Church of the Lukumi Babalu Aye v. City of Hialeah

Church of the Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993), is a landmark decision of the United States Supreme Court.

The Santeria church in Hialeah, Florida practiced animal sacrifice as part of its religious rituals. In response to the church’s plans to open a facility, the city passed ordinances prohibiting the unnecessary killing of animals. The church argued the ordinances targeted their religious practices in violation of the Free Exercise Clause.

Significance

Justice Kennedy’s unanimous opinion struck down the Hialeah ordinances. Applying Smith, the Court held that laws targeting religious conduct are not neutral or generally applicable and must satisfy strict scrutiny. The ordinances were invalid because they were enacted specifically to suppress Santeria practice — they were ‘gerrymandered’ with so many exceptions that only Santeria was affected. The decision reaffirmed that while neutral laws need not accommodate religion, laws specifically targeting religion are subject to the most rigorous constitutional scrutiny.

Category

US Federal Case Law