Background Information:
The Church of the Lukumi Babalu Aye was leasing land in Hialeah, Florida and planning to establish a church, school, and cultural center there.
Their religion was Santeria, which originated in Cuba in the 19th century and includes the ritual sacrifice of animals. In Santeria, ritual animal sacrifice is practiced at birth, marriage, and death rites. It is also used for curing the sick and other annual ceremonies.
In response to this, the city of Hialeah passed several ordinances specifically prohibiting animal sacrifice of any sort. The Church regarded these laws as an attempt to violate their First Amendment rights to freely exercise their religion.
Court Decision:
In 1993, the Court unanimously invalidated city ordinances outlawing animal sacrifices.
In his majority opinion, Justice Kennedy noted that to avoid having to meet the compelling interest requirement, a law must be both neutral and generally applicable:
Official action that targets religious conduct for distinctive treatment cannot be shielded by mere compliance with the requirement of facial neutrality.
But Kennedy found that the laws in question were not of general applicability:
Although the practice of animal sacrifice may seem abhorrent to some, 'religious beliefs need not be acceptable, logical, consistent, or comprehensible to others in order to merit First Amendment protection.'
That the laws were designed for the express purpose of suppressing Santeria was demonstrated by the use of terms such as "ritual" and "sacrifice" in the statute. Furthermore, a resolution was also passed by the city which spoke badly against "practices which are inconsistent with public morals, peace and safety," and "reiterated" the city's commitment to prohibit "any and all [such] acts of any and all religious groups."
The city tried to claim that they had two secular interests in passing the legislation: protecting the public health and preventing cruelty to animals. Unfortunately, the laws that were passed did not go very far to meet those goals. For example, they limited the laws to cover just the types of practices that would (coincidentally?) occur during Santeria practices.
Significance:
This decision suported the standard set forth in Smith to determine whether a law violates the freedom of individuals' to exercise their religions. In order to not have to meet the compelling interest standard a law must be generally applicable and neutral. In particular, the government cannot pass laws which unfairly burden a minority religion, religious group, or religious doctrine.
"Margaret Ramirez, 74, lived in an apartment in Manhattan on 164th Street. She recently died in an automobile accident, and police came to her apartment to notify the next of kin. They found her son Michael Grahales, 54, who became "extremely unstable" on learning what happened to his mother and is now locked up in a mental hospital. Police also found what appeared to be a den of Palo Mayombe sorcery, complete with statues in every corner, skulls, chunks of flesh rotting in pots, and boarded-up windows. What most shocked police was a perfectly preserved newborn girl floating in a jar of formaldehyde. Since the son claims to know nothing about the body, police are left to speculate. "We haven't ruled out homicide, but we're hoping the baby was stillborn," says Lt. George Menig. "It's too creepy to think that it could have been a human sacrifice.""
(Laura Italiano and Maria Malave, Black-Magic Woman, New York Post, Aug. 28, 2000.)
If you say "Hey," followed by the above highlighted passage aloud, you get, "Hey, look a' me, Babaloo!"
Was that grim lot somehow inspired by that all time great tune, "Bobaloo's Wedding Day"?