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69-437: The Religious Freedom Restoration Act of 1993 , Pub. L. No. 103-141, 107 Stat. 1488 (November 16, 1993), codified at 42 U.S.C.   § 2000bb through 42 U.S.C.   § 2000bb-4 (also known as RFRA ), is a 1993 United States federal law that "ensures that interests in religious freedom are protected." The bill was introduced by Congressman Chuck Schumer ( D - NY ) on March 11, 1993. A companion bill

138-543: A claim or defense in lawsuits "regardless of whether the government is a party to the proceeding." While proponents said the bill was intended to protect the right of business owners to refuse services based on religious objections and was a direct response to the New Mexico Supreme Court's ruling in Elane Photography v. Willock against a business that religiously objected to accommodating

207-730: A matter of conscience and faith are not to be superimposed on the statutory schemes which are binding on others in that activity. Granting an exemption from social security taxes to an employer operates to impose the employer's religious faith on the employees. Mandates courts use the following when considering religious liberty cases: Legislatures of 28 states have enacted versions of the Religious Freedom Restoration Act: An additional 9 states have RFRA-like provisions that were provided by state court decisions rather than via legislation: Some states have had legislation withdrawn or vetoed. Arizona's bill SB 1062

276-602: A message that the state is bigoted." Supporters of the bill included two conservative groups, the Center for Arizona Policy and the Alliance Defending Freedom , both of whom worked on the bill. The Arizona Catholic Conference had called on its congregants to support the bill. Three lawmakers who initially voted for the bill, including Senate Majority Whip Adam Driggs, had encouraged Governor Brewer to veto it. The National Football League stated that it

345-440: A person's exercise of religion, unless the burden is the least restrictive means of furthering a "compelling government interest". SB 1062 would have revised it by expanding the definition of person in the article from "a religious assembly or institution" to also include "any individual, association, partnership, corporation, church," "estate, trust, foundation or other legal entity", and would have allowed for religious-freedom as

414-503: A rehab clinic after testing positive for mescaline , the main psychoactive compound in the peyote cactus, which they had used in a religious ceremony. The Smith decision outraged the public. Groups representing all points on the political spectrum (from the liberal American Civil Liberties Union to the conservative Traditional Values Coalition ) and a wide variety of religions (i.e. the Christian Legal Society ,

483-604: A religious ceremony, stating that the federal government must show a compelling state interest in restricting religious conduct. Post- Smith , many members of the Native American Church still had issues using peyote in their ceremonies. This led to the Religious Freedom Act Amendments in 1994 , which state, "the use, possession, or transportation of peyote by an Indian for bona fide traditional ceremony purposes in connection with

552-401: A religiously neutral law can burden a religion just as much as one that was intended to interfere with religion; therefore the act states that the "Government shall not substantially burden a person's exercise of religion even if the burden results from a rule of general applicability." The federal RFRA provided an exception if two conditions are both met. First, the burden must be necessary for

621-455: A same-sex wedding, critics, a few media outlets, and opponents argued that the intent was to allow businesses to refuse to serve the LGBT community, specifically in the cases of same-sex couples . Critics said that the bill would have allowed any business to discriminate against any group of people for any religious reason. Businesses, civil rights groups, and gay rights groups had opposed

690-566: A similar position in a brief for the case submitted before the U.S. Supreme Court handed down its decision in Burwell v. Hobby Lobby , writing that "Congress could not have anticipated, and did not intend, such a broad and unprecedented expansion of RFRA. ... The test Congress reinstated through RFRA ... extended free-exercise rights only to individuals and to religious, non-profit organizations. No Supreme Court precedent had extended free-exercise rights to secular, for-profit corporations." Following

759-510: Is a 1993 United States federal law that "ensures that interests in religious freedom are protected." The bill was introduced by Congressman Chuck Schumer ( D – NY ) on March 11, 1993. A companion bill was introduced in the Senate by Ted Kennedy ( D - MA ) the same day. A unanimous U.S. House and a nearly unanimous U.S. Senate —three senators voted against passage —passed the bill, and President Bill Clinton signed it into law. The law

