1. Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, (1993)
2. Facts: Members of the church practice the Santeria religion which practices animal sacrifices for various occasions. Sometimes the animal is then eaten, sometimes it is not. Outrage in the community over the animal sacrifices led the city council to ban all animal sacrifices which were not for the purpose of food.
3. Procedural Posture: The district court found for the city, and the court of appeals affirmed.
4. Issue: Whether a city may enact laws specifically prohibiting the practice of certain religious rituals when such laws are directed against a particular religion.
5. Holding: No.
6. Reasoning: A law which is specifically directed at regulating the practice of a specific religion will be subjected to “the most rigorous of scrutiny,” unless it is both neutral and generally applicable (Smith). The law here is very underinclusive, because the city’s stated purpose of promoting public health would be better served if they also regulated disposal of animals killed by hunters, as well as disposal of restaurant food, and the killing of pests. Since the city failed to enact such other laws, its purpose could not be compelling.
