Church of Lukumi Babalu Aye v. City of Hialeah
Case Date: 07/09/1993
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Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993),[1] was a case in which the Supreme Court of the United States held an ordinance passed in Hialeah, Florida that forbade the "unnecessar[y]" killing of "an animal in a public or private ritual or ceremony not for the primary purpose of food consumption." as unconstitutional. The law was enacted soon after the city council of Hialeah learned that the Church of Lukumi Babalu Aye, which practiced Santería, was planning on locating there. Santeria is a religion practiced in the Americas by the descendants of Africans; many of its rituals involve animal sacrifice. The church filed a lawsuit in United States district court for the Southern District of Florida, seeking for the Hialeah ordinance to be declared unconstitutional.
Adhering to Employment Division v. Smith, the lower courts deemed the law to have a legitimate and rational government purpose and therefore upheld the enactment. The Supreme Court, however, held that the ordinances were neither neutral nor generally applicable: rather, they applied exclusively to the church. Because the law was targeted at Santería, the Court held, it was not subject to an undemanding rational basis test. Rather, the nature of the case was held to mandate a standard of strict scrutiny: state action had to be justified by a compelling governmental interest, and be narrowly tailored to advance that interest. Because the ordinance suppressed more religious conduct than was necessary to achieve its stated ends, it was deemed unconstitutional.
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