City of Boerne v. Flores

In 1993, Congress enacted the Religious Freedom Restoration Act (RFRA) in an express attempt to overturn the United States Supreme Court’s decision in Employment Div., Dept. of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990). In Smith, Oregon’s prohibition on peyote use in Native American religious practice was upheld because the Oregon state law was one of general applicability. The RFRA prohibits the government from substantially burdening a person’s free exercise of religion, even if the burden is derived from a law of general applicability. A person’s free exercise of religion can only be substantially burdened if the government can show that its actions were necessary to achieve a compelling government interest and were the least restrictive means of furthering that interest. Archbishop Flores (plaintiff) brought suit against the City of Boerne (defendant) under the RFRA after the City of Boerne denied his church’s application for a building permit to make necessary expansions to its current building. The city denied the church’s permit pursuant to a city ordinance that prevented expansions and alterations of structures designated as historic landmarks or existing within historic districts. The church’s permit was denied because the City’s Historic Landmark Commission determined the church was located in a historic district. Archbishop Flores sought relief under the RFRA in the District Court for the Western District of Texas. The district court held that the RFRA was unconstitutional, but the Fifth Circuit Court of Appeals reversed. The United States Supreme Court granted certiorari.