City of Boerne v. Flores
United States Supreme Court
521 U.S. 507 (1997)
Congress enacted RFRA specifically to override Employment Division v. Smith, which had upheld a generally applicable state drug law against a religious-exercise challenge; RFRA required the government to justify any substantial burden on religious exercise, even from neutral, generally applicable laws, using strict scrutiny. Archbishop Flores (plaintiff) sued the City of Boerne (defendant) under RFRA after the city denied his church a building permit under a historic-preservation ordinance restricting alterations to buildings in a historic district. The district court held RFRA unconstitutional, the Fifth Circuit reversed, and the Supreme Court granted certiorari.
Whether, in exercising its remedial and preventive power to enforce a constitutional right under Section 5 of the Fourteenth Amendment, Congress may enact only legislation that uses congruent and proportional means to achieve that legislative purpose.