CHURCH OF THE LUKUMI BABALU AYE, INC. v. CITY OF HIALEAH

Legal Principle at Issue

Whether city ordinances prohibiting ritual animal sacrifice violated the First Amendment's Free Exercise Clause.

Action

Reversed. Petitioning party received a favorable disposition.

Facts/Syllabus

Petitioner Church of the Lukumi Babalu Aye and its congregants practice the Santeria religion, which employs animal sacrifice as one of its principal forms of devotion. The animals are killed by cutting their carotid arteries, then are cooked and eaten following all Santeria rituals except healing and death rites. 

After the church leased land in respondent city and announced plans to establish a house of worship and other facilities there, the Hialeah City Council held an emergency public session and passed several resolutions and ordinances that noted city residents' "concern" over religious practices inconsistent with public morals, peace, or safety, and declared the city's "commitment" to prohibiting such practices, as well as prohibiting "the killing of animals for food" outside of areas zoned for slaughterhouses, with exemptions for "small numbers of hogs and/or cattle" when exempted by state law. 

Petitioner Church of the Lukumi Babalu Aye and its congregants filed this lawsuit alleging violations of their rights under the Free Exercise Clause of the First Amendment. Although acknowledging that the foregoing ordinances are not religiously neutral, the U.S. District Court for the Southern District of Florida ruled for the city, concluding, among other things, that compelling governmental interests in preventing public health risks and cruelty to animals fully justified the absolute prohibition on ritual sacrifice accomplished by the ordinances, and that an exception to that prohibition for religious conduct would unduly interfere with fulfillment of the governmental interest because any more narrow restrictions would be unenforceable as a result of the Santeria religion's secret nature. The U.S. Court of Appeals for the Eleventh Circuit affirmed.