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828-728: Is a core norm of the First Amendment." The Supreme Court for example stated in Estate of Thornton v. Caldor, Inc. (1985): "The First Amendment ... gives no one the right to insist that, in pursuit of their own interests others must conform their conduct to his own religious necessities.'" Relying on that statement they point that the U.S. Constitution allows special exemptions for religious actors, but only when they don't work to impose costs on others. Insisting on "the constitutional importance of avoiding burdenshifting to third parties when considering accommodations for religion" they point out

897-424: Is compelling when it is more than routine and does more than simply improve government efficiency. A compelling interest relates directly to core constitutional issues. The second condition is that the rule must be the least restrictive way in which to further the government interest. The Free Exercise Clause of the First Amendment states that Congress shall not pass laws prohibiting the free exercise of religion. In

966-565: Is the least restrictive means of pursuing a compelling government interest. While RFRA initially applied to both state and federal laws, its application to state governments was held unconstitutional by the Supreme Court in the City of Boerne v. Flores decision in 1997, which ruled that the RFRA is not a proper exercise of Congress's enforcement power . However, it continues to be applied to

1035-809: The American Jewish Congress , the Baptist Joint Committee for Religious Liberty , and the National Association of Evangelicals ) agreed that the law required reform, and recommended reinstating the Sherbert Test . In response, Congress passed the RFRA, unanimously in the House and 97-to-3 in the Senate . The bill was then signed by U.S. President Bill Clinton . The RFRA applies "to all Federal law, and

1104-552: The Burwell v. Hobby Lobby decision, many states have proposed expanding state RFRA laws to include for-profit corporations, including in Arizona where SB 1062 passed by in Arizona but vetoed by Jan Brewer in 2014. Indiana SB 101 defines a "person" as "a partnership, a limited liability company, a corporation, a company, a firm, a society, a joint-stock company, an unincorporated association" or another entity driven by religious belief that can sue and be sued, "regardless of whether

1173-538: The First Amendment should prevent the U.S. Forest Service from constructing a road through sacred land used in ceremonies and prayer. The Supreme Court disagreed, arguing that only government coercion or punishment for religious beliefs would violate the First Amendment. In Smith , the Court upheld the state of Oregon 's refusal to grant unemployment benefits to two Native Americans fired from their jobs at

1242-705: The Georgia State Senate and the Georgia House of Representatives passed a religious freedom bill. On March 28, Georgia's governor, Nathan Deal , vetoed the bill after multiple Hollywood figures, as well as the Walt Disney Company threatened to pull future productions from the state if the bill became law. Many other companies had also been opposed to the bill, including the National Football League , Salesforce ,

1311-505: The Hobby Lobby decision. Several law professors from Indiana stated that State Religious Freedom Restoration Acts like " Indiana SB 101 " are in conflict with the U.S. Supreme Court's Free Exercise Clause jurisprudence under that "neither the government nor the law may accommodate religious belief by lifting burdens on religious actors if doing so shifts those burdens to third parties. [...] The Supreme Court has consistently held that

1380-648: The Sherbert Test , which was set forth by Sherbert v. Verner , and Wisconsin v. Yoder , mandating that strict scrutiny be used when determining whether the Free Exercise Clause of the First Amendment to the United States Constitution , guaranteeing religious freedom, has been violated. In the federal Religious Freedom Restoration Act, which usually serves as a model for state RFRAs, Congress states in its findings that

1449-496: The "Save Chick-fil-A" law, given that the fast-food chain Chick-fil-A has been criticized for its donations to anti-LGBT causes. Religious Freedom Restoration Act of 1993 The Religious Freedom Restoration Act of 1993 , Pub. L. No. 103-141, 107 Stat. 1488 (November 16, 1993), codified at 42 U.S.C.   § 2000bb through 42 U.S.C.   § 2000bb-4 (also known as RFRA , pronounced "rifra" ),

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1518-399: The "furtherance of a compelling government interest". Under strict scrutiny, a government interest is compelling when it is more than routine and does more than simply improve government efficiency. A compelling interest relates directly with core constitutional issues. The second condition is that the rule must be the least restrictive way in which to further the government interest. In 2014,

1587-627: The 1960s, the Supreme Court interpreted this as banning laws that burdened a person's exercise of religion (e.g. Sherbert v. Verner , 374 U.S. 398 (1963); Wisconsin v. Yoder , 406 U.S. 205 (1972)). But in the 1980s the Court began to allow legislation that incidentally prohibited religiously mandatory activities as long as the ban was "generally applicable" to all citizens. But "generally applicable" bans frequently conflicted with Native American religious practice . Often, government projects required acquisition of sacred grounds necessary for Native American rituals. Ritual peyote use infringed on

