holding
The city’s ordinance did violate the First Amendment’s Free Exercise Clause because the ordinances were neither neutral nor generally applicable. Because the ordinance hindered the free exercise of religion, and the ordinances were neither neutral not generally applicable, the ordinance was viewed under a strict scrutiny by the Supreme Court, in which the ordinances had to be justified by a compelling state interest and they had to be narrowly tailored to that interest, and the Supreme Court held that this ordinance was not narrowly tailored to satisfy the interest given by the state, even though the interest by the state was not valid either.
Analysis
The ordinances singled out the activity of the Santeria faith, so they were not generally applicable to everyone. Once the ordinances are not generally applicable to everyone, they receive a strict scrutiny review, in which the state almost always loses. These ordinances suppressed more religious conduct than was necessary to achieve the needs of the state.
Facts
The Church of Lukumi Babalu Aye practied the religion known as Santeria, which uses animal sacrifice as a form of worship. Shortly after the Church announced its establishment in Hialeah, Florida, the city council announced several ordinances which were directed at the Church of Lukumi Babalu Aye. The ordinances included but were not limited to the prohibition of possession of animals for sacrifice or slaughter with the exception for state-licensed activities like those of butcher shops.
Issue
Did the city’s ordinance violate the First Amendment’s Free Exercise Clause?
Holding
The city’s ordinance did violate the First Amendment’s Free Exercise Clause because the ordinances were neither neutral nor generally applicable. Because the ordinance hindered the free exercise of religion, and the ordinances were neither neutral not generally applicable, the ordinance was viewed under a strict scrutiny by the Supreme Court, in which the ordinances had to be justified by a compelling state interest and they had to be narrowly tailored to that interest, and the Supreme Court held that this ordinance was not narrowly tailored to satisfy the interest given by the state, even though the interest by the state was not valid either.
Analysis
The ordinances singled out the activity of the Santeria faith, so they were not generally applicable to everyone. Once the ordinances are not generally applicable to everyone, they receive a strict scrutiny review, in which the state almost always loses. These ordinances suppressed more religious conduct than was necessary to achieve the needs of the state.