Berkley Center

In re Bruce Young was one of the first cases to uphold the Religious Freedom Restoration Act (RFRA) as applied to the federal government after City of Boerne v. Flores invalidated it as applied to the states. Congress enacted RFRA to make it easier for plaintiffs to challenge government conduct that burdened the exercise of religion by requiring that the government justify such conduct with a compelling interest, and show that the conduct was the least restrictive means in furthering that interest. In this case, the United States Court of Appeals for the Eight Circuit considered Young’s challenge to the bankruptcy court’s determination that his tithes to his church were avoidable transfers that could be recovered and distributed to his creditors in a bankruptcy proceeding. Young argued that recovery of the contributions violated RFRA because it substantially burdened his free exercise of religion and was not in furtherance of a compelling governmental interest. The bankruptcy trustee responded that RFRA was unconstitutional. The court upheld RFRA as applied to the federal government in bankruptcy cases because, under Article I of the Constitution, Congress has the power to make all laws necessary and proper for regulation of the bankruptcy system. Further, the court agreed that there was no compelling interest for recovering Young’s donations to his church. Thus, the court held that RFRA prohibited the bankruptcy trustee from recovering Young’s donations.