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Church of the Lukumi Babalu Aye v. City of Hialeah

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Constitutional Law Keyed to Sullivan

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Citation. 508 U.S. 520,113 S. Ct. 2217,124 L. Ed. 2d 472,1993 U.S.

Brief Fact Summary. City ordinances passed to prevent animal sacrifices in connection with Santeria rituals were held invalid by the Supreme Court of the United States (Supreme Court).

Synopsis of Rule of Law. A law burdening religious practice that is not neutral or not of general application must undergo the most rigorous of scrutiny. Where the government restricts only conduct protected by the First Amendment of the United States Constitution (Constitution) and fails to enact feasible measures to restrict other conduct producing substantial harm or alleged harm of the same sort, the interest given in justification of the restriction is not compelling.


Facts. Santeria is a religion that fused African religion with Roman Catholicism. It called for animal sacrifices to keep the orishas (spirits) alive. In response to the news that a Santeria church was to be built in the city of Hialeah, the city council held an emergency public session in order to pass three laws outlawing any animal sacrifices in connection with Santeria rituals. All ordinances were passed by a unanimous vote. Violations were punishable by fines not exceeding $500.00 or imprisonment no longer than sixty days, or both.

Issue. Whether the city ordinances violate the Free Exercise Clause of the Constitution?

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