Church of Lukumi Babalu Aye v. City of Hialeah

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Church of Lukumi Babalu Aye, Inc. and Ernesto Pichardo v. City of Hialeah

Argued November 4, 1992
Decided June 11, 1993

Full case name:	Church of Lukumi Babalu Aye, Inc. and Ernesto Pichardo v. City of Hialeah

Citations:	508 U.S. 520
Prior history:	Church of Lukumi v. City of Hialeah, 936 F.2d 586 (11th Cir. 1991)

Holding

That the laws in question were enacted contrary to free exercise principles and are void

Court membership

Chief Justice: William Rehnquist
Associate Justices: Byron White, Harry Blackmun, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas

Case opinions

Majority by: Kennedy (Parts I, III, IV)
Joined by: Rehnquist, White, Stevens, Scalia, Souter, Thomas
Majority by: Kennedy (II-B)
Joined by: Rehnquist, White, Stevens, Scalia, Thomas
Majority by: Kennedy (Parts II-A-1, II-A-3)
Joined by: Rehnquist, Stevens, Scalia, Thomas
Concurrence by: Kennedy (Part II-A-2)
Joined by: Stevens
Concurrence by: Scalia (in part and judgment)
Joined by: Rehnquist, Souter
Concurrence by: Blackmun (in judgment)
Joined by: O'Connor

Laws applied

U.S. Const. Free Exercise Clause, 42 U.S.C. § 1983, City of Hialeah Ordinances 87-52, 87-71, 87-72

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 unconstitutional 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." 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. 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.

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, it 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.