United States v. Quaintance

Danuel Quaintance (defendant) and Mary Quaintance (defendant) were founding members of the Church of Cognizance (the church), which taught that marijuana was both a deity and a sacrament. Danuel and Mary claimed to sincerely believe in the tenets of the church and claimed that the possession and consumption of marijuana was essential to their religion. Timothy Kripner, a drug dealer, regularly sold the Quaintances marijuana and small amounts of cocaine. The Quaintances resold the marijuana, referring to the transactions as their business. Mary used the cocaine recreationally. Mary’s brother, Joseph Butts, was arrested during a traffic stop after police found 338 pounds of marijuana in his vehicle. After learning of Butts’s arrest, the Quaintances involved Kripner in organizing a large marijuana transaction to raise $100,000 in bail money for Butts. The night before the transaction, Kripner joined the church by signing a membership pledge. In return, the Quaintances gave Kripner a certificate designating him an authorized courier for the church. The Quaintances did not ask Kripner whether he believed in the tenets of the church, nor did they have him read the pledge. Kripner and the Quaintances were arrested during the next day’s drug transaction, and the Quaintances were indicted for conspiracy and possession with intent to distribute marijuana. The Quaintances moved to dismiss the charges, arguing that, as church members, they were shielded from prosecution by the Religious Freedom Restoration Act (RFRA). After considering extensive evidence, the district court denied the motion to dismiss, finding that the Quaintances’ claimed religious beliefs were not sincerely held.