The First Amendment to the United States Constitution protects the free exercise of religion. However, the Supreme Court has never specified what counts as religious and what does not. In some of the earlier cases, the Court sometimes implied that it employed some unstated criteria to make the relevant determination. However, more recently, the Court has rejected that it will examine the content of beliefs to determine whether they are religious as long as those beliefs are not utterly bizarre. Instead, the Court will examine other factors such as the role that the beliefs play in the sincere believer’s life. While free exercise guarantees only protect religious beliefs and practices, the Court has impliedly made what counts as religious for constitutional purposes so broad that many beliefs and practices (not traditionally viewed as religious) may nonetheless qualify for protection under free exercise guarantees.