Facts
-
Church of the Lukumi Babalu Aye and its priest planned to establish a Santería house of worship in Hialeah, Florida; Santería religious exercise includes animal sacrifice, with participants often cooking and eating the animals.
-
After the Church announced its plans, the city council held an emergency meeting at which officials made statements expressing hostility toward Santería and its practices.
-
The City adopted multiple measures aimed at animal killing associated with “sacrifice” or “ritual,” including:
- A resolution expressing a commitment to prohibit religious practices viewed as inconsistent with public morals, peace, or safety.
- Ordinances defining “sacrifice” in terms of killing animals in a ritual or ceremony “not for the primary purpose of food consumption,” and prohibiting possession, sacrifice, or slaughter connected to ritual use.
- A slaughter ordinance restricting slaughter to properly zoned districts, while allowing exceptions and exemptions.
-
The combined ordinances effectively prohibited Santería animal sacrifice while leaving many secular animal killings largely permitted (including hunting, fishing, pest control, food production, and specified slaughter exceptions).
-
The Church and its priest sued under 42 U.S.C. § 1983, alleging the ordinances violated the First Amendment’s Free Exercise Clause.
-
The federal district court granted summary judgment to the City; the Eleventh Circuit affirmed.
Issues
- Whether the ordinances were neutral and generally applicable regulations that only incidentally burdened religious exercise.
- If not neutral or not generally applicable, whether the ordinances satisfied strict scrutiny by serving a compelling governmental interest through narrowly tailored means.
- Whether the City impermissibly targeted Santería religious conduct by prohibiting ritual animal sacrifice while permitting comparable secular animal killings.
Decision
- The Supreme Court reversed and held the ordinances unconstitutional under the Free Exercise Clause.
- The Court concluded the ordinances were neither neutral nor generally applicable because they were designed and applied to suppress Santería animal sacrifice.
- Because neutrality and general applicability were lacking, strict scrutiny applied.
- The City’s asserted interests (public health and preventing animal cruelty) did not justify the ordinances as drafted because the scheme was underinclusive and not narrowly tailored.
Legal Principles
- A law that is neutral and generally applicable may be applied to religious conduct even if it incidentally burdens religious exercise.
- If a law is not neutral or not generally applicable, it must satisfy strict scrutiny: it must further a compelling governmental interest and be narrowly tailored to achieve that interest.
- Neutrality is assessed by examining the law’s text, operation, historical background, and contemporaneous statements by decisionmakers; a law is not neutral if its object is to restrict religious practice.
- General applicability is violated when a law selectively burdens religious conduct while permitting comparable secular conduct that threatens the government’s asserted interests to a similar or greater degree.
- Underinclusive regulatory schemes and categorical exemptions for secular conduct can show that asserted interests are being pursued only against religiously motivated conduct, defeating strict scrutiny.
Conclusion
The Court invalidated Hialeah’s ordinances because they targeted Santería animal sacrifice through definitions and exemptions that singled out religious conduct, rendering the laws neither neutral nor generally applicable and unable to survive strict scrutiny under the Free Exercise Clause.