Thursday, November 14, 2013

Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah case brief

Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah case brief summary
508 U.S. 520 (1993)

Petitioners, a church and its president, appealed a decision of the United States Court of Appeals for the Eleventh Circuit which affirmed a finding in favor of respondent city in an action filed pursuant to 42 U.S.C.S. § 1983 alleging violations of petitioners' rights under U.S. Constitutional, Amendment I.

Petitioners, church and its president, applied for and received licensing, inspection and zoning approvals to establish a church including a ritual of animal sacrifice from respondent city. In response, an emergency public session of respondent's city council was held and ordinances were passed which prohibited animal sacrifice. Petitioners filed an action pursuant to 42 U.S.C.S. § 1983 alleging that their rights under the Free Exercise Clause, U.S. Constitutional, Amendment I, were violated. The trial court ruled for respondent finding no constitutional violations. The appellate court affirmed.


  • The United States Supreme Court reversed the judgment, holding that the ordinances were unconstitutional. 
  • It found that they were not neutral nor of general application, therefore it applied a strict scrutiny analysis. 
  • The Court determined that the governmental interests were not compelling, the ordinances were not drawn in narrow terms, and were both overbroad and underinclusive in substantial respects.
Decision for respondent city reversed where the Court held that ordinances prohibiting animal sacrifice violated the Free Exercise Clause because they were not neutral nor of general application, were both overbroad and underinclusive, were not drawn in narrow terms and were not passed to protect a compelling government interest.

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