Church Of The Lukumi Babalu Aye v. City Of Hialeah

508 U.S. 520 (1993)

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Nature of the Case

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Facts

The Church's announcement of plans to open a Santeria church in Hialeah prompted the city council to hold an emergency public session on June 9, 1987. Notes, minutes, and taped excerpts evidence significant hostility by residents and city officials toward the Santeria religion. The city council adopted Resolution 87-66, which noted the 'concern' expressed by residents of the city 'that certain religions may propose to engage in practices which are inconsistent with public morals, peace or safety,' and declared that 'the City reiterates its commitment to a prohibition against any and all acts of . . . religious groups which are inconsistent with public morals, peace or safety.' In September 1987, the city council adopted three substantive ordinances addressing the issue of religious animal sacrifice. All ordinances and resolutions passed the city council by unanimous vote. Violations were punishable by fines not exceeding $500 or imprisonment not exceeding 60 days, or both. The ordinances prohibited ritual killing even if followed by consumption, and prohibited slaughter outside of areas zoned for slaughterhouse use. There were exemptions for slaughtering by licensed establishments of animals specifically raised for food purposes, and kosher slaughter. The Church filed this action pursuant to 42 U.S.C. alleging violations of petitioners' rights under the Free Exercise Clause. The District Court proceeded to determine whether the governmental interests underlying the ordinances were compelling and, if so, to balance the 'governmental and religious interests.' The court found that animal sacrifices present a substantial health risk, both to participants and the general public. The court found emotional injury to children who witness the sacrifice of animals. The court found compelling the city's interest in protecting animals from cruel and unnecessary killing. The court determined that the method of killing used in Santeria sacrifice was 'unreliable and not humane and that the animals, before being sacrificed, are often kept in conditions that produce a great deal of fear and stress in the animal.' The District Court found compelling the city's interest in restricting the slaughter or sacrifice of animals to areas zoned for slaughterhouse use. Balancing the competing governmental and religious interests, the District Court concluded the compelling governmental interests 'fully justify the absolute prohibition on ritual sacrifice' accomplished by the ordinances. The Court of Appeals affirmed.