ABSTRACT
Congress enacted the Religious Freedom Restoration Act of 1993 (RFRA) in response to the 1990 US Supreme Court decision of Employment Division, Department of Human Resources of Oregon v. Smith, 494 US 872 (1990). RFRA reversed the Supreme Court's decision in Smith and provided an exemption to any law that had the effect of substantially burdening religious exercise. The archdiocese sued under RFRA, arguing that the denial of the permit placed a substantial burden on meeting its religious needs. The US Supreme Court found in favor of Oregon and ruled that the antidrug law applied to the terminated employees, despite the fact that they used peyote in a religious manner. The Court found that the scope of RFRA, which potentially touched every law passed on any subject, was out of proportion to the evidence of interference with religious exercise that Congress considered in enacting RFRA.
