Warner v. City of Boca Raton

Summary

The Supreme Court of Florida answered certified questions concerning the scope of the Florida Religious Freedom Restoration Act (FRFRA) and a City of Boca Raton ordinance regulating vertical grave decorations. The court held that the FRFRA provides broader protection than federal Free Exercise Clause precedent, but concluded that the ordinance did not violate the FRFRA because it did not substantially burden the appellants’ religious exercise. The court defined a substantial burden as compelling conduct forbidden by religion or forbidding conduct required by religion.

Holdings

1. The FRFRA provides broader protection for religiously motivated activity than the Free Exercise Clause as interpreted by the United States Supreme Court because it applies the compelling-interest test to neutral laws of general applicability and protects acts or refusals to act that are substantially motivated by religious belief whether or not compulsory or central to a larger system of religious belief.
2. A substantial burden on the free exercise of religion is one that either compels a religious adherent to engage in conduct forbidden by the religion or forbids the adherent from engaging in conduct required by the religion.
3. The City of Boca Raton's ordinance prohibiting most vertical grave decorations did not violate the FRFRA because it did not substantially burden appellants' exercise of religion.

Questions Presented

1. Whether the Florida Religious Freedom Restoration Act broadens the protection for religiously motivated conduct beyond the protection recognized under United States Supreme Court Free Exercise Clause precedent.
2. Whether the City's neutral, generally applicable ordinance prohibiting most vertical grave decorations violated the Florida Religious Freedom Restoration Act.
3. What constitutes a substantial burden on the exercise of religion under the Florida Religious Freedom Restoration Act.

Disposition

remanded