## Facts

- A Christian Spiritist church (UDV) uses hoasca tea as sacramental communion; the tea contains DMT, a Schedule I controlled substance under the Controlled Substances Act (CSA).
- In 1999, U.S. Customs officials seized a shipment of hoasca destined for UDV’s New Mexico branch, and federal authorities threatened prosecution.
- UDV and members filed suit under the Religious Freedom Restoration Act (RFRA), seeking declaratory and injunctive relief to prevent CSA enforcement against their sacramental use.
- At the preliminary injunction stage, the government conceded that CSA enforcement would substantially burden a sincere religious exercise.
- The government asserted compelling interests in protecting health and safety, preventing diversion, and complying with the 1971 U.N. Convention on Psychotropic Substances.
- The district court granted a preliminary injunction permitting limited religious use, finding the government had not carried its burden on compelling interest and noting uncertainty about the treaty’s application to hoasca.
- The Tenth Circuit affirmed (panel and en banc), and the Supreme Court granted certiorari.

## Issues

1. Whether RFRA requires the government to justify burdening UDV’s religious use of hoasca by proving a compelling interest and least restrictive means as applied to UDV.
2. Whether the government may satisfy RFRA’s compelling-interest requirement through categorical reliance on the CSA’s Schedule I classifications and a general interest in uniform drug enforcement.
3. Whether asserted interests in health and safety, diversion prevention, and treaty compliance were shown to be compelling on the preliminary-injunction record.

## Decision

- The Supreme Court unanimously affirmed the preliminary injunction (Justice Alito not participating).
- RFRA required the government to satisfy strict scrutiny “to the person,” not by stating broad interests supporting the CSA generally.
- The government did not show, on this record, a compelling interest in barring UDV’s sacramental use of hoasca based on health and safety or diversion concerns.
- The government did not substantiate that a religious exemption for UDV would seriously impair treaty compliance or produce concrete international consequences.
- Because the government failed on compelling interest, it could not justify the substantial burden under RFRA at the preliminary injunction stage.

## Legal Principles

- Under RFRA, once a substantial burden on sincere religious exercise is shown, the government bears the burden to prove that applying the law to the claimant furthers a compelling governmental interest and is the least restrictive means.
- RFRA does not allow the government to meet strict scrutiny by invoking broadly framed interests supporting a generally applicable law; the showing must be claimant-specific.
- Claims that a regulatory regime admits no exceptions are weakened where the regime already contains exemptions (including regulatory accommodations for certain religious uses).
- Generalized assertions about health, safety, diversion, or treaty importance are insufficient without evidence showing how the requested exemption would cause concrete harms in the specific context presented.

## Conclusion

The Court held that RFRA demands rigorous, claimant-specific strict scrutiny and that the government failed, on the preliminary-injunction record, to prove a compelling interest in prohibiting UDV’s sacramental hoasca use under the CSA, leaving the injunction against enforcement in place.


Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006)