Church Of Lukumi Babalu Aye V. City Of Hialeah

At issue in Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993), a United States Supreme Court case, was an ordinance passed in Hialeah, Florida that forbade the "unnecessary" killing of "an animal in a public or private ritual or ceremony not for the primary purpose of food consumption." The law was enacted soon after the city council of Hialeah learned that the Church of Lukumi Babalu Aye, which practiced Santeria, was planning on locating in the city. 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 federal court, seeking for the Hialeah ordinance to be declared unconstitutional. Following 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 because the law was targeted at this religion it is not subject to an undemanding "rational basis" test: rather, it must be justified by a compelling governmental interest, and must be narrowly tailored to advance that interest. Because the ordinance did not meet this standard, it was unconstitutional.

 

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