1656-515: The 1990s that worked for the passage of RFRA. The second was from Douglas Laycock , who was an author of RFRA. His address traced the legal history of RFRA and discussed its impact on current debates, including the contraception mandate and same-sex marriage laws. The panel discussions covered the history and impact of RFRA, religious freedom and the contraceptive mandate of the Affordable Care Act , and current and future challenges to

1725-624: The 20th anniversary of the Religious Freedom Restoration Act. "Restored or Endangered? The State of the Free Exercise of Religion in America" featured three panel discussions and two keynote addresses. The first keynote address was from Oliver S. Thomas, the former general counsel of the Baptist Joint Committee for Religious Liberty and the chair of the diverse "Coalition for the Free Exercise of Religion" in

1794-477: The Arizona law that SB 1062 proposed to amend. The Supreme Court upheld the constitutionality of the federal RFRA as applied to federal statutes in Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal in 2006. Arizona lawmakers were concerned about a 2013 New Mexico Supreme Court ruling that weakened its state's RFRA, which was passed as a religious exemption to its own public accommodation law prohibiting

1863-562: The Coca-Cola Company , and Unilever . In March 2015, Gov. Mike Pence signed the Religious Freedom Restoration Act , allowing business owners who object to same-sex couples on religious grounds to opt out of providing them services. In April 2016, Phil Bryant , the governor of Mississippi , signed into law a bill that protects people from government punishment if they refuse to serve others on

1932-522: The Federal income tax system, irrespective of religious belief, is a compelling governmental interest." In the case of Miller v. Commissioner , the taxpayers objected to the use of social security numbers, arguing that such numbers related to the " mark of the beast " from the Bible. In its decision, the U.S. Court discussed the applicability of the Religious Freedom Restoration Act of 1993, but ruled against

2001-509: The RFRA can be applied to "internal operations of the federal government." RFRA, in conjunction with President Bill Clinton 's executive order in 1996, provided more security for sacred sites for Native American religious rites. As of 1996, the year before the RFRA was found unconstitutional as applied to states, 337 cases had cited RFRA in its three-year time range. It was also found that Jewish, Muslim, and Native American religions, which make up only three percent of religious membership in

2070-616: The RFRA with respect to its applicability to States (but not Federally), stating that Congress had stepped beyond its power of enforcement provided in the Fourteenth Amendment . In response to the Boerne ruling, Congress passed the Religious Land Use and Institutionalized Persons Act (RLUIPA) in 2000, which grants special privileges to religious land owners. A number of states have passed state RFRAs , applying

2139-427: The RFRA, federally-funded healthcare insurers and providers must be allowed to deny medical treatment and coverage on the basis of the sex, gender identity or termination of pregnancy of the person who is requesting the services, even if the services are medically necessary. Transgender people may be turned down even if the healthcare service they need is not related to their being transgender. In 1997, part of this act

State Religious Freedom Restoration Acts - Misplaced Pages Continue

2208-483: The Religious Freedom Restoration Act as a vehicle for fighting back against the legalization of same-sex marriage." Despite being of intense interest to religious groups, state RFRAs have never been successfully used to defend discrimination against gay people—and have rarely been used at all. The New York Times noted in March 2015 that state RFRAs became so controversial is due to their timing, context and substance following

2277-523: The Supreme Court on March 25, 2014. In a 5–4 decision, Justice Alito declared that nothing about the language of RFRA or the manner in which Congress passed it implied the statutory protections conferred therein were confined solely within the bounds of First Amendment case law as it existed pre- Smith . A day-long symposium was held at the Newseum in Washington, D.C., on Nov. 7, 2013, to commemorate

2346-459: The Texas House passed a version of Senate Bill 1978 which prohibits the government from penalizing anyone for “membership in, affiliation with, or contribution...to a religious organization.” The bill was expected to pass the Senate again rapidly and to be signed by the governor. On June 10, 2019 the governor signed the bill officially into law and it took effect immediately. Some have called it

