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
- 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.
- 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.
- 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.