Church of Lukumi Babalu Aye v. City of Hialeah
Encyclopedia
Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993), was a case in which the Supreme Court of the United States
held 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." as unconstitutional. 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 there. 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 United States district court
for the Southern District of Florida
, 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, the nature of the case was held to mandate a standard of strict scrutiny
: state action 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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held an ordinance passed in Hialeah, Florida
Hialeah, Florida
Hialeah is a city in Miami-Dade County, Florida, United States. As of the 2000 census, the city population was 226,419. As of 2009, the population estimate by the U. S...
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." as unconstitutional. The law was enacted soon after the city council of Hialeah learned that the Church of Lukumi Babalu Aye
Church of Lukumi Babalu Aye
Church of Lukumi Babalu Aye is a Santería church in Hialeah, Florida.CLBA was founded and incorporated in 1974 by Oba Ernesto Pichardo and his associates. In the 1980s, the church decided to begin public services in Hialeah. The city of Hialeah responded by passing four ordinances which outlawed...
, which practiced Santería
Santería
Santería is a syncretic religion of West African and Caribbean origin influenced by Roman Catholic Christianity, also known as Regla de Ocha, La Regla Lucumi, or Lukumi. Its liturgical language, a dialect of Yoruba, is also known as Lucumi....
, was planning on locating there. Santeria is a religion practiced in the Americas by the descendants of Africans; many of its rituals involve animal sacrifice
Animal sacrifice
Animal sacrifice is the ritual killing of an animal as part of a religion. It is practised by many religions as a means of appeasing a god or gods or changing the course of nature...
. The church filed a lawsuit in United States district court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
for the Southern District of Florida
United States District Court for the Southern District of Florida
The United States District Court for the Southern District of Florida is the federal United States district court with jurisdiction over the southern part of the state of Florida....
, seeking for the Hialeah ordinance to be declared unconstitutional.
Adhering to Employment Division v. Smith
Employment Division v. Smith
Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872 , is a United States Supreme Court case that determined that the state could deny unemployment benefits to a person fired for violating a state prohibition on the use of peyote, even though the use of the drug was...
, 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, the nature of the case was held to mandate a standard of strict scrutiny
Strict scrutiny
Strict scrutiny is the most stringent standard of judicial review used by United States courts. It is part of the hierarchy of standards that courts use to weigh the government's interest against a constitutional right or principle. The lesser standards are rational basis review and exacting or...
: state action 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.
See also
- List of United States Supreme Court cases, volume 508
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
Further reading
- Palmie, Stephan. “Whose centre, whose margin? Notes towards an archaeology of US Supreme Court Case 91-948, 1993 Church of the Lukumi vs. City of Hialeah, South Florida,” in Inside and outside the law: anthropological studies of authority and ambiguity, ed. Olivia Harris (Routledge, 1996).