Gonzales v. O Centro Espírita Beneficente União Do Vegetal
The Supreme Court ruled that the government could not stop a small Brazil-based Christian church from using its hallucinogenic sacramental tea, because officials failed to show a compelling reason to ban this particular religious use even though the drug is generally illegal.
The decision reinforces that a federal law protecting religious exercise requires the government to justify burdening a specific religious practice with real evidence, not just broad claims about a law's general importance.
How it got here: A federal trial court granted a preliminary injunction letting the church use the tea; the Tenth Circuit affirmed en banc; the government asked the Supreme Court to review.
The Case in Depth
What happened
A Brazil-based Christian sect called O Centro Espirita Beneficente Uniao do Vegetal has about 130 American members who drink hoasca, a tea containing a hallucinogen regulated as a Schedule I drug, as a central part of their communion. After U.S. Customs seized a shipment and threatened prosecution, the church sued, arguing that banning its sacramental tea use violated a federal law protecting religious exercise.
The question before the Court
Could the federal government ban a small religious group from drinking its sacramental tea containing a controlled hallucinogen, without proving it had a compelling reason to do so?
Why it matters
The ruling means the government cannot rely solely on a drug's general danger classification to override a specific group's religious practice; officials must present actual evidence tailored to that practice. This strengthens protections for minority religious practices nationwide and sets a higher bar for federal agencies defending blanket bans against religious exemption claims.
What changes now
The case is sent back for further proceedings, including a full trial on the merits of the church's claims. The preliminary injunction allowing the church to import and use the tea under specific safeguards remains in effect while that litigation continues. The ruling itself is a decision on the preliminary injunction, not a final resolution of the whole lawsuit, though its legal reasoning about the compelling interest test applies going forward.
What this does not decide
The Court did not finally decide whether the church will win at trial, only that the government failed to show a compelling interest at the preliminary injunction stage. It also left open whether other situations might justify uniform enforcement without religious exceptions.
How the Court got there
The legal reasoning, step by step
- The Court applied the Religious Freedom Restoration Act's compelling interest test, under which the government must show that burdening a specific person's religious practice serves a compelling interest and uses the least restrictive means available.
- Because the government had already conceded that banning the tea substantially burdened a sincere religious practice, the church had effectively shown it was likely to win, shifting the evidentiary weight to the government at the preliminary injunction stage just as it would at trial.
- The Court rejected the government's argument that a general finding that Schedule I drugs are dangerous is enough by itself, holding that RFRA requires focusing on the harm from this particular use by this particular group, not broad, categorical assertions.
- The Court noted that the government already allows a similar exception for Native American religious use of peyote, another Schedule I substance, without evidence that this exception undermined enforcement, undercutting the claim that no exceptions are possible.
- The Court also found the government's asserted interest in complying with an international drug treaty insufficient, because officials offered only general statements about the value of honoring treaties rather than specific evidence about the consequences of exempting this small group.
Doctrinal impact
Cases affected by this decision
Distinguishes Employment Div., Dept. of Human Resources of Ore. v. Smith (494 U. S. 872)
Smith's rejection of case-by-case religious exemptions under the Constitution does not control this statutory RFRA case.
Reaffirms Ashcroft v. American Civil Liberties Union (542 U. S. 656)
Reaffirmed that a defendant's trial burden also applies at the preliminary injunction stage.
Reaffirms Sherbert v. Verner (374 U. S. 398)
Relied on as the source of RFRA's focused, case-by-case compelling interest test.
Distinguishes United States v. Lee (455 U. S. 252)
Distinguished because the government there proved specific administrative harm, unlike here.