2415-587: The U.S. , make up 18 percent of the cases involving the free exercise of religion. The Religious Freedom Restoration Act was a cornerstone for tribes challenging the National Forest Service 's plans to permit upgrades to Arizona's Snowbowl ski resort . Six tribes were involved, including the Navajo , Hopi , Havasupai , and Hualapai . The tribes objected on religious grounds to the plans to use reclaimed water . They felt that this risked infecting

2484-554: The United States Supreme Court handed down a landmark decision in Burwell v. Hobby Lobby Stores, Inc. recognizing a for-profit corporation's claim of religious belief. Nineteen members of Congress who signed the original RFRA stated in a submission to the Supreme Court that they "could not have anticipated, and did not intend, such a broad and unprecedented expansion of RFRA". The United States government stated

2553-536: The United States, who had been placed on the No Fly List by FBI agents for refusing to be informants for their fellow Muslim communities. The Religious Freedom Restoration Act holds the federal government responsible for accepting additional obligations to protect religious exercise. In O'Bryan v. Bureau of Prisons , it was found that the RFRA governs the actions of federal officers and agencies and that

2622-514: The basis of their own religious objection to same-sex marriage, transgender people, or extramarital sex. The sponsors of " Project Blitz ," a coalition of conservative Christian organizations supporting dozens of "religious liberty" bills at the state level across the United States, see Mississippi's law as model legislation. On March 9, 2016, the Missouri State Senate passed a religious freedom bill. Senate Democrats tried to stop

2691-598: The bill after significant national attention. There are not enough votes in the legislature to override the veto. Following the veto, Senator Steve Gallardo , one of the bill's most strident opponents, came out as gay. He identified the day that the bill passed the Senate as a "game changer". SB 1062 was intended to amend Section 41-1493 of the Arizona Revised Statutes, which prevents "any law, including state and local laws, ordinances, rules, regulations and policies" from "substantially burden[ing]"

2760-520: The bill as a "game changer," and noted the national controversy surrounding its passage, as prompting his decision. The United States Supreme Court ruled in Employment Division v. Smith (1990) that a person may not defy neutral laws of general applicability, such as public accommodation laws, as an expression of religious belief. "To permit this," wrote Justice Scalia, "would make the professed doctrines of religious belief superior to

2829-555: The bill with a 39-hour filibuster, but Republicans responded by forcing a vote using a rarely used procedural maneuver, which resulted in the bill passing. In April, it was defeated 6-6 in a Missouri House of Representatives committee vote, with three Republicans joining three Democrats in voting against the bill. On March 10, 2017, Dennis Daugaard , the governor of South Dakota , signed into law SB 149, which allows taxpayer-funded adoption agencies to deny services under circumstances that conflict with religious beliefs. On May 20, 2019,

State Religious Freedom Restoration Acts - Misplaced Pages Continue

2898-531: The bill. As state law already allows businesses to refuse services to anyone for any given reason, business owners noted that refusing services to LGBT people was currently allowed anyway. They would only be losing business by discriminating and do not need extra protections for something they cannot be sued for. Erwin Chemerinsky, dean of the UC Irvine law school, argued that the bill was harmful and "sends

2967-441: The case of United States v. Lee (1982). Here the court stated: Congress and the courts have been sensitive to the needs flowing from the Free Exercise Clause , but every person cannot be shielded from all the burdens incident to exercising every aspect of the right to practice religious beliefs. When followers of a particular sect enter into commercial activity as a matter of choice, the limits they accept on their own conduct as

3036-471: The denial of services based on a person's sexual orientation or gender identity . Twenty-one states, not including Arizona, have similar public accommodation laws protecting sexual orientation. The New Mexico Supreme Court ruled in Elane Photography v. Willock that the state's RFRA could not be invoked between two parties if the government was not a party to the legal proceedings. The bill

3105-551: The entity is organized and operated for profit or nonprofit purposes". Indiana Democrats proposed an amendment that would not permit businesses to discriminate and the amendment was voted down. An RFRA bill in Georgia has stalled, with constituents expressing concern to Georgia lawmakers about the financial impacts of such a bill. Stacey Evans proposed an amendment to change references of "persons" to "individuals", which would have eliminated closely held for-profit corporations from

3174-617: The federal war on drugs . And the American Indian Religious Freedom Act , which Congress had passed to protect tribal religious freedoms, lacked an enforcement mechanism. These interests collided in Lyng v. Northwest Indian Cemetery Protective Association , 485 U.S. 439 (1988), and Employment Division v. Smith , 494 U.S. 872 (1990). In Lyng , members of the Yurok , Tolowa and Karok tribes argued that

