Church of the Lukumai Babalu Aye Inc. v. Hialeah (1993)

Overview

• Case Citation: Church of the Lukumai Babalu Aye Inc. v. Hialeah, 508 U.S. 520 (1993)
• Issue: Whether ordinances prohibiting animal sacrifice in religious rituals violate the Free Exercise Clause of the First Amendment.
• Holding: The Supreme Court held that the Hialeah ordinances were unconstitutional as they violated the Free Exercise Clause.

Background

• Santeria Religion:
  • Afro-American religion, syncretism of Roman Catholicism and Yoruba religion.
  • Practices include animal sacrifice, particularly chickens, which are then consumed by participants.
  • Faced historic persecution and practiced in secret.
• Church of Lukumai Babalu Aye Inc.:
  • Founded in 1973 by Ernesto Pichardo in Florida.
  • In 1987, the church leased a property in Hialeah for open practice.

Legal Proceedings

• Hialeah City Actions:
  • Held emergency public session criticizing Santeria practices.
  • Passed ordinances criminalizing animal sacrifices except for kosher and other exempted practices such as hunting.
• Court Decisions:
  • Initial lawsuits by the church were dismissed at the district level.
  • The Court of Appeals upheld the district court's decision.
  • Supreme Court granted certiorari.

Supreme Court Decision

• Majority Opinion:
  • Written by Justice Anthony Kennedy.
  • Found the ordinances violated the Free Exercise Clause.
  • Concluded the laws were not neutral or generally applicable and were designed to suppress religious practices.
  • Applied strict scrutiny, which the ordinances failed to pass.
• Concurrences:
  • Justice Scalia's Concurrence: Supported Smith decision; criticized the use of legislative intent.
  • Justice Souter's Concurrence: Suggested re-examining the Smith rule.
  • Justice Blackmun's Concurrence: Criticized Smith; noted that a sincere law protecting animals from cruelty might be different.

Implications and Subsequent Developments

• Religious Freedom and Animal Sacrifice:
  • Case reaffirmed protection of religious practices under the First Amendment.
• Merced v. Casson (2009):
  • A similar case where a Santeria priest challenged Texas ordinances prohibiting animal slaughter.
  • Court ruled in favor of the priest, emphasizing religious freedom protections.