Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah

In Church of the Lukumi Babalu Aye, Inc., v. City of Hialeah, the Supreme Court held several city ordinances dealing with ritual slaughter of animals to be unconstitutional. The case involved ordinances whose stated purpose was to address the concern of city residents over Santeria religious practices inconsistent with public morals and to declare the city’s commitment to prohibiting such practices. Among other things, the ordinances prohibited the possession, sacrifice, or slaughter of an animal if it was killed in “any type of ritual” and there was an intent to use it for food. The ordinances exempted commercial establishments and certain categories of farmers. The Santeria religion uses animal sacrifice as one of its principal forms of devotion, and members of the religion brought a free exercise claim against the city. Under the Free Exercise Clause, a law that intentionally burdens a specific religious practice must be justified by a compelling governmental interest and narrowly tailored to further that interest. In contrast, a neutral law of general applicability must only have a rational basis. The Court held that the ordinances here were not neutral on their face because they specifically exempted other animal killings and targeted only Santeria animal sacrifices. The Court also found that the ordinances failed to meet the required level of scrutiny; the city’s proffered governmental interests in protecting the public health and preventing cruelty to animals could have been addressed by restrictions that stopped far short of a flat prohibition of all Santeria sacrificial practice. Thus, the ordinances were not narrowly tailored to achieve their stated purpose. Because the ordinances both targeted a specific religion and failed to meet strict scrutiny, the Court concluded that the ordinances violated the Free Exercise Clause of the First Amendment.

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