3243-468: The federal government—for instance, in Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal —because Congress has broad authority to carve out exemptions from federal laws and regulations that it itself has authorized. In response to City of Boerne v. Flores and other related RFRA issues, twenty-one individual states have passed State Religious Freedom Restoration Acts that apply to state governments and local municipalities. State RFRA laws require

3312-425: The federal government—for instance, in Gonzales v. O Centro Espírita Beneficente União do Vegetal (2006) and Burwell v. Hobby Lobby Stores, Inc. (2014). In response to City of Boerne v. Flores and other related RFR issues, twenty-one individual states have passed State Religious Freedom Restoration Acts that apply to state governments and local municipalities. This law reinstated the Sherbert Test , which

3381-578: The free exercise of religion in a diverse society. The addresses and panel discussions are all available online, as well as a special downloadable resource with more on RFRA, published by the Baptist Joint Committee. Arizona SB 1062 Arizona SB 1062 was an Arizona bill to amend an existing law to give any individual or legal entity an exemption from any state law if it substantially burdened their exercise of religion, including Arizona law requiring public accommodation . It

3450-423: The government may not accommodate religious belief by lifting burdens on religious actors if that means shifting meaningful burdens to third parties. This principle protects against the possibility that the government could impose the beliefs of some citizens on other citizens, thereby taking sides in religious disputes among private parties. Avoiding that kind of official bias on questions as charged as religious ones

3519-497: The implementation of that law, whether statutory or otherwise", including any Federal statutory law adopted after the RFRA's date of signing "unless such law explicitly excludes such application." According to a federal appeals court ruling on March 7, 2018, the RFRA did not justify discrimination against employees on the basis of their lesbian, gay, bisexual, or transgender identity in those circumstances. However, on October 15, 2019, federal judge Reed O’Connor said that, because of

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3588-462: The law of the land, and in effect to permit every citizen to become a law unto himself." He wrote that neutral laws of general applicability do not have to meet the standard of strict scrutiny , because such a requirement would create "a private right to ignore generally applicable laws". Strict scrutiny would require a law to be the least restrictive means of furthering a compelling government interest. The meaning of neutral law of general applicability

3657-550: The practice of a traditional Indian religion is lawful, and shall not be prohibited by the United States or any state. No Indian shall be penalized or discriminated against on the basis of such use, possession or transportation." Tanzin v. Tanvir (2020) determined that RFRA allows for those whose religious rights are adversely affected by federal officers acting in their capacity for the government to seek appropriate remedies, including monetary damages, from those individuals. The case involved three Muslim men, all legal residents of

3726-594: The proposed law, but the amendment was rejected because it would not give protections to closely held corporations to practice religious freedoms granted by the Supreme Court in the Hobby Lobby case. Some commentators believe that the existence of a state-level RFRA bill in Washington could have affected the outcome of the Arlene's Flowers lawsuit . Politifact reports that "Conservatives in Indiana and elsewhere see

3795-485: The rule to the laws of their own state, but the Smith case remains the authority in these matters in many states. The constitutionality of RFRA as applied to the federal government was confirmed on February 21, 2006, as the Supreme Court ruled against the government in Gonzales v. O Centro Espírita Beneficente União do Vegetal , 546 U.S. 418 (2006), which involved the use of an otherwise illegal substance in

3864-589: The taxpayers. In Navajo Nation v. United States Forest Service , the Court of Appeals for the Ninth Circuit held that the use of recycled sewage water in order to manufacture artificial snow in the San Francisco Peaks was not a "substantial burden" on the religious freedom of Native Americans. The RFRA figured prominently in oral arguments in the case, Burwell v. Hobby Lobby , heard by

3933-546: The tribal members with " ghost sickness " as the water would be from mortuaries and hospitals. They also felt that the reclaimed water would contaminate the plant life used in ceremonies. In August 2008, the Ninth Circuit Court of Appeals rejected their RFRA claim. In the case of Adams v. Commissioner , the United States Tax Court rejected the argument of Priscilla M. Lippincott Adams, who

4002-415: Was elaborated by the court in 1993 . The US Congress responded by passing the Religious Freedom Restoration Act (RFRA), requiring strict scrutiny when a neutral law of general applicability "substantially burden[s] a person's exercise of religion". When the Supreme Court ruled in 1997 that the RFRA was inapplicable to state laws, some states passed their own Religious Freedom Restoration Acts , including

4071-472: Was "following the issue in Arizona and will continue to do so should the bill be signed into law", prompting concerns from Arizona business leaders that signing of SB1062 would lead to the pulling of Super Bowl XLIX , similar to how Super Bowl XXVII was moved to Pasadena, California after a Martin Luther King Jr. Day ballot measure failed in Arizona's 1990 elections. The issue was rendered moot by

4140-434: Was a devout Quaker . She tried to argue that under the Religious Freedom Restoration Act of 1993, she was exempt from federal income taxes . The U.S. Tax Court rejected her argument and ruled that she was not exempt. The Court stated that "while petitioner's religious beliefs are substantially burdened by payment of taxes that fund military expenditures, the Supreme Court has established that uniform, mandatory participation in

4209-467: Was intended to interfere with religion; therefore, the Act states that the "Government shall not substantially burden a person's exercise of religion even if the burden results from a rule of general applicability." The law provided an exception if two conditions are met. First, the burden must be necessary for the "furtherance of a compelling government interest." Under strict scrutiny, a government interest

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4278-539: Was introduced by Senator Steve Yarbrough to amend a law currently giving religious assemblies or institutions a religious exemption from any law. The bill was passed by the Republican -controlled Senate on February 19, along party lines and passed by the state House on February 20. The vote tally in the Senate was 17 for, 13 against, and in the House, 33 for, 27 against. On February 26, Governor Jan Brewer vetoed

4347-482: Was introduced in the Senate by Ted Kennedy ( D - MA ) the same day. A unanimous U.S. House and a nearly unanimous U.S. Senate —three senators voted against passage—passed the bill, and President Bill Clinton signed it into law. The federal RFRA was held unconstitutional as applied to the states in the City of Boerne v. Flores decision in 1997, which ruled that the RFRA is not a proper exercise of Congress's enforcement power. However, it continues to be applied to

4416-484: Was one of several similar bills in U.S. state legislatures allowing individuals to refuse service based on religion, with some bills specifically protecting religious disapproval of same-sex marriage . It was widely reported as targeting LGBT people, although Arizona law at the time provided no protection against discrimination on the basis of sexual orientation . Critics noted that it would have broadly denied anyone service on religious grounds. Supporters argued that it

4485-487: Was overturned by the United States Supreme Court . The Roman Catholic Archdiocese of San Antonio wanted to enlarge a church in Boerne, Texas , but a Boerne ordinance protected the building as a historic landmark and did not permit it to be torn down. The church sued, citing RFRA, and in the resulting case, City of Boerne v. Flores , 521 U.S. 507 (1997), the Supreme Court struck down

4554-427: Was passed in response to the United States Supreme Court 's 1990 decision in Employment Division v. Smith , which held that "neutral laws of general applicability" that burden the free exercise of religion do not violate the First Amendment to the United States Constitution . RFRA requires that strict scrutiny be applied to any law that burdens religious freedom, providing that such a law may only be justified if it

4623-424: Was set forth by Sherbert v. Verner , and Wisconsin v. Yoder , mandating that strict scrutiny be used when determining whether the Free Exercise Clause of the First Amendment to the United States Constitution , guaranteeing religious freedom, has been violated. In the Religious Freedom Restoration Act, Congress states in its findings that a religiously neutral law can burden a religion just as much as one that

4692-437: Was simply restoring the legal status of the right to free exercise of religion as intended by the First Amendment to the United States Constitution . The bill was passed by the Republican -controlled state legislature and vetoed by Republican Governor Jan Brewer on February 26, 2014. The national controversy surrounding the bill prompted Arizona State Senator Steve Gallardo to publicly come out as gay. He referred to

4761-465: Was vetoed by Governor Jan Brewer . Bills 1161 and 1171 have been vetoed by a Colorado committee. In April 2015, the governor of Arkansas , Asa Hutchinson , signed a religious freedom bill into law. The version of the bill he signed was more narrow in scope than the original version, which would have required state and local governments to demonstrate a compelling governmental interest to be able to infringe on someone's religious beliefs. In March 2016,

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