## Facts

- Plaintiffs, including animal-welfare advocates and individuals asserting church–state concerns, sued federal officials responsible for administering the Humane Slaughter Act.
- The Humane Slaughter Act declared a federal policy that livestock slaughter and related handling be conducted only by “humane methods.”
- The Act defined “humane methods” to include (1) pre-slaughter stunning to render animals insensible to pain and (2) slaughter performed under “the ritual requirements of the Jewish faith or any other religious faith” prescribing a method causing loss of consciousness by anemia of the brain from simultaneous severance of the carotid arteries.
- The Act created an administrative committee and required at least one member to be knowledgeable about humane slaughter “including religious slaughter,” and it contemplated federal implementation resources.
- Plaintiffs sought declaratory and injunctive relief, alleging the Act’s recognition of ritual slaughter as “humane” violated the First Amendment’s Establishment and Free Exercise Clauses.
- A three-judge district court was convened, and the parties filed cross-motions for summary judgment; defendants also moved to dismiss.

## Issues

1. Whether plaintiffs had standing to challenge the Act’s ritual-slaughter provisions.
2. Whether treating religious ritual slaughter as a “humane” method and incorporating it into a federal regulatory scheme violates the Establishment Clause.
3. Whether those provisions violate the Free Exercise Clause by involving the government in religious practice or burdening objectors.

## Decision

- The court proceeded to the merits and resolved the case on summary judgment.
- The court held the ritual-slaughter provisions did not violate the Establishment Clause because the statute served a secular animal-welfare purpose, did not primarily advance religion, and did not create excessive government entanglement with religion.
- The court held the provisions did not violate the Free Exercise Clause because they did not compel religious conduct and instead permitted religious adherents to comply with both religious requirements and federal humane-slaughter standards.
- Summary judgment was granted for defendants; plaintiffs’ requests for declaratory and injunctive relief were denied.

## Legal Principles

- A statute with a secular purpose may accommodate religious practice without violating the Establishment Clause if its primary effect is not to advance or inhibit religion and it does not require detailed, continuing governmental supervision of religious matters.
- Government recognition of a religious practice as satisfying a secular regulatory standard is permissible when it does not impose religious doctrine or mandate religious conduct.
- Limited consultation with or inclusion of religious-slaughter knowledge in administering a secular regulatory program does not, by itself, constitute excessive entanglement.
- A Free Exercise violation generally requires coercion or a meaningful burden on the claimant’s religious exercise; allowing religiously compliant conduct within a neutral regulatory framework is typically protective rather than restrictive of free exercise.

## Conclusion

The court upheld the Humane Slaughter Act’s inclusion of ritual slaughter as an approved “humane method,” characterizing it as a secular animal-welfare scheme that permissibly accommodates religious slaughter without establishing religion, excessively entangling government with religion, or burdening free exercise.


Jones v. Butz, 374 F. Supp. 1284 (S.D.N.Y. 1974)