Inc. v. City of Hialeah Church of Lukumi Babalu Aye

The Supreme Court unanimously declared that religious rituals involving animal sacrifices are allowed under First Amendment rights.

Santeria, a Cuban form of voodoo, combines Roman Catholicism and African tribal religions. West African slaves brought the religion to Cuba in the 1500s. The Santeria religion came to the United States via the Caribbean where Yoruba slaves brought it from West Africa. There are an estimated 70,000 followers in South Florida, mainly in the Dade County area, with as many as 800,000 nationwide. Santeria believers worship "orishas," a deity or god identified with a figure from Christianity. When help is sought from these "orishas," a ritual sacrifice is made. Animals sacrificed in Santeria rituals include doves, ducks, chickens, guinea pigs, goats, sheep, and turtles. After Santeria worshipers cut the carotid artery in the animal's neck, they cook and eat the animal except during healing and death rituals.

After the Church of Lukumi Babalu Aye, Inc., leased land in Hialeah, Florida, and said it would build a house of worship there, the Hialeah City Council passed resolutions declaring the city's commitment to prohibiting animal sacrifices. The church filed suit. The suit stated that the rights of church members were being violated. These rights were due members, the church claimed, under the Free Exercise Clause of the First Amendment. Both the district court and the court of appeals ruled in favor of the city of Hialeah.

Although differing in their approaches to this case, the Supreme Court justices unanimously agreed to reverse the lower court rulings. Echoing the High Court's opinion, Supreme Court Justice Kennedy said the laws enacted by the city of Hialeah were null and void. The ordinances were deemed invalid because they suppressed Santeria religious worship. According to Linda Greenhouse of the New York Times, Kennedy said "killings that are no more necessary or humane in almost all other circumstances are unpunished."

The Supreme Court said the laws enacted by the city of Hialeah violated America's commitment to freedom of religion. Although it is a non-profit religious organization, the church was accused of engaging in practices inconsistent with public morals including cruelty to animals. Still, this prohibition of ritual animal sacrifice violated freedom of religion, a constitutional right granted to all U.S. citizens.