Merced v. Euless (2009)
Protecting the right to freely worship at home, the Becket Fund represented a Santeria priest in Texas who—because of discriminatory state action—was unable to perform certain religious rituals in his own home.
In an important ruling under the Texas Religious Freedom Restoration Act, a unanimous panel of the U.S. Court of Appeals for the Fifth Circuit agreed with the Becket Fund and found in favor of the Santeria priest. The court held that the city ordinances forbidding the slaughter of certain animals prevented the Santeria priest from performing ceremonies essential to his faith, causing a substantial burden on his religious exercise.
Although the government argued two compelling interests (public health and animal treatment) justified that burden, the court disagreed, finding that the Santeria priest had conducted these rituals for 16 years without incident. Even if the interests were compelling, the court reasoned that the regulatory method the government chose was not the least restrictive means. With this win, the right to worship freely in one’s own home has been affirmed.
Additional Resources
Law Reviews
Douglas Laycock, The Religious Exemption Debate
Christopher C. Lund, Religious Liberty After Gonzales: A Look at State RFRAs
