Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal
546 U.S. 418 (2006)
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Rule of Law:
Under the Religious Freedom Restoration Act of 1993, the government must demonstrate a compelling interest in applying a generally applicable law to a specific religious practice and show it is the least restrictive means; merely asserting a broad interest in the uniform application of the law is insufficient.
Facts:
- O Centro Espirita Beneficente Uniao do Vegetal (UDV) is a religious sect with approximately 130 members in the United States.
- A central tenet of the UDV's faith involves receiving communion by drinking a sacramental tea known as hoasca.
- Hoasca is brewed from two plants, one of which contains dimethyltryptamine (DMT), a hallucinogen.
- DMT is classified as a Schedule I controlled substance under the federal Controlled Substances Act (CSA), making its possession and use illegal.
- The government concedes that the UDV's use of hoasca is a sincere exercise of religion.
- In 1999, U.S. Customs inspectors intercepted a shipment of hoasca intended for the American UDV branch.
- Following the seizure, the federal government threatened the UDV with prosecution for its use of the sacramental tea.
Procedural Posture:
- The UDV sued the Attorney General and other federal officials in the U.S. District Court for the District of New Mexico.
- The UDV filed a motion for a preliminary injunction to prevent the government from enforcing the Controlled Substances Act against its use of hoasca, arguing the enforcement violated RFRA.
- The District Court granted the preliminary injunction, finding that the government failed to demonstrate a compelling interest in prohibiting the UDV's practice.
- The Government, as appellant, appealed the injunction to the U.S. Court of Appeals for the Tenth Circuit.
- A three-judge panel of the Tenth Circuit affirmed the District Court's grant of the injunction.
- The Tenth Circuit, sitting en banc, also affirmed the District Court's decision, with the UDV as appellee.
- The Government petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the uniform application of the Controlled Substances Act to prohibit the sacramental use of hoasca by the O Centro Espirita Beneficente Uniao do Vegetal violate the Religious Freedom Restoration Act of 1993?
Opinions:
Majority - Chief Justice Roberts
Yes. The application of the Controlled Substances Act to prohibit the UDV's religious use of hoasca violates the Religious Freedom Restoration Act (RFRA) because the government failed to carry its burden of demonstrating a compelling interest. RFRA requires a case-by-case, particularized inquiry, not reliance on broad, categorical prohibitions. The government cannot simply assert a general interest in the uniform enforcement of the CSA; it must show a compelling interest in prohibiting the UDV's specific religious practice. The government failed to demonstrate that the UDV's use of hoasca presented significant health risks or a substantial risk of diversion to recreational users, as the evidence on these points was found to be 'in equipoise' by the District Court. Furthermore, the government's argument for absolute uniformity is fatally undermined by the long-standing statutory and regulatory exemption allowing members of the Native American Church to use peyote, another Schedule I substance, for religious purposes. If an exception for a Schedule I substance is permissible for one religion, the government cannot claim that the general findings underlying the CSA preclude any consideration of a similar, narrowly tailored exception for another.
Analysis:
This decision significantly strengthens the power of the Religious Freedom Restoration Act by rejecting the government's attempt to create a de facto categorical exception for drug laws. It solidifies that RFRA mandates a strict, individualized, and fact-specific inquiry, requiring the government to prove actual harm from a specific religious practice rather than relying on the general purposes of a statute. The ruling empowers minority religions by ensuring their practices receive a case-by-case assessment, and it establishes that existing exemptions to a law can critically weaken the government's claim of a compelling interest in uniform enforcement.
