Gonzales v. O Centro Espírita Beneficente União Do Vegetal
Headline: Court upholds preliminary injunction blocking federal ban on a small religious group's sacramental tea that contains a banned drug, finding the Government failed to show a compelling reason under RFRA.
Holding: The Court affirmed a preliminary injunction preventing enforcement of the drug ban against a 130-member religious group’s sacramental tea because the Government did not prove a compelling, least-restrictive interest under RFRA at the injunction stage.
- Allows the small religious group to use their sacramental tea while the case continues.
- Requires the Government to show specific evidence before banning religious drug use.
- Confirms courts can grant individualized religious exemptions under RFRA.
Summary
Background
A small religious sect from the Amazon with about 130 U.S. members (the UDV) uses a sacramental tea called hoasca that contains DMT, a drug listed as illegal in Schedule I. U.S. customs seized a shipment and threatened prosecution. The UDV sued federal law enforcement and the Attorney General under the Religious Freedom Restoration Act (RFRA), which requires the Government to justify burdens on religion by a compelling interest and the least restrictive means. The district court granted a preliminary injunction and the Tenth Circuit affirmed before the case reached this Court.
Reasoning
The key question was whether the Government had shown a compelling, narrowly tailored reason to bar the UDV’s sacramental use of hoasca at the preliminary stage. The Government conceded that the practice was a sincere religious exercise. The Court held that under RFRA the Government bears the burden to show a compelling interest as applied to this specific group, and that evidentiary ties or “equipoise” on health, diversion, or international concerns did not meet that burden at the injunction stage. The Court also said the drug’s Schedule I listing and general treaty obligations do not automatically foreclose individualized exemptions, noting the existing peyote exception.
Real world impact
The ruling lets the UDV continue its sacramental use under the injunction while the case proceeds, and requires the Government to produce specific evidence to justify denying religious accommodation. It endorses individualized court review under RFRA and makes clear this was an interim decision that could change on a full merits hearing.
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