Brief Fact Summary. Congress’ enactment of the Religious Freedom Restoration Act (RFRA) of 1993 was held by the Supreme Court of the United States (Supreme Court) to be an excessive use of power under Section:5 of the Fourteenth Amendment of the United States Constitution (Constitution).
Synopsis of Rule of Law. While preventive rules are sometimes appropriate remedial measures, there must be a congruence between the means used and the ends sought to be achieved. The appropriateness of remedial measures must be considered in light of the evil presented.
Facts. A decision by local zoning authorities to deny a church a building permit was challenged under the RFRA. The Act’s stated purposes are: “(1) to restore the compelling interest test and to guarantee its application in all cases where the free exercise of religion is substantially burdened; (2) to provide a claim or defense to persons whose religious exercise is substantially burdened by government.” The Act forbids the government from “substantially burdening” a person’s exercise of religion unless the government can demonstrate that the burden “(1) is in furtherance of a compelling state interest; and (2) is the least restrictive means of furthering that state interest.” Specifically, this case calls into question the authority of Congress to enact the RFRA.
Issue. Whether the RFRA is a proper exercise of Congress’ Section:5 power to “enforce” by “appropriate legislation” the constitutional guarantee that no state shall deprive any person of “life, liberty, or property without the due process of law” nor deny any person “equal protection of the laws?”