Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal

Gonzales v. O Centro Espirita Beneficente União do Vegetal, 546 U.S. 418 (2006)^[1], is a case decided by the United States Supreme Court involving the Federal Government's seizure of a sacramental tea, containing a Schedule I substance, from a New Mexican branch of the Brazilian church União do Vegetal (UDV). The church sued, claiming the seizure was illegal, and sought to ensure future importation of the tea for religious use. The United States District Court for New Mexico agreed and issued a preliminary injunction under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. § 2000bb. The Government appealed to the Appeals Court for the Tenth Circuit which upheld the previous ruling, which was then appealed to the Supreme Court.

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The Supreme Court heard oral arguments November 1, 2005, and issued its opinion February 21, 2006, finding that the Government failed to meet its burden under RFRA that barring the substance served a compelling government interest. The court also disagreed with the government's central argument that the uniform application of the Controlled Substances Act (CSA) does not allow for exceptions for the substance in this case, as Native Americans are given exceptions to use peyote, another Schedule I substance.

Background of the case

In 1999, U. S. Customs agents seized over 30 gallons of hoasca (ayahuasca) tea which was shipped to the Santa Fe, New Mexico branch of the Brazil-based UDV; ayahuasca contains dimethyltryptamine, a Schedule I substance. While no charges were filed, the United States chapter, led by Seagram heir Jeffrey Bronfman, filed suit claiming that the seizure was an illegal violation of the church members' rights; they claimed their usage was permitted under the 1993 Religious Freedom Restoration Act, a law passed by Congress in direct response to the Employment Division v. Smith (1990) ruling, in which the Court ruled that unemployment benefits could be denied to two Native Americans fired for using Peyote.

In filing suit, the UDV sought a preliminary injunction preventing the federal government from barring their usage of hoasca; the New Mexico district court ruled in favor of the UDV; on appeal by the government, the Tenth Circuit Appeals Court upheld the previous ruling, which was then appealed to the Supreme Court.

As it worked its way through the appellate courts, the Supreme Court lifted a stay in December 2004 thereby permitting the church to use hoasca for their Christmas services.

The Court's decision

Chief Justice John Roberts wrote the opinion for a unanimous Court of eight justices. Newly confirmed Justice Samuel Alito took no part in the consideration or decision of the case as he was not on the Court when the case was argued. The Court found that the government was unable to detail the State's compelling interest in barring religious usage of Hoasca under the strict scrutiny that the RFRA demands of such regulations.

Disagreeing with the District Court, the Supreme Court found that Hoasca is covered under the 1971 United Nations Convention on Psychotropic Substances, which is implemented by the Controlled Substance Act. However, because the government had failed to submit any evidence on the international consequences of granting an exemption to CSA enforcement allowing UDV to practice its religion, the Court ruled that it had failed to meet its burden on this point. The Supreme Court ruled that the government failed to demonstrate a compelling interest in applying the Controlled Substances Act to the UDV’s sacramental use of the tea.

The ruling upheld a preliminary injunction allowing the church to use the tea pending a lower court trial on a permanent injunction, during which the government will have the opportunity to present further evidence consistent with the Supreme Court's ruling.

States are not directly impacted by the Court's ruling due to the Court ruling in City of Boerne v. Flores, 521 U.S. 507 (1997), where it held that Congress exceeded its power to enforce the Fourteenth Amendment in passing the RFRA.

See also

• List of United States Supreme Court cases, volume 546