Lyng v. Northwest Indian Cemetery Protection Association

The Court's ruling in Lyng has been criticized for its unwillingness to consider the effects of government programs or policies while focusing only on the form the government action takes. In a Cornell Law Review article, J. Brett Pritchard stated:

The scope of the constitutional guarantee of free exercise of religion now depends on the Court's tenuous distinction between regulations that coercively impact religious practices and regulations that only make it more difficult for an individual to practice his beliefs.