ABSTRACT
The Northwest Indian Cemetery Protective Association, together with individual Indians, environmental organizations, and the state of California, filed suit in federal district court challenging both the road construction and the logging. Justice Sandra Day O'Connor, writing for the majority, accepted the assertion that the Indians' beliefs were sincere and that the Forest Service's actions would have a devastating effect on the practice of their religion. Justice O'Connor noted, however, that these projects would not "prohibit" the Indians' religious practices. Justice William J. Brennan Jr., writing for the dissenters, discussed the fact that Indian religious beliefs and understandings were fundamentally different from those of the Judeo-Christian tradition. In particular, he emphasized that a "pervasive feature" of the Indian lifestyle was "the individual's relationship with the natural world." The site-specific nature of Indian religious activities arose from a perception that the land was "a sacred living being." .
