ABSTRACT
Santeria is a religion that combines elements of Roman Catholicism with the traditional African religion that was brought to the United States by slaves. Some Santerian rituals include sacrifice of animals. In 1987 a group of Santerians announced plans to open a house of worship in Hialeah, Florida. In response, the city council in an emergency meeting adopted a set of ordinances that forbade the ritual killing of animals and specified certain exceptions to that rule. These exceptions substantially narrowed the persons affected by the legislation to the Santerians. Both the US District Court and the Eleventh Circuit Court of Appeals found no violation of the Free Exercise Clause of the First Amendment, which prohibits restrictions on the free exercise of religion. Justice Scalia in a concurring opinion took issue with the way Justice Kennedy used the terms "neutrality" and "general applicability." He also thought the Court should not have considered the subjective motivation of the city council members.
