Church of the Lukumi Babalu Aye v. Hialeah
"Church of the Lukumi Babalu Aye v. Hialeah" is a significant Supreme Court case addressing the intersection of religious freedom and animal rights. The case arose in the late 1980s when the Hialeah, Florida, city council enacted ordinances that effectively banned animal sacrifices, specifically targeting practices associated with the Santería religion, which involves such rituals for spiritual healing and ceremonial purposes. In response, the Church of the Lukumi Babalu Aye contested these ordinances, asserting that they violated the First and Fourteenth Amendments, which protect the free exercise of religion.
Initially upheld by lower courts, the case was ultimately brought before the Supreme Court, which ruled unanimously in favor of the church. The Court held that laws explicitly aimed at restricting religious practices must meet a stringent standard of justification by a compelling state interest and utilize the least restrictive means to achieve that interest. This ruling underscored the importance of protecting minority religious practices against legislative actions that lack secular justification, particularly when those practices are unpopular. The decision highlighted the delicate balance between maintaining animal welfare and respecting religious diversity, emphasizing that laws must not directly burden specific religious rituals without valid secular reasons.
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Church of the Lukumi Babalu Aye v. Hialeah
Believers of the Santería religion perform animal sacrifices for the curing of the sick and, at certain ceremonies, cook and eat the animal’s flesh. In 1987, the Hialeah, Florida, city council responded to a public outcry against a Santería church by passing a series of ordinances that had the effect of outlawing the killing of animals in religious rituals.
Church attorneys attacked the ordinances as a violation of freedom of religion under the First and Fourteenth Amendments. After federal district and appellate courts upheld the ordinances, the church appealed the case to the Supreme Court, where the justices voted 9 to 0 that the ordinances were unconstitutional. The Court ruled that when a law is plainly directed at restricting a religious practice, it must satisfy two tests: justification by a compelling state interest and use of the least restrictive means to promote that interest. However, Justice Anthony Kennedy also reaffirmed Employment Division, Dept. of Human Resources of the State of Oregon et al. v. Smith (1990), a ruling that a neutral law of general applicability would not be required to pass the two tests when the law burdened religion incidentally. General and neutral laws might proscribe cruelty to animals or require the safe disposal of animal wastes; however, Hialeah could not place a direct burden on unpopular religious rituals without a secular justification.
Bibliography
"Church of Lukumi Babalu Aye, Inc. v. City of Hialeah." Legal Information Institute. Cornell U Law School, n.d. Web. 9 Apr. 2015.
Finkelman, Paul. The Supreme Court: Controversies, Cases, and Characters from John Jay to John Roberts. Santa Barbara: ABC-CLIO, 2014. Print.
Harris, James F. The Serpentine Wall: The Winding Boundary between Church and State in the United States. New Brunswick: Transaction, 2013. Print.