Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal

The UDV (plaintiff), a religious sect using a hallucinogenic sacramental tea, sued Attorney General Gonzales (defendant) after Customs seized a shipment, seeking a preliminary injunction against enforcing the Controlled Substances Act pending trial on their RFRA claim. The government conceded the CSA's application substantially burdened the UDV's sincere religious exercise but argued this was the least restrictive means of advancing compelling interests in member health and safety, preventing diversion, and complying with an international treaty; after hearing competing expert evidence, the district court found the evidence on health/safety and diversion risks "in equipoise" and rejected the treaty argument, granting the injunction. The Tenth Circuit affirmed, and the government argued on appeal that the UDV, not the government, should have borne the burden of disproving the compelling interest at the preliminary-injunction stage.