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Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal

Supreme Court of the United States · 2006 · Constitutional Law

Constitutional LawReligious Freedom Restoration ActFree ExerciseControlled Substances ActPreliminary InjunctionsRFRAstrict scrutinycompelling interest

Facts

UDV is a small religious sect whose American branch has about 130 members and uses hoasca, a sacramental tea, as communion. Hoasca contains DMT, a hallucinogen listed in Schedule I of the Controlled Substances Act, and federal customs officials seized a shipment and threatened prosecution. The Government conceded that banning the tea would substantially burden a sincere exercise of religion, but argued that enforcement was justified by compelling interests in health and safety, preventing diversion, and complying with an international treaty. After hearing evidence, the District Court found the evidence on health risks and diversion to be evenly balanced and entered a preliminary injunction allowing limited importation and use under specified conditions.

Issue

Whether, under RFRA, the Government showed a compelling interest in applying the Controlled Substances Act to bar UDV's sacramental use of hoasca at the preliminary injunction stage. More specifically, the question was whether general interests in uniform enforcement of the Act, Schedule I classification, and treaty compliance were enough without a particularized showing directed to this claimant and practice.

Rule

RFRA bars the Federal Government from substantially burdening a person's sincere religious exercise unless the Government demonstrates that applying that burden to the particular person furthers a compelling governmental interest and is the least restrictive means of doing so. The RFRA inquiry is claimant-specific and practice-specific; broad assertions about the importance of a generally applicable law or its uniform enforcement do not alone satisfy the Government's burden, and at the preliminary injunction stage the burdens of proof track the burdens at trial.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A small religious fellowship in Santa Fe uses a tea containing a federally scheduled hallucinogen during monthly worship. Federal officials concede the practice is sincere and that banning the tea would substantially burden the fellowship's exercise of religion, but at the preliminary-injunction hearing the evidence on health risks and diversion is evenly balanced.

Who is most likely to prevail on the motion for a preliminary injunction under RFRA?

Explanation. RFRA places the burden on the government to demonstrate that applying the burden to the particular claimant furthers a compelling interest and is the least restrictive means. At the preliminary-injunction stage, those burdens track the burdens at trial. So where the government concedes sincerity, religious exercise, and substantial burden, and the evidence on its asserted compelling interests is in equipoise, the government has failed to carry its burden. (Derived from Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal (2006).)