Consumer WonLandmark Casediscrimination

Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006)

546 U.S. 418
Supreme Court
Decided: November 1, 2005
No. 04

Primary Holding

The Federal Government may not substantially burden a person's exercise of religion under the Religious Freedom Restoration Act unless it demonstrates that the application of the burden is in furtherance of a compelling government interest and is the least restrictive means of furthering that interest.

View original source (justia)
AI Summary - What This Case Means For You

In the case of Gonzales v. O Centro Espírita Beneficente União do Vegetal, a religious group wanted to use a special tea containing a hallucinogen as part of their rituals, but the government tried to stop them because the tea's main ingredient was illegal. The Supreme Court ruled that the government couldn't interfere with their religious practice unless it could show that stopping them was absolutely necessary and that there were no other ways to achieve that goal. This case is important because it protects people's rights to practice their religion freely, especially when it involves unique beliefs or rituals, and it reminds consumers that they have the right to challenge government actions that might unfairly restrict their religious freedoms.

AI-generated plain-language summary to help you understand this case

Facts of the Case

In Gonzales v. O Centro Espírita Beneficente União do Vegetal, the underlying dispute arose from the practices of a religious sect that originated in the Amazon Rainforest, which includes the consumption of a sacramental tea containing a hallucinogen regulated under the Controlled Substances Act. The federal government acknowledged that the sect's use of the tea was a sincere exercise of religion but sought to prohibit its American branch from using the tea, citing the Controlled Substances Act. In response, the sect filed a lawsuit to prevent the enforcement of this prohibition and sought a preliminary injunction. The procedural history of the case began when the sect moved for a preliminary injunction against the government’s enforcement of the ban. The District Court granted this injunction, and the Court of Appeals upheld the decision. Subsequently, the government petitioned the Supreme Court for certiorari to review the case, arguing that it had a compelling interest in uniformly applying the Controlled Substances Act and that no exceptions should be made for the sect's religious practices. The relevant background context includes the enactment of the Religious Freedom Restoration Act (RFRA) in 1993, which was a legislative response to the Supreme Court's decision in Employment Division v. Smith. RFRA prohibits the federal government from substantially burdening a person's exercise of religion unless it can demonstrate that such a burden serves a compelling interest and is the least restrictive means of achieving that interest. This case tested the application of RFRA in the context of the federal government’s regulation of controlled substances and the protection of religious practices.

Question Presented

Whether the Government's enforcement of the Controlled Substances Act against a religious sect's sacramental use of a hallucinogen constitutes a substantial burden on the sect's exercise of religion under the Religious Freedom Restoration Act, and whether the Government can demonstrate that such enforcement serves a compelling interest by the least restrictive means.

Conclusion

The judgment of the United States Court of Appeals for the Tenth Circuit is affirmed, and the case is remanded for further proceedings consistent with this opinion.

Quick Facts
Court
Supreme Court
Decision Date
November 1, 2005
Jurisdiction
federal
Case Type
landmark
Majority Author
Roberts
Damages Awarded
N/A
Data Quality